River basin management plans - silage, slurry and liquid digestate – storage and application: consultation analysis

3. The Scottish Government response.

Scottish Government appreciated the responses to the consultation and the constructive comments. Following analysis of the responses Scottish Government has taken into account points raised and the potential cost implications for some in the farming sector.

Based on the analysis Scottish Government proposes that:

3.1 Silage storage

• The proposals on storage of silage in bales and bulk bags will be taken forward as drafted.

3.1.1 Pre 1991 stores

• In a change to the consultation proposals the exemption for pre-1991 stores will be removed but these stores will not be required to meet certain rules including the British Standards within the rules.
• Pre-1991 stores will be required to meet a basic set of standards which will ensure their integrity in being fit for purpose and protecting the environment.
• Where any pre-1991 store is enlarged, reconstructed, or remedial work carried out full compliance with all the silage storage general binding rules is required.

3.2 Slurry storage

• The requirement for 22 (cattle) or 26 (pig) weeks storage, for housed livestock, across Scotland will be taken forward.
• The requirement for 6 months storage has been in the SSAFO regulations since 1991.
• The ability to store slurry and apply when there is most nutrient benefit for crop growth is important for all farmers and can be a cost saving on expensive chemical fertilisers.
• We consider that it unfair that only those with storage constructed after 1991 be required to meet the minimum storage capacity requirement.

3.2.1 Pre-1991 storage

• In a change to the consultation proposals the exemption for pre-1991 stores will be removed but these stores will not be required to meet certain rules including the required British Standards.
• Pre-1991 stores will be required to meet a basic set of standards which will ensure their integrity in being fit for purpose and protecting the environment.
• Where any pre-1991 store is enlarged, reconstructed, or remedial work carried out full compliance with the slurry storage general binding rules is required.

3.3 Liquid digestate

• The provisions for the storage of liquid digestate will be taken forward as drafted.
• This is in line with storage of slurry as there are similar characteristics.

3.4 Notification of new silage, slurry, and liquid digestate structures.

• The requirement to notify SEPA before construction will be taken forward.
• This will help identify any issues before becoming operational.

3.5 Risk Assessment for Manures and Slurries map

• The requirement to produce RAMS maps will be taken forward
• RAMS maps have been used by many farmers for a number of years and recognised as a helpful tool.
• The requirement for all farmers to prepare RAMS map will help focus the general provisions of water environment protection.

3.6 The use of precision spreading equipment for slurry and digestate.

• The requirement to spread slurries and digestate will be taken forward.
• A phased move to low emission precision spreading equipment will provide further protection of the water environment from agricultural activities along with supporting Scotland's air quality and climate change targets.