EC raised concerns about farmers’ ability to store manures outside of the closed period when weather conditions are unsuitable.
Initial research data is showing that February is a high risk month for spreading – EC have questioned ongoing spreading in February.
Continue research programme – due to produce final report 2012
DARD / DOE will survey on-farm practice in relation to application of manures and fertilisers.
No change proposed
22 weeks storage is already required to allow for storage beyond the end of the closed period (15.5 weeks) when conditions are unsuitable.
Research at AFBI used to assess February run-off is questionable due to level of slurry applied to research plots (4500 gallons/acre equivalent)- not comparable with farm practice.
It is crucial that February is not lost for slurry spreading. Strong arguments were put forward to permit spreading in February in previous consultation on Nitrates Action Programme – this position has not changed.
Spreading & Storage of Farm Yard Manure (FYM)
ROI have closed period for FYM (1 Nov – 31 Jan), EC suggested need similar in NI on the basis that there is no crop requirement during winter months
EC queried the use of field heaps for storing FYM, they are concerned that as these are permitted for up to 180 days there is the potential for pollution. Phased out field heaps of FYM during next 4 years .
Introduce closed period for FYM 31 October – 31 January
Field storage of FYM during closed period (31 Oct-31 Jan) prohibited from 31December 2012
Length of time FYM stored in field reduced from 180 days to 90 days
The UFU are opposed to the introduction of a closed period for FYM.
There are no closed periods for FYM in England, Scotland and Wales.
FYM field storage is important to many farmers and must be retained.
Farmers purchased slurry separators to allow solid fraction to be stored in field heaps and therefore reduce slurry storage requirements if this rule is changed, additional investment will be required on farms which is not feasible.
The UFU believe that there is no significant evidence to show that FYM field heaps are causing problems in Northern Ireland. There is no justification for change.
Arable farmers – 180 days storage essential
Farmers may not have alternatives to field heaps i.e. middens with effluent collection therefore significant investment would be required to bring many farms up to standard. It is unfair that any change is imposed at this stage when there is no opportunity to avail for funding e.g. FNMS.
If the Departments remove the ability to store in field heaps a new grant scheme must be considered.
FYM used by smaller farms and small percentage of ‘manures’ therefore no real problems from FYM heaps.
Field storage of poultry litter
EC concerned about high nutrient content of litter and particularly the over-application of P. They will not permit poultry field heaps beyond end of 2010 as these pose a significant risk to water quality.
Field storage of poultry litter will not be permitted from 1 January 2011.
DARD / DOE estimate 45 farms impacted (based on O’Kanes & Moy Park figures).
Concerns about the ability of the poultry sector and those importing litter to comply
It is vital that a positive decision on Rose Energy is announced to allow this project to proceed.
DARD / DOE have not accounted for litter from producers outside of Moy Park and O’Kanes.
If the Departments remove the ability to store in field heaps a new grant scheme must be considered.
Application of chemical fertiliser during the closed period, on the basis of crop need
at present farmers who can prove crop need for fertiliser during closed period are allowed to spread e.g. some vegetable crops. EC want evidence of this practice and figures on number of farmers doing this
DARD / DOE have proved to the EC that this practice is not common in NI.
No change proposed
This is only carried out by a very small number of farmers with specialist crops – there should be no need to change this measure.
Spreading distance from waterway
Queried the current 1.5 m limit for spreading chemical fertiliser close to watercourse. Have suggested increase to 2m.
DARD / DOE proposed to change to 2m
UFU oppose this change.
Steeply sloping fields
Queried the steeply sloping field measure (currently not allowed to spread on steeply sloping ground where there is a significant risk of water pollution)
EC want to remove the ‘where there is a significant risk’ clause and therefore the rule would prohibit spreading of chemical fertiliser or organic manures on any ‘steeply sloping ground’
Propose change to definition of ‘steeply sloping’ to where there is an average slope of 20% or more on grassland and 15% on arable land.
DARD / DOE propose to remove the ‘where there is a significant risk’ clause and change the definition as suggested by the EC.
20% = 1 in 5 slope or 12 degree slope
15% = 8.5 degree slope
This proposal would have very serious consequences for NI agriculture as it would prohibit the fertilising of most fields due to the proposed wording.
The UFU are totally opposed to any changes to the wording of this measure.
Many fields in NI are steeply sloping but do not present a risk to waterways – where is the evidence demonstrating need for changing this measure.
ROI currently have the same rule in place and under their review the EC or their Government did not request any change.
Not spreading chemical fertiliser / organic manures on ‘steep slopes’ could result on large areas on NI being unproductive.
DARD/DOE assessment of the potential impact this would have on local farms, as outlined in the consultation paper is not accurate. AFBI have assessed this based on measuring a hill slope over 100m not on field size. The UFU believe this would have a major impact on all local farms and may make many unproductive and unviable.
Derogation
EC have stated that if numbers fall any further they will not renew the NI derogation.
Queried the actions of those farmers who have higher stocking limits but not under derogation – wanted to know how exports were managed/controlled/inspected.
NIEA and DARD have agreed that they need to work to increase the numbers
DARD / DOE have submitted request to renew the nitrates derogation. They have already presented their case to the EU Nitrates Committee (April 2010) and a decision will be made in September / October.
The derogation is very important to some local farms and must be retained.
Current policing of the derogation is unacceptable – NIEA are not taking a practical approach in the assessing of Fertilisation Accounts and other aspects of the derogation.
DARD/NIEA/DOE need to do more to encourage farmers to apply for the derogation
Nitrogen excretion rates- Pigs and Poultry
Amendments to pig N and poultry N excretion rates following scientific work carried out by AFBI
The UFU support the amendment of these figures.
Management of silage effluent facilities
Pollution problems arising from inappropriate management of silage effluent.
Propose to change regulations to include the need to manage silage effluent
The UFU strongly oppose this measure. NIEA already have the ‘regulatory tools’ to deal with this under the NI Water Order. If this is introduced in Nitrates Regs, NIEA would enforce under cross-compliance therefore easy for them to penalise farmers.
‘Management’ is very ‘grey area’ and open to abuse by over-zealous inspectors.
EC have not asked for this measure to be amended therefore if introduced would be ‘gold-plating’ EC requirements
Appropriate person
Change regulations so that ‘appropriate person’ should be held responsible for an offence.
Contractors could be prosecuted now under the Nitrates Regulations through courts
Cross compliance penalties would apply to SFP claimant or ‘controller’ not the contractor.
