The fifth cycle of Ireland’s Nitrates Action Programme is currently being developed.
The programme, which covers the period 2022 to 2025, will need to be completed and have ministerial sign off before the end of quarter four of 2021.
A second-stage consultation document was recently released to allow farmers and stakeholders an opportunity to submit feedback on the proposals. The window to do so is relatively tight, with the deadline for receipt of responses set as Monday 20 September.
More information required
For farmers to optimally make submissions there are a number of clarifications required on several aspects of the proposals. Similar issues have been raised through farmer and stakeholder feedback and these same issues were also to the fore in a webinar hosted by the Irish Farmers Journal on Monday night (watch back at www.ifj.ie/nitrates).
The panel on the night included Aidan Brennan, Jack Kennedy, Adam Woods and Darren Carty.
A request was sent to the Department to have an official present but the Department declined in light of them opting to organise their own webinar on Monday 6 September. The main farm buildings- and farmyard-related issues which were discussed on the Irish Farmers Journal webinar and need to be clarified in next week’s Department webinar are outlined as follows.
Arguably the greatest debate on the night surrounded soiled water proposals.
These state that soiled water will no longer be allowed to be mixed with slurry, with the date at which this will be introduced not yet published. All farmers producing soiled water on their farm must also have a minimum of four weeks’ soiled water storage in place by 2025. The proposals also state there can be no spreading of soiled water between 15 November and 15 January (an eight-week period).
Farmers with winter milking herds are particularly aggrieved at the rules
These rules will hit dairy farmers hardest but also have the potential to cause significant disruption on all farms where soiled water is produced. Farmers with winter milking herds are particularly aggrieved at the rules and state the minimum of four weeks’ storage for soiled water is misleading as they will essentially need to have eight weeks’ storage in place.
Other farmers with ample slurry and soiled water storage also bemoaned the fact that they will be required to build separate soiled water storage facilities and make significant investments that are in many cases not required. It was stated on the night that the thinking behind the rule is to prevent soiled water mixing with slurry on dairy farms and eroding slurry storage capacity. This is highlighted as being a major issue, with only half of farmers said to have sufficient capacity.
The farmers who have ample storage are casualties of this rule. Other farmers outside of dairy could also be casualties of the soiled water rule if proposals remain in place for these farms stating that soiled water cannot be mixed with slurry.
The difficulty arises if there is any loose or fallen silage on the base and rainfall is falling on this
An issue which was continually raised on the night is the collection of soiled water from silage pits. At present, effluent has to be collected and stored for as long as necessary but once silage has been preserved and there is no effluent seepage then clean water can be diverted to suitable outlets. On many farms this effluent is collected in slatted tanks.
The difficulty arises if there is any loose or fallen silage on the base and rainfall is falling on this or where, for example, dung is stored on the corner of a silage base for a short period in spring.
Under the letter of the law, rain falling on these areas is classified as soiled water and farmers will be required to build separate storage facilities regardless of how much capacity is in place.
Clarification is required on what exactly classifies as soiled water and if the soiled water rule is applicable to all farmers.
The other area which was raised several times on the night is with regard the requirement to cover all new unroofed/external tanks by 2022 and existing tanks by 2028.
This proposal is aimed at curtailing ammonia emissions by reducing air flow across the surface of slurry rather than being designed to prevent water from entering tanks.
The proposal is pretty clear in the case of open tanks and the area where clarifications are required is if slats classify as providing a ‘roof’ or ‘cover’ over external tanks.
There are a high number of tanks built in recent years in tandem with topless cubicles or outdoor feeding areas that fall in to this category.
Will the slurry storage requirements for dairy cows change in line with the new bands being introduced on nitrogen excretion levels? If so, what will be the baseline figure from the new bands for the current figure used of 0.33m3 per week?
There is no mention of this change in the draft Nitrates Action Programme second stage consultation document. However the Irish Farmers Journal understands this storage figure of 0.33m3 is being reviewed with the possibility of changing it and bringing it in line with the new excretion bands.
