Of all the new measures proposed in Ireland’s Nitrates Action Programme review, the banding of organic nitrogen per cow based on milk yield has proven to be the most contentious.

Early this week saw a flurry of submissions from farm organisations, research institutes, discussion groups and individual farmers before the consultation period closed.

This is the first time that banding of organic nitrogen has been proposed in Ireland.

The Department of Agriculture says it was requested to look at this by the European Commission as most other member states apply different rates of organic nitrogen based on milk yield. Teagasc was asked by the Department to carry out research into bands and came back with the following proposal:

  • Band one: cows producing less than 4,500kg milk annually will be assigned an organic nitrogen rate of 80kgN/ha/year.
  • Band two: cows producing between 4,500kg and 6,500kg milk annually will be assigned an organic nitrogen rate of 92kgN/ha/year.
  • Band three: cows producing over 6,500kg milk annually will be assigned an organic nitrogen rate of 106kgN/ha/year.
  • There is 1.03kg of milk in every litre of milk, so herds milking more than 4,370 litres and less than 6,310 litres annually will be banded in the 92kg category, while those milking more than 6,310 litres annually will be under the higher category of 106kgN/ha.

    Those producing less than 4,500kg of milk annually will have a lower N excretion rate than is currently the case

    At present, all cows are classed as excreting 89kgN/ha/year so under these proposals, all herds producing more than 4,500kg of milk annually will have a higher N excretion rate than currently. Those producing less than 4,500kg of milk annually will have a lower N excretion rate than is currently the case.

    What this means in practice is that if this measure is introduced, maximum permissible stocking rates will vary depending on how much milk the herd produces.

    The maximum stocking rate allowed is 170kgN/ha or 250kgN/ha where there is a derogation in place.

    Farmers will still be permitted to export slurry in order to remain under these thresholds

    Those with higher-yielding herds are going to hit the stocking rate limit much quicker than those with lower yielding herds.

    Farmers will still be permitted to export slurry in order to remain under these thresholds, but finding farmers able to import slurry is getting more and more difficult.

    According to Teagasc, 24% of dairy farmers have herds producing less than 4,500kg milk annually. This represents 13% of the national milk pool and these herds are fed 770kg meal per cow per year.

    Those in the third band, above 6,500kg of milk annually, amount to 11% of dairy farmers and 17% of the national milk pool

    The majority of dairy farmers, 65%, are in band two, producing between 4,500kg and 6,500kg of milk from 945kg of meal per cow annually. Seventy per cent of Ireland’s milk is produced on these farms.

    Those in the third band, above 6,500kg of milk annually, amount to 11% of dairy farmers and 17% of the national milk pool. These farmers feed an average of 1,432kg of meal per cow annually, almost twice what the farmers in the first band feed. Meal feeding levels were derived from National Farm Survey data.

    Science

    The reason behind the introduction of banding is that high-yielding cows excrete more nitrogen because they eat more feed – grass, silage and meal.

    Up to now, a purebred Jersey cow being milked once per day was considered to excrete the same amount of organic nitrogen, and therefore be at the same stocking rate, as a Holstein Friesian cow perhaps twice her size and producing three times as much milk. The introduction of bands will be a crude, but fairer way of setting stocking rate limits based on nitrogen inputs and outputs.

    The Teagasc research into nitrogen banding also looked at greenhouse gas (GHG) emissions and this found that high-yielding cows emitted more GHG than lower-yielding cows.

    There was a 2% difference between the medium- and high-yielding cows in terms of emissions per litre

    Total GHG emissions for the low-yielding band is found to be 4.64t CO2e/cow/year, 5.46t CO2e/cow/year for the mid-yielding cows and 6.82t CO2e/cow/year for the high-yielding cows.

    However, when looked at in terms of emissions intensity, the high-yielding cows produced 20% less GHG per litre of milk than the low-yielding cows.

    There was a 2% difference between the medium- and high-yielding cows in terms of emissions per litre.

    The difference in feed conversion efficiency between the bands was not looked at by Teagasc.

    Submission

    High-yielding and highly stocked herds are the ones most affected by this measure. If producing more than 6,500kg/cow, the maximum stocking rate with a derogation will be 2.36 cows/ha, down from 2.8 cows/ha.

