Current proposals from the Scottish Environment Protection Agency (SEPA) are that under the Controlled Activities Regulations (CAR), all those abstracting more than 10 cubic metres of water per day will be charged for registration.

NFUS has submitted a response to these proposals, to represent the interests of farming members as regards the potential impact of the proposals on their businesses.

In particular, NFU Scotland highlighted the following points:

• Charging for the privilege of being regulated is fundamentally unfair. Compliance with the CAR will impose costs on those who are being regulated. The costs of administration of regulation should be paid from general taxation.
  
• Proposed charges should be adjusted in light of the independent auditor's report into SEPA's costs.

George Lawrie, Chairman of the NFUS Environment & Land Use Committee, said:

"Whilst this consultation has taken place following NFUS participation in stakeholder groups and that we believe the process to be effective, there is a fundamental issue that has not been resolved to our satisfaction.

"We believe that the Scottish Executive grant-in-aid to SEPA is inadequate relative to the functions it must discharge. Regulations are introduced in the wider public interest and so it is unfair that those who are being regulated will have to meet the costs of compliance. This flies in the face of the Polluter Pays Principal because a financial penalty is being applied to those who, through their compliance with the rules, are ensuring that the objectives of the Directive are being met.

"On the specifics of the proposed charges, we have still not had the report from the independent auditor so we can't tell yet whether or not they are fair.

"Also, it's important that those farmers who only use one abstraction point in any given year should not be charged over and over again for the regulations of only one activity."

Water Abstraction Talks Continue