National Pig Association THE VOICE OF THE UK PIG INDUSTRY NPA is active on members' behalf in Brussels & Whitehall, and with processors, supermarkets & caterers - fighting for the growth and pros-perity of the UK pig industry.

Policy manager Ann Petersson makes the following points:

• NPA strongly supports the exclusion of pigs and poultry from the over winter and outwinter erosion provisions, as detailed in the possible soil measures for Good Agricultural and Environmental Condition.
  
  
• With regard to preventing run-off that causes soil erosion, a pragmatic approach is needed by providing guidance to prevent soil related problems on specific sites. Sector specific advice would be an appropriate approach and should include recognition of the essential health and welfare aspects of outdoor pig production.
  
  
• The NPA welcomes Defra's intention to avoid the use of prescriptive national measures. It opposes a "one size fits all approach" with every farmer required to produce a formal soil management plan. The approach should be based on risk assessment, and be proportionate and targeted accordingly. Nor should there be delays in the production of clear guidance for producers. If there are delays, then changes must be made to the milestones that follow.
  
  
• The NPA opposes the inclusion of a two-metre buffer strip either as an Entry Level Stewardship option, or a cross-compliant requirement. It is a costly requirement, and these buffer strip corridors could create biosecurity risks from trespass, especially for farms close to urban areas, where fly-tipping is also a regular occurrence.
  
  
• For pig-keepers, it is important that the storage of manure continues to be permitted on set-aside land.
  
  
• No changes should be are made to Public Rights of Way that might compromise biosecurity.
  
  
• NPA supports Defra's proposal to allow written warnings without penalty, and requests that an appeals process, similar to that under IACS, be an integral part of the inspection and sanction regime.
  
  
• It welcomes government's intention to minimise the administrative burden on farmers and the public purse. However, it is crucial that a joined up approach is adopted with the enforcement agencies, so that government's intentions are apparent in the field. This has not been the case with trading standard officers and the animal by-products regulation.
  
  
• The implications of cross-compliance are of particular interest to those mixed enterprise producers, who are members of the climate change levy scheme. Can a holistic approach be adopted, when the arable part of the enterprise is a net user of carbon and the pig sector a net carbon producer? Could an overall balancing or offsetting arrangement be achieved? This arrangement would present a positive aspect to cross-compliance and help to offset concerns that the unsupported sector is being penalised by CAP Reform.