Back to Environment Homepage
18 March 2003
RSPB and Nitrate Vulnerable Zones:
a reflection of how they view farming
(Filed 18 March 2003)
The designation by SEERAD of Lower Nithsdale in
Dumfriesshire as a Nitrate Vulnerable Zone was challenged in the
Transport and Environmental Committee of the Scottish Parliament
(22 January 2003) on the basis of inadequate scientific evidence
to justify such a designation (1).
The scientific evidence provided by an independent and authoritative
body (2) clearly indicated that
there was no scientific justification for such a designation.
However, the RSPB were invited to give evidence
in support of maintaining the designation. What they had to say
gives a good insight into how the RSPB views farming. The report
of their evidence obtained from the minutes of the Committee (3)
is given below:
RSPB Evidence to Transport and Environment Committee January 2003
RSPB Scotland has been
disappointed with the Scottish Executives progress in
implementing the Nitrates Directive. An earlier and well-planned
approach, working in partnership with agricultural and environmental
organisation could have lead to real benefits for the Scottish
RSPB Scotland welcomes proposals to designate
the Lower Nithsdale area. The British Geological survey indicates
nitrate levels over the level that the EC Nitrates Directive
requires designation to be made. The Directive also requires
the designation of waters that could
be at risk from pollution if no action is taken. If heavy
rainfall had contributed to the high reading, then these waters
are at risk and should be designated.
Why does RSPB Scotland support NVZs?
Chemical pollution from agricultural sources
has been shown to have impacts on populations of wild birds,
both directly (for example, through eutrophication of water
courses) and indirectly (through the mechanical applications
RSPB Scotland welcomed the Nitrates Directive
as an opportunity for Government, agricultural and environmental
interests in Scotland to work together to reduce chemical
pollution. This reduction would promote environmental justice
and have many benefits including:
- Economic benefits for farmers as inputs
- A healthier countryside full of wildlife
- Promote Scotland and its produce as clean
- Reduced costs of removing chemicals from
our drinking water
The NVZ process in Scotland
RSPB Scotland has been very disappointed
with SEERADs minimalist approach to NVZs.
These disappointments include:
- Actions fail to encourage good practice
in land management.
- There has been little integration with
other policies, for example set-aside. We would wish to
see farmers place set-aside along watercourses where possible.
- The designation of land has been minimalist,
and has not followed the precautionary principle. We advocate
further designation of intensive arable and livestock rearing
areas of Scotland (such as the area proposed by SEERAD in
January 2002, plus Ayrshire and Dumfries and Galloway).
This would avoid perceived discrimination and raise environmental
standards across Scotland.
- The designation of land does not adequately
address the Directives requirement to designate waters,
which could be affected by pollution if action is not taken.
The above clearly shows that the RSPB wants to
gold-plate an EC Directive to the maximum. Even although objective
science does not support it. The imposition of the designation NVZ
in Lower Nithsdale was based on a single reading. Instead of recommending
the sensible and proper scientific course, which would be to check
the situation with further readings under differing conditions,
the opportunistic RSPB argues that, as the single reading could
possibly have been as a result of heavy rainfall, the area should
be designated. The RSPB should know that in science it is very unwise
to make important decisions on a single reading, especially when
there is ample opportunity to check the finding by repeating the
analysis as often as scientifically required.
The RSPB then goes on to make a series of disingenuous
recommendations which suggest that, in their view, it would be a
good thing anyway to designate Lower Nithsdale as a NVZ.
No farmer benefits from restrictions of inputs
when such restrictions are not required, He is perfectly able (with
the help of his advisors if necessary) to restrict inputs on his
own account. Unnecessary inputs are of no benefit to the farm, especially
in these days of severe financial constraints. Do we really need
the RSPB to be telling farmers what to do, when there is no adequate
scientific evidence to support what the RSPB say?
What is the point of imposing unsubstantiated
restrictions (together with copious form filing and other layers
of bureaucracy) on such a spurious basis - it promotes a healthier
countryside, a healthier wildlife, a cleaner and greener image and
less cost of removing chemicals from drinking water (when they have
not been convincingly shown to be there in the first place).
There is little wonder the RSPB is just a touch
too keen to try and manipulate science to promote its own image,
as indeed the Advertising Standards Authority have confirmed (4),
However, the RSPB does itself no favours when the science it is
trying to manipulate does not substantiate their actions.
The Scottish Executive chose to uphold the designation
(1). Was that why the RSPB was invited to come
and give them support for an illogical decision?
1. Nitrate Vulnerable
Zone (NVZ) in Lower Nithsdale: Demonstration of Poor Science over-ruled
by Scottish Parliament.
(Filed 18 February 2003, www.land-care.org.uk,
here to view).
2. Entec UK
Ltd (2003). NFU Scotland. Proposed Lower Nithsdale Nitrate Vulnerable
Zone. Review of the Proposed Lower Nithsdale Nitrate Vulnerable
Zone. January 2003. (Download
and Environment Committee Minutes. 2nd Meeting, 2003 (Session 1).
Wednesday 22 January 2003.
4. RSPB falls
foul of the Advertising Standards Authority
(Filed 18 March 2003, www.land-care.org.uk,
click here to view).