While cow banding and other implications for dairy farmers may have hit the headlines when the new nitrates proposals first came out, all farmers, including lower-stocked drystock farmers, will bear the brunt of the new proposals in the Nitrates Action Plan (NAP).

One of the proposals that has seen the biggest reaction from drystock farmers and advisers is the changes to the criteria for outwintering animals. Under the new proposals from 1 January 2025, reduced storage throughout wintering of animals will only be applicable to farmers stocked at less than 100kg/organic N/ha.

Speaking to advisers, many say that this clause could have severe implications where farmers outwinter sheep during the winter months.

In the past, if they were stocked at less than 140kg/N/ha, they could avail of a derogation for reduced storage where animals were outwintered.

This made sense, as the animals were outwintered at a low stocking rate.

In the proposed scenario, these farmers could be made to build sheds for animals that will never be housed and manure pits that will never see any dung.

It is ludicrous to think that these farmers would have to build slurry storage and sheds that may never be used

In a further complication, if a drystock farmer stocked between 100-140kg/ha is deemed to have ineligible slurry or manure storage facilities, they will then become ineligible to apply for a TAMS grant. Without investment in buildings, these farmers will either face reducing their stocking rate to below 100kg/N/ha or face penalties if inspected.

South Leinster IFA vice president Francie Gorman said: “The Department of Agriculture has acknowledged in the past that this cohort of lower stocked farmers are not part of the problem so why target them with this new regulation.

“This highly vulnerable section of farmers will have no choice to reduce stocking rate as given the margins that exist within beef systems as they won’t have the capability to invest in slurry storage.

“It is ludicrous to think that these farmers would have to build slurry storage and sheds that may never be used.

“If these farmers are forced to erect new sheds, they could be in a position that they will need to keep more stock in the future to justify building them.”

Rented land proposal dropped

The proposal to only include land within 30km in stocking rate had come in for strong criticism.

In the border counties, many drystock farmers will rent parcels of land in counties like Meath, Westmeath and Kildare, and will move up cattle during the summer months to graze.

Having been included in the original proposal last September, this proposal was taken out in the latest submission.

Low-emission slurry spreading (LESS)

Compulsory use of low emission slurry spreading (LESS) equipment will be phased in as follows:

  • From 1 January 2023, compulsory usage of LESS for all farmers above 150kg livestock N/ha.
  • From 1 January 2024, compulsory usage of LESS for all farmers above 130 kg livestock N/ha.
  • From 1 January 2025, compulsory usage of LESS for all farmers above 100kg livestock N/ha.
  • LESS will also be mandatory for all pig slurry spread on land from 1 January 2023. From 1 January 2022, all slurry generated on the farm must be spread by 8 October of that year. From 1 January 2023, all slurry generated on a farm must be spread by 1 October of that year.

    Speaking to the Irish Farmers Journal, IFA livestock chairman Brendan Golden said: “The IFA is opposed to the compulsory usage of LESS on farms operating above 100kg livestock N/ha from 2023 and for all pig farmers from 2023 onwards. This requirement has limited potential on small farms where only small volumes of slurry are generated.

    “On extensive farms, the imposition of compulsory LESS equipment usage will be severely cost prohibitive. Research has shown that when slurry is spread with a splash plate in spring, the amount of nitrogen recovered is similar to that from slurry applied by trailing shoe in the summer.

    “Therefore, lower stocked farms should be encouraged to spread slurry in the spring rather than imposing the compulsory use of LESS equipment on these farms.

    “This proposal will add significant costs to extensive livestock farmers, who either own their own equipment for slurry spreading or hire contractors. Setting this level at 100kg N/ha directly impacts suckler, beef and sheep farmers,” Golden said.

    The proposed stocking rate ceiling, where LESS will be compulsory after 2025, is just over one suckler cow/ha, so it’s likely to take in a large proportion of suckler farms and will in effect make many smaller slurry tankers redundant. It wouldn’t make economic sense for these farmers to retrofit LESS equipment to these smaller tankers – it will mean more slurry will be spread by contractors.

    The costs associated with this requirement will also impact farms below this stocking rate level, as it is unlikely that contractors will offer the alternative means of spreading, as it would require additional investment in machinery.