On Monday evening, the Irish Farmers Journal team hosted a webinar detailing proposals within the Department of Agriculture’s draft Nitrates Action Programme. Over 2,000 farmers tuned in. It was unfortunate that despite Minister for Agriculture Charlie McConalogue’s commitment to consult extensively with farmers, no one from his Department was available to join and provide clarity on the range of outstanding issues.

The level of farmer interest is not surprising given the increased regulatory burden set to be imposed on farmers operating at what are relatively low stocking rates. The requirement for farmers stocked at over 100kg of organic N/ha (just 1.1 cows per ha) to use Low Emissions Slurry Spreading (LESS) equipment is estimated to see an additional 60,000 farmers having to adopt this technology.

It is important to point out the environmental and nutrient efficiency benefits of this technology at farm level. Farmers using LESS report better crop response and more flexibility when grazing swards. The environmental benefits in terms of gaseous emissions and nutrient run-off are equally important. But it is also important to point out the limitations. At a basic level, the availability of this technology is limited with waiting periods currently over six months. This is likely to extend given the need for so many farmers to adopt it by 2023. Clearly some flexibility needs to be provided around implementation.

The consequences of forcing farmers to use LESS equipment regardless of land type could lead to a concentration of slurry spreading

There are also cost implications, particularly on smaller farms where slurry is spread using owned equipment. These costs will be significant on lower-income drystock farms that will be required to retain the cost of a tractor while incurring additional contractor costs. In the case of larger units that can justify the investment in a LESS tanker, they will likely be required to invest in a larger tractor.

This added investment will be significant where spreading is taking place on marginal land or on steep ground/hill-type land.

The consequences of forcing farmers to use LESS equipment regardless of land type could lead to a concentration of slurry spreading on the flatter, better-quality land. To avoid this, some flexibility needs to be introduced for more challenging terrain.

The requirement for increased storage capacity for soiled water and slurry has frustrated farmers. Few argue against the need to have adequate storage capacity. Spreading slurry in poor weather or outside permitted periods has huge implications for water quality – implications for which all farmers are paying. Many believe that these more stringent storage regulations are a reflection of farmers paying for those individuals who flaunted the existing rules.

The price penalty is significant. Aidan Brennan has calculated the cost implications for a typical dairy farmer to be €18,000. Added to this, farmers who have just completed major building works in line with existing regulations could be told these facilities are no longer adequate and require further investment. There is clearly more guidance needed as to what constitutes a covered slurry store. This information is needed immediately for farmers in the process of building tanks.

Flawed proposal

While the scientific justification for demanding adequate storage for soiled water and slurry is strong, the proposal preventing soiled water from mixing with slurry is flawed. It is ideological to require a farmer with adequate combined storage on the farm to build a separate tank for soiled water. Also, have the implications for spreading much thicker slurry been properly considered?

The new organic nitrogen bands are a clear signal from Government on where it wants dairy farm systems and genetics to go: away from high-input and high-output systems. However, this measure poses a serious financial risk to many farmers with high-yielding herds who are highly stocked, many of whom are on marginal land. A phased introduction would give farmers time to adapt.

One element that has not been considered within the draft proposal is encouraging farmers to transfer stock during the closed period to farms with adequate storage facilities – in the main tillage farms. Often the biggest barrier to this is the associated paperwork and/or issues around animal movements. In other parts of the world, we have seen the movement of fattening pigs into tillage areas incentivised in order to transfer the production of slurries.

Ultimately, the measure of success with regard to these proposals will be the impact on water quality. It is critical for the future development of the sector that they deliver. For this to happen, the Department must ensure measures are proportionate and science-led in order to get farmer buy-in. Also, measures contained within the Nitrates Action Programme should not be looked at in isolation. Farmers adopting these measures should be given credit within the CAP and – where appropriate – be recognised within eco-schemes.

There must also be flexibility to ensure farmers can use the most appropriate spreading techniques to ensure slurry continues to be spread across a range of land types. But perhaps most of all, the regulations must be enforced to ensure that the actions of a few are not allowed to tarnish the good work of an industry.