BGS responds to England's NVZ concultation

BGS responds to England's NVZ concultation

Monday, January 21, 2008

Responding to government consultations on behalf of members is a key activity of the BGS Research and Development Committee. Last December, it submitted views on England's NVZ rules, having already contributed to Scotland and Northern Ireland consultations. Here we summarise its content

General summary
The Society is supportive of action to protect the environment and integrity of surface and groundwaters.

It recognises encouraging farmers to manage fertilisers and manures more effectively can lead to environmental and economic advantages.

It is, however, essential such action does not impose an unsustainable economic burden and farmers retain the flexibility in decision making to run their businesses cost-effectively, with due regard to environmental responsibility.

The Society is concerned that, if implemented in full, the proposed action will impose unacceptable costs on sectors of the industry and undue constraints and work.

Re-targeting NVZs
The Society believes NVZs should be designated only if there is a sound scientific basis for this action. It, therefore, supports a targeted approach, rather than designation of the whole country, But we recognise this could be seen to penalise some and not others.

De-designation
In view of the significant impact of the proposals, it is essential there is a scheme for de-designation where there is no longer a risk of nitrate pollution. So, where water quality has remained acceptable for an agreed number of years de-designation could occur, with regulations reinstated should quality deteriorate.

Closed periods for spreading manure
Proposed closed periods for high available nitrogen manures and associated storage requirements will impose unacceptable costs on many farm businesses. For farms without adequate storage at present, two years is insufficient to cover the high level of investment required.

There is a strong argument for not imposing closed periods for cattle slurry on grassland because:
- Data in Table 1 on page 33 of the consultation indicate closed periods for manures have a relatively small impact on nitrate losses.
- The need to empty slurry stores at the end of the closed period could pose a risk of pollution, particularly if this coincides with heavy rainfall. This may damage soil structure and increase release of greenhouse gases.
- In milder areas, grass continues to grow through winter. This is recognised in table A1 on page 21 of the consultation in the proposal for 80kg/ha inorganic nitrogen fertiliser to be applied to grazed grass.
- A safer and more practical option than rigid closed periods would be to permit low rates of slurry application on grassland throughout autumn/winter in accordance with the Code of Good Agricultural Practice.

Some of the measures are aimed at reducing losses of pollutants other than nitrates, e.g. incorporation of manures into soil within a short time after spreading will reduce ammonia emissions. Although desirable, we question whether these should be part of this legislation.

Record keeping
The proposals call for an excessive amount of record keeping by farmers, much of which is not necessary to run their farm business efficiently, but very time consuming. We ask: Is it all essential for enforcement? Could it be streamlined?

Clarity, jargon and policy definitions
The consultation document lacks clarity in places, uses policy terminology and "jargon" and is sometimes ambiguous. We assume on implementation, clearer guidance and documentation will be provided.

There are a number of terms that require clear definition, so farmers can comply with regulations. These, for example, include "high trajectory techniques for applying manures" and "dirty water".

Similarly, a range of different liquid and solid manures are often produced on the same farm and guidance is needed on what constitutes low and high available N, bearing in mind that farmers do not have ready access to chemical analyses of these materials.

Whole farm manure limits
The Society strongly supports action on the part of Defra to seek derogation from the whole farm limit for organic manure on the basis of retention of N, especially in grassland soils, high N removal, etc. Also, the financial impact of a sharp reduction in stocking rate would be damaging to many businesses.

Concluding remarks
Finally, the Society wishes to express disappointment that the earlier Action Programme implemented by Defra failed to have any significant environmental benefits.

It appears that four years towards meeting requirements of the Nitrate Directive have been wasted and now much more restrictive measures are proposed in order to achieve compliance.

You can see the full consultation document, The Protection of Waters Against Pollution from Agriculture: Consultation on implementation of the Nitrate Directive in England on the website www.defra.gov.uk and legislation is due to come into force in April 2008. The BGS R&D Committee response was complied by Brian Pain who can be contacted by e-mail: brian.pain.@ukgateway.net

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