    According to Teagasc and ICBF data, these higher-yielding herds are stocked higher and feed more meal and spread more nitrogen per hectare than herds in the lower-yielding bands. This would explain why they excrete more nitrogen.

    On average, these farms are still relatively lowly stocked as additional land is required for grazing and winter feed, because intakes are higher. In such instances, the new proposal will have little or no impact.

    There is some suggestion that farmers in the middle category will now be encouraged to move into the lower band, which enables them to carry more cows. While this may be true for those on the fringes of bands, the majority of farmers will remain within their band.

    Submissions: key points from submissions made on organic nitrogen bands

    IFA

    The IFA is seeking a postponement of the plans to introduce banding to allow more time for consultation. It says farms with high-yielding cows will be forced to lease or purchase additional land to retain current stocking rates, which could affect livestock and tillage farmers competing for land. It wants to know the number of farmers pushed above 250kg N/ha by the proposal.

    ICMSA

    ICMSA says the proposal to introduce banding in just three months’ time is unrealistic and will lead to a significant reduction in income for farmers with high-yielding cows. It is calling for the 89kg limit to be retained until research on banding is completed.

    IHFA

    The Irish Holstein Friesian Association (IHFA) says that two-thirds of its 3,400 members have herds producing in excess of 6,500kg of milk annually and the remaining one-third is in the 4,500kg to 6,500kg category.

    The IHFA is scathing of the proposal, citing a 40% improvement in feed conversion efficiency between the low- and high-yielding bands.

    It says that the proposal will encourage farmers to breed lower-yielding cows to capitalise on the lower organic nitrogen rate.

    Its submission says that in a stable national herd, 8.5bn kg of milk could be produced with 1.2m high-yielding cows, instead of the 1.5m cows there are currently.

    This would reduce greenhouse gas emissions by 25%, it says.

    The IHFA says the lower band needs to be scrapped and no farmer should be “gifted organic output which is lower than what is already accepted as industry standard which is 85kgN/cow. This apparent bonus in N excretion per cow to a cohort of farmers is an inequitable approach”.

    It goes on to say that “calf quality produced from this cohort of herds is largely not transferable to a beef system”.

    Devenish/UCD

    In a document on the proposals, Devenish and UCD say the proposals will penalise the more efficient, higher-yielding cows and decrease the overall efficiency of the national dairy herd. They say that the use of innovative technologies such as bypass proteins, amino acids and biological treatment of slurry has not been explored.

    Teagasc

    Teagasc is the author of the report from which the bands have been derived.

    In its submission to the consultation, Teagasc says: “There can be significant year-to-year variation in milk yields. Therefore, a three-year rolling average should be used to calculate a farm’s milk deliveries per cow. Banding will result in significant change for a number of farmers as stocking decisions are made at least a year in advance. A lead-in period for stocking rate changes may be necessary.”

    Comment

    It has been interesting to watch the reaction of the various sections of Irish agriculture to the proposal on banding. A lot of businesses that rely on farmers in the high-yielding band to buy their products or services are worried about the long-term impact of the proposals on their own business. Some of these businesses even sent out templates to their customers on how to make a submission to the consultation process.

    In my view, these proposals are much fairer than the old, one-size-fits-all approach.

    Over the last decade, average organic N excretion rates increased by 0.6kgN/cow/year. If banding is not introduced, every cow, regardless of yield, would see her organic N level increase by 6kg over the next 10 years because the average cow is increasing in yield.

    Banding gives more transparency to decisions around breeding and feeding and what impact they have on the overall farm system.

    However, I do think that just three bands is not fair and that additional bands should be included such as:

  • Band one: less than 4,000kg/cow.
  • Band two: 4,000kg to 6,000kg/cow.
  • Band three: 6,000kg to 8,000kg/cow.
  • Band four: 8,000kg to 10,000kg/cow.
  • Band five: greater than 10,000kg/cow.
  • The addition of extra bands will be fairer for all farmers, but particularly for those who are producing slightly more than 6,500kg/cow but less than, say, 8,000kg/cow.