The introduction of a whole farm plan on nutrient use, backed up by a certification system, has been recommended for derogation farms by the Environmental Protection Agency (EPA).

The proposal is part of its submission to the nitrates derogation review, initiated by the Department of Agriculture as a result of the increasing numbers of farmers availing of the facility.

The EPA wants the certification system to monitor the management of fertiliser and manure on farms as well as the actions undertaken by farmers to protect the environment.

Environmental targets such as limiting nutrient losses to water, reducing air and greenhouse gas emissions, enhancing biodiversity and complying with agri-environmental or other certification schemes could all be included.

Whole farm plan

To ensure these targets are being met, the EPA proposes the whole farm plan to take account of a farm’s nutrient management plan, its grass growth monitoring and actions to support the environment.

The EPA wants to trial this approach on derogation farms with a view to extending it to all farms classified as intensive (stocking rate >131kg N/ha). It also wants to see the scheme structured in such a way that could be included in an environmental scheme under the next CAP.

In its submission the EPA stressed that this approach would be good for the farmer, through increased nutrient efficiency, and good for the environment, through reduced nutrient losses.


However, it warned that a derogation was predicated on the basis that farming under such conditions did not cause environmental impact. The EPA said it was concerned that recent agricultural intensification coincided with a deterioration in water quality.

Given phosphorus loss occurs mainly on poorly-drained soils and nitrogen loss occurs on free-draining soils, the EPA wants the Department to consider a farm’s soil type before granting a derogation. It said this would prevent intensification occurring in unsuitable areas.

Other proposals for derogation farms include:

  • Mandatory use of grassland management systems such as PastureBase.
  • Reconsidering the practise of spreading slurry on freshly cut silage ground.
  • Recording of slurry storage capacity.
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