DEAR SIR: While it is regrettable to see clouds of soil being eroded away as dust on a recent front cover of the Irish Farmers Journal, I feel your front cover picture recently did a service in highlighting how contentious the newly introduced mandatory stubble cultivation rules under the Nitrates Action Plan are.

From a water quality perspective, management practices like shallow stubble cultivation to encourage growth and associated uptake of nitrogen can be beneficial, particularly on free draining, higher rainfall, crop producing catchments and regions. However, the arbitrary requirement to cultivate after seven days (or within a maximum of 14 days) after harvesting is very inflexible and takes no account of our notoriously unpredictable summer weather. This point was consistently highlighted by IFA in submissions made to the Department of Housing, Planning and Local Government on proposed changes to stubble cultivation requirements as part of the revised Nitrates Action Plan.

There are always trade-offs in agricultural policy objectives, but soil erosion is a clear winner from mandatory cultivation in the current prevailing soil/weather conditions.

Conversely, if we have more typical, wet summer weather conditions like July or August 2020, when soil moisture deficits were negative, there is little point in compacting and damaging soil structure with shallow cultivation.

Accurate, up-to-date, agrometeorological criteria are needed to determine when shallow stubble cultivation is appropriate. These criteria need to be urgently established by the Nitrates Expert Review Group to ensure negative outcomes like those in the picture do not become the norm across the country in future years.