Responding to a consultation on the Environmental Regulation (Scotland) Charging Scheme for 2016, the Union has informed SEPA of its opposition to any increase in charges that go beyond inflation.

It is particularly angered by the huge increases being proposed for Pollution Prevention and Control (PPC) regulated businesses which primarily operate within the pigs and poultry sector.

The proposals include a 596 per cent increase in the charge for a technical variation to a PPC permit and an overall 81 per cent increase for large PPC permits.

For growers, the Union believes a proposed 20 per cent increase for water abstraction licences should also be withdrawn.

Commenting on the NFUS submission, Vice President Rob Livesey said: “While we broadly accept the principles that underpin any charging scheme, a further principle must be added – the ability of a business or sector to pay.

“Many agricultural businesses are operating on very small or no margins and returns in those pig, poultry and egg systems covered by PPC regulations are significantly worse that they were almost a decade ago.

“Through improved management and adoption of best practice, the environmental risk posed by intensive agriculture has improved significantly in recent years but gross margins have not. These businesses clearly have a reduced ability to pay and we can see no justification to increase charges.

“For our growers, we also oppose the intention to introduce a ‘mothballing charge’ where a farmer has chosen not to use a licenced site to abstract water. Many farmers will quite legitimately retain their abstraction licences as an insurance policy for dry years.

“Provided that they comply with the conditions of the abstraction licence, then it is unnecessary for SEPA to propose charging them were they to mothball the abstraction point.”