Members will have seen that we opposed the draconian Natural Resources Wales (NRW) fee increases and have responded to the consultation accordingly. Our members were universally and genuinely astounded by many of the proposed increases in NRW regulatory charges for 2023/24.

There was a general lack of information and evidence in the consultation to justify the cost recovery and despite pre-consultation stakeholder engagement that offered a basic organogram to show what data and costs were modelled, numerical figures were missing to support the charge proposals.

An element that stood out for us was the impact of such exorbitant charge increases on efforts to control and eradicate sheep scab. In December, the Welsh Government announced an £8 million funding pot for a long-awaited 3 year national sheep scab eradication programme.

This funding represents a tremendous investment by the FUW and other stakeholders and the onset of this programme is to be welcomed. However, there is extreme and valid concern that the charges proposed could function to derail this national programme and that industry efforts to eradicate this disease will be significantly hindered.

Sheep scab has a significant impact on the health, welfare and productivity of affected animals. Alongside health and welfare implications, the effects of sheep scab infestations can lead to economic losses amounting to approximately £8 million per year in the UK.

There are just 2 types of treatment available to farmers to control and treat sheep scab, plunge dipping with organophosphate dips (diazinon) and endectocides (injectables 3–ML). Dipping used to be compulsory but since this ended, it has been estimated that sheep scab has increased 60 fold in the UK sheep flock.

In our response to the consultation we highlighted that plunge dipping is a vital tool in scab eradication and is regarded as the most effective tool in controlling both scab and other external parasites of sheep. However, the charges proposed under the Water Quality Discharge (Landspreading) section of the consultation would see a new application for sheep scab dip disposal rise from £402 to £3728–a rise of 827%. This is in addition to the new requirement for a habitat survey which, if required under the permit, would be charged at £1670.

The agricultural sector is continually driven towards more sustainable farming systems, which includes less use of antibiotics, anthelmintics and medicines. However, with the proposed increased costs for the disposal of used sheep dip, many farmers could resort to using injectables to control sheep scab, despite reports of parasitic resistance to injectables rising rapidly in recent years.

We strongly believe that the national sheep scab programme cannot be successful without extensive plunge dipping and that the introduction of the proposed charge increases will undoubtedly introduce a barrier to the successful control and eradication of this parasitic disease. The fact that the proposal to increase dip disposal charges coincides with the launch of a national sheep scab programme demonstrates a lack of joined up policy thinking and cohesion and there must therefore be a rethink on the ‘full cost recovery’ proposed in the consultation.

Furthermore, these exorbitant increases, if introduced in 3 months time, would allow farmers precious little time to adapt, at a time when the industry already faces so many other challenges.

Given the impact of the current charging proposals on livestock health, farmer wellbeing and business economics, the FUW does not agree that these increases represent the ‘right charges in the right places’ or that they are ‘appropriate’ and believes that the onset of any charge increases should be delayed until their full impact upon the national scab programme can be identified.

The farming sector continues to face numerous challenges on many fronts and this can impact on the well-being and mental health of FUW members. We do not agree that the proposed increases in charges are proportionate or fair and we are therefore calling for a rethink and recognition of the wider implications of such tremendous price increases.