Regarding what baseline figure will be used, it is difficult to gauge this as the original figure was in line with a nitrogen excretion rate of 85kg organic N. The proposed new bands which are due to come in to play on 1 January 2022 are 80kg N for cows producing less than 4,500kg milk (approximately 4,365l), 92kg N between 4,501kg and 6,500kg (approximately 4,366l to 6,300l) and 106kg N for cows producing greater than 6,500kg milk (6,300 litres).
It is likely that the storage requirements, if changed, will reflect these bands in some way but as yet no figures have been mentioned.
If the storage requirements are to change, then farmers need to know as there is little point planning yard alterations to satisfy new soiled water requirements and then find out that slurry storage requirements may also be deficient.
I have 55% of my milking platform on long-term lease agreements, all due to expire in December 2024. What will we be expected to do regarding investment in slurry/soiled water storage as 20% of our storage is in lease agreement?
Yes, all facilities under your control need to satisfy the requirements regardless of if they are owned, rented or leased.
Do you have to cover dung and straw waste stored on a concrete base?
There is no requirement to cover dung and straw waste similar to what is proposed for unroofed tanks. However, it should be noted that water falling on these areas needs to be stored during the closed period. Therefore, it may be more prudent to cover some areas depending on the size of the store and the level of rainfall for the particular county.
If I do not milk during the winter months, do I still need to have a minimum of four weeks’ storage for soiled water?
Yes, you are obliged under current proposals to have a minimum of four weeks’ soiled water storage in place if you are producing it at any stage of the year.
It will be impossible to put in an additional soiled water tank in my yard. Can I install a tank in an adjoining field and use this to satisfy the requirement?
The proposals do not specify any requirement in terms of location and one would assume that the required storage can be in place in a different location as long as soiled water can be collected without mixing with slurry to transfer it.
Is there a standard figure for how much soiled water a cow produces?
This is another area where clarification is required at next week’s meeting.
Can I continue to export slurry?
Yes, there are no proposals to change existing measures, which include that slurry can only be exported to a farmer stocked at less than 170kg organic N/ha.
I export a significant volume of slurry to a local tillage farmer and purchase the straw from him. The arrangement always worked well, but if 15 September becomes the new deadline it will put an end to it as it will be too early to apply slurry and plough down afterwards. Is there any likelihood that there will be any derogation where slurry will be applied on tillage ground? Not having access to this as an outlet for slurry will mean I am forced to apply for a derogation.
This is a major problem in the new proposals. Slurry is a valuable source of nutrients on tillage farms and, on ground low in phosphorus and potassium, autumn is an ideal time to apply nutrients to build these indexes. The crop is also growing vigorously at this time and will require nitrogen.
The slurry is being applied to land and incorporated into soil as soon as possible after spreading – at least 48 hours. Although under new proposals slurry spread without low-emission slurry spreading (LESS) equipment will have to be incorporated within 12 hours to reduce gaseous losses.
Bringing forward the date for the closed period to 15 September means that farmers will be required to spread slurry when in a typical year many cereal crops may not be harvested, straw may not be gathered and beans are still to be harvested – remember 2021 has been an exceptional year weather wise. If farmers are practising good integrated pest management, they will not be sowing until into October to keep crop disease instance low and will cultivate ahead of sowing and therefore will apply slurry as close to that time as possible.
Applying at this time also decreases workload in the spring when weather is often difficult and it ensures livestock farmers’ tanks are empty.
Aside from the situation in this question, it is important to remember that most tillage farms have livestock. Those finishing cattle, for example, will have animals in sheds in the spring during sowing. This slurry will not be applied once crops are planted. Those crops may not be harvested by 15 September. Where is that slurry to go? Is the tillage farmer going to need to export slurry?
The proposed measure seems to be moving away from sustainable agriculture and getting farmers to work together to reduce artificial fertiliser use, improve soil health and decrease pressure on access to land.