Mervyn Williams to David Jones MP

Tan y Graig

Llanferres

Mold

Denbighshire CH7 5TG

mervyn.williams@btinternet.com

20th April 2020

Rt.Hon David Jones MP

Dear Mr. Jones

You will see from my address at the head of this letter that I write to you as a one of your constituents. As such I’m copying Darren Millar as my AM

As a conservationist concerned with pollution of water courses from agricultural practices I have concerns that you appear to consider that legislation to reduce this pollution is not required.  I Chair the Dee and Clwyd Local Fisheries Advisory Group and I am a Trustee to the Welsh Dee Trust. Both organisations have been lobbying for protection from diffuse pollution from agriculture, which is causing so much damage to our water courses’ for many years.

I refer to the letter (dated 16th April) sent by the Conservative Group of Welsh MPs to Lesley Griffiths (Welsh Minister for the Environment, Energy and Rural Affairs). Having read the above letter, I make the following observations.

There are issues with the Welsh Intense Farming industry, most notably in this case, that of agricultural pollution. Pollution incidents of water courses are well documented over the recent years in the media. The Intensive Farming Industry has developed to an extent that it must regard its bye products of slurry, chicken and pig manure as industrial waste. It is the dealing with this growing amount of industrial waste that has led to the aquatic environment often failing to meet the Water Framework Directive (WFD) standards to the detriment of water quality, with consequent negative effect on aquatic life. 

The damage from diffuse pollution is not something that has just happened – it has increased over the past 20 years due to changes in agriculture practices with no significant action being taken either by the Welsh Government or by the Farming Industry as a whole. Both need to take a long hard look at their lack of action. It is disappointing that your letter fails to acknowledge the problem.

Throughout the expansion of factory farming, water quality in Welsh rivers has declined dramatically. This has had a significant effect on the recruitment of migratory fish (salmon and sea trout) in Wales, which have declined markedly.  While there are various reasons for the decline in migratory fish stocks – agricultural pollution must take a major proportion of the blame for this.

The issue of agricultural pollution has been raised in the majority of fishery related meetings I have attended over the past three years.  At the 2019 Inquiry re the New Fishery Bye Laws much play was made by NRW that the updated Bye Laws were part of a raft of regulations to improve migratory fish stocks.  Agricultural pollution controls were part of these regulations. Following the Inquiry Lesley Griffiths has instructed NRW to produce a Plan of Action for Salmon and Sea Trout.  In order to identify major issues affecting migratory fish stocks NRW organised meetings across Wales with local fishery groups (LFG’s). At all of these meetings the minutes record the issue of problems due to agricultural pollution reducing recruitment of juveniles.

Despite the impression you give in your letter, these regulations have been long expected and consequently anticipated by the Farming Industry. The Welsh Government had set up a Land Management Forum. Meetings with farmers and their organisations have been held across Wales. The impression in your letter is that farmers have been unaware of the proposed legislation and have had no input, this is not the case.

There are very valid reasons why there are dates and conditions for which there should be no spreading of slurry. This should have little or no impact on small farms who bed their animals on straw.  It is the holding of live stock on concrete surfaces and the washing down of these surfaces which cause the storage and pollution issues. There are valid concerns about the overuse of nitrates etc. The Vale of Clwyd has been declared a Nitrate Vulnerable Zone for more than 20 years.  Similarly there should be no issue over ensuring that storage for slurry is adequate to meet unforeseen circumstances as not all weather conditions are suitable to ensure that spreading does not impact on the aquatic environment.

I refer to the third paragraph in your letter where you seem to confuse environmental protection with environmental standards. Whilst farm equipment, barns and environs might be kept clean and to a high environmental standard, the storage of waste and its disposal is the issue.

I am sure that not all farms in Wales are polluters and that there are examples of good practice. Your biggest and major criticism seems to be over making the whole of Wales a Nitrate Vulnerable Zone.  This might be a valid argument to take up with the Welsh Minister but is lost by not acknowledging that Welsh farming (as an industry) has huge pollution problems. It’s also not helped by making the industry a special case in these trying times.  We are all suffering due to the current crisis and as for adding lambing as a valid argument against the legislation this beggars belief and shows just how little you understand of the problem.

Please feel free to share this letter with your fellow Welsh Conservative MPs

Your sincerely

Mervyn Williams

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