The current nitrates derogation agreed under the nitrates action plan (NAP) is in place until 31 December 2021.
A mid-term review halfway into the four-year cycle has introduced a number of new elements farmers availing of the derogation must complete during 2021 and 2022. This will affect in the region of 7,000 intensively stocked farmers who apply each year for the derogation.
A document published on the Department of Agriculture website addressing frequently asked questions also tackles the question as to why the mid-term review took place when the derogation has already been granted.
The document states: “Given the current environmental challenges which include a continuing trend of disimprovement in water quality and the significant expansion in the dairy herd since the abolition of quotas, it was considered prudent to initiate a review of the derogation in advance of Ireland reviewing and considering an application for NAP 5 in 2021.”
It goes on to say the purpose of the review was to examine further opportunities for derogation farmers to improve efficiencies and continue to reduce their environmental footprint with particular regard to water, climate and air quality.
It says the introduction of further measures in 2020 to protect water quality will assist in the application for the next NAP in 2021.
There have been a number of queries on the new elements, with the most common and time-sensitive of these detailed below as per the Department document.
Q. Regarding the required reduction in the crude protein content in concentrates fed to grazing livestock, what level of reduction is required and what are the timelines?
A. Livestock with a 100% grass forage diet during the main grazing (1 April to 15 September) season will be required to follow the following:
A maximum of 16% CP between 1 April and 15 September in 2020.A maximum of 15% CP between 1 April and 15 September in 2021. Note: If higher levels of crude protein are required, this needs to be certified by the appropriate adviser. Appropriate concentrate records are also required to be submitted by 31 March in the following year and this is the case for farmers using blended mixes or straights.
Q. Derogation farmers must undertake grass measurements and record them through appropriate software technology. How will these measurements be verified, how many must be taken annually and must I complete training?
A. Measurements will be verified based on the dates of record entry. It is the responsibility of the derogation farmer to complete grass measurement and recording of grass data.
If the required skills are not in place to complete this, then derogation farmers must undertake training in grassland management which must be completed by the end of 2021. Proof of attendance is required for verification.
A minimum of 20 grass measurements is required per annum (falling plate meter or cut and weigh) on the main grazing platform only. Eyeballing grass is not a sufficient measurement.
The following measurements are required per month over the season: at least one in February, two in March, 14 in the period April to September, two in October and one in November.
Q. The review states commonage/rough grazing will not be eligible for the derogation allowance of 250kg livestock manure N/ha. How will DAFM define commonage/rough grazing for the purpose of the nitrates derogation?
A. This will be defined based on the declaration of commonage/rough grazing on the Basic Payment Scheme application. Commonage/rough grazing is eligible for inclusion in the whole farm stocking rate (WFSR) to 170kg livestock manure N/ha.
However, please note the following rules for commonage/rough grazing from 2020 for derogation farms:
Derogation farmer is permitted for inclusion to =170kg livestock manure N/ha.Chemical allowance permitted to =170kg livestock manure N/ha or WFSR stocking rate allowance, whichever is less. No further chemical allowance is permitted for commonage/rough grazing above a WFSR of 170kg livestock manure N/ha.Q. What are the requirements of the new liming programme?
A. The liming programme must be implemented in 2020 and based on a current nutrient management plan (NMP) and associated soil analysis results. The current NMP must be amended if a liming programme is not included. The lime application must be recorded on the annual fertiliser accounts and invoices will be required for inspection.
Lands by way of one-year (conacre) agreements do not have to be limed. However, if land is being managed for more than one year then it should be included in the liming programme. Note: the liming programme also applies to tillage lands on derogation farms.
Q. The document states slurry remaining on the holding after 15/4/2020 must be spread by low emission slurry spreading (LESS) and that all slurry on the holding from the 12/1/2021 must be spread by LESS. How will the Department capture and record the volume of slurry spread by LESS?
A. Farmers are required to furnish records on the volume of slurry spread by LESS for 2019, 2020 and 2021 in m3. This will be captured retrospectively on the derogation application form on a yearly basis. Farmers will also be required to show evidence or provide details of the use of a contractor or own equipment and invoices will be required. It is anticipated TAMS II grants will grant aid LESS equipment up until 15/04/2021 (one year after the mandatory introduction of LESS for farmers in derogation).
Note: Questions and answers concerning reseeding, biodiversity (all-island pollinator plan) and nutrient management training will be printed in next week’s paper.
