Following an article in the edition dated 8 November which compared potential changes to the Nitrates (Nutrients in NI) Action Programme (NAP) either side of the Irish border it was correctly pointed out that proposed nitrogen (N) fertiliser limits are actually higher in NI.

In the South, authorities have cut the maximum allowance by 15% in recent years, taking it down to 240kg N/ha. No further reductions are planned in the latest NAP to apply from 2026 to 2029.

In NI, under the existing NAP, dairy farmers can spread up to 272kg N/ha on their grassland area, while other farms can apply up to 222kg N/ha. It works out at a maximum of 8.25 bags and 6.75 bags per acre of 27% N fertiliser respectively.

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In the NAP proposals from May 2025, DAERA suggested new limits for both silage and grazing based on target grass yields while also making an allowance for the N in slurry. At the top end (intensive, high yielding dairy), up to 270kg could be spread on grazing and up to 242kg N/ha on silage ground. However, much lower limits were suggested for lower input farms.

The proposed system looks bureaucratic and it is unclear how it could ever be enforced. The Stakeholder group currently tasked with devising with a new NAP plan will have to find a simpler solution.

Extensive

One related issue that has received no attention, is what constitutes an “extensive” farm enterprise within the NAP rules. At present, it is a farm with less than 120kg manure N per ha per year.

In their proposals, DAERA suggested this business has a total fertiliser N requirement of just 130kg/ha (3.9 bags per acre of 27%N).

If we take a 110-acre unit, stocked with 50 suckler cows and with all cattle taken through to beef at 24 months in a predominantly grass and forage-based system, it comes in just below the 120kg limit, so is classed as ‘extensive’.

Under the proposed rules it could only apply around 18t of CAN annually (once slurry N is allowed for). In practice, that limit seems incredibly tight. Even if it is backed up by science, some practical reality needs built in to whatever is agreed next.