The current nitrates derogation agreed under the nitrates action plan (NAP) is in place until 31 December 2021.
A mid-term review halfway into the four-year cycle has introduced a number of new elements farmers availing of the derogation must complete during 2021 and 2022. This will affect in the region of 7,000 intensively stocked farmers who apply each year for the derogation.
A document published on the Department of Agriculture website addressing frequently asked questions also tackles the question as to why the mid-term review took place when the derogation has already been granted.
The document states: “Given the current environmental challenges which include a continuing trend of disimprovement in water quality and the significant expansion in the dairy herd since the abolition of quotas, it was considered prudent to initiate a review of the derogation in advance of Ireland reviewing and considering an application for NAP 5 in 2021.”
It goes on to say the purpose of the review was to examine further opportunities for derogation farmers to improve efficiencies and continue to reduce their environmental footprint with particular regard to water, climate and air quality.
It says the introduction of further measures in 2020 to protect water quality will assist in the application for the next NAP in 2021.
There have been a number of queries on the new elements, with the most common and time-sensitive of these detailed below as per the Department document.
Q. Regarding the required reduction in the crude protein content in concentrates fed to grazing livestock, what level of reduction is required and what are the timelines?
A. Livestock with a 100% grass forage diet during the main grazing (1 April to 15 September) season will be required to follow the following:
A maximum of 16% CP between 1 April and 15 September in 2020.A maximum of 15% CP between 1 April and 15 September in 2021. Note: If higher levels of crude protein are required, this needs to be certified by the appropriate adviser. Appropriate concentrate records are also required to be submitted by 31 March in the following year and this is the case for farmers using blended mixes or straights.
Q. Derogation farmers must undertake grass measurements and record them through appropriate software technology. How will these measurements be verified, how many must be taken annually and must I complete training?
A. Measurements will be verified based on the dates of record entry. It is the responsibility of the derogation farmer to complete grass measurement and recording of grass data.
If the required skills are not in place to complete this, then derogation farmers must undertake training in grassland management which must be completed by the end of 2021. Proof of attendance is required for verification.
A minimum of 20 grass measurements is required per annum (falling plate meter or cut and weigh) on the main grazing platform only. Eyeballing grass is not a sufficient measurement.
The following measurements are required per month over the season: at least one in February, two in March, 14 in the period April to September, two in October and one in November.
Q. The review states commonage/rough grazing will not be eligible for the derogation allowance of 250kg livestock manure N/ha. How will DAFM define commonage/rough grazing for the purpose of the nitrates derogation?
A. This will be defined based on the declaration of commonage/rough grazing on the Basic Payment Scheme application. Commonage/rough grazing is eligible for inclusion in the whole farm stocking rate (WFSR) to 170kg livestock manure N/ha.
However, please note the following rules for commonage/rough grazing from 2020 for derogation farms:
Derogation farmer is permitted for inclusion to =170kg livestock manure N/ha.Chemical allowance permitted to =170kg livestock manure N/ha or WFSR stocking rate allowance, whichever is less. No further chemical allowance is permitted for commonage/rough grazing above a WFSR of 170kg livestock manure N/ha.Q. What are the requirements of the new liming programme?
A. The liming programme must be implemented in 2020 and based on a current nutrient management plan (NMP) and associated soil analysis results. The current NMP must be amended if a liming programme is not included. The lime application must be recorded on the annual fertiliser accounts and invoices will be required for inspection.
Lands by way of one-year (conacre) agreements do not have to be limed. However, if land is being managed for more than one year then it should be included in the liming programme. Note: the liming programme also applies to tillage lands on derogation farms.
Q. The document states slurry remaining on the holding after 15/4/2020 must be spread by low emission slurry spreading (LESS) and that all slurry on the holding from the 12/1/2021 must be spread by LESS. How will the Department capture and record the volume of slurry spread by LESS?
A. Farmers are required to furnish records on the volume of slurry spread by LESS for 2019, 2020 and 2021 in m3. This will be captured retrospectively on the derogation application form on a yearly basis. Farmers will also be required to show evidence or provide details of the use of a contractor or own equipment and invoices will be required. It is anticipated TAMS II grants will grant aid LESS equipment up until 15/04/2021 (one year after the mandatory introduction of LESS for farmers in derogation).
Note: Questions and answers concerning reseeding, biodiversity (all-island pollinator plan) and nutrient management training will be printed in next week’s paper.
This is a subscriber-only article
SHARING OPTIONS: