NPA response to the Defra review of the nitrates and slurry/silage storage regulations
4th Feb 2020 / By Lizzie Wilson
NPA has responded to the Government's review of the nitrates and slurry storage regulations.
In it, I have made it clear that the nitrates regulations are too prescriptive and have historically been guided by ease of administration of compliance, rather than being outcome based.
Closed periods, for example, are far too inflexible and do not consider other influencing factors, such as weather, soil type, soil cover, environmental constraints or the local landscape and risk a failure to achieve the best environmental outcome.
I also suggested that, as the costs associated with compliance are significant and varied, the most effective way to improve compliance is for the Government to provide farmers with greater financial support, with the priority being slurry storage.
Grants for slurry storage are consistently absent from any financial support offered by government, but are most desperately needed and would significantly improve compliance and reduce nitrate pollution.
Furthermore, as guidance specific to the nitrates regulations is now difficult to find and understand since the transition from separate websites to the centralised gov.uk site, farmers are struggling to follow the rules and requirements.
Previously, farmers were issued with a complete booklet to help them, which is now dispersed across different web pages.
And finally, we have made our feelings clear in response to this question in the consultation: ‘Is the existing form of Government Regulation the correct approach? If so, what alternative model would you suggest?’
We have proposed a more outcome focused environmental policy, which allows the use of central data to better target areas of risk/specific issues and would permit farmers to manage their land and animals accordingly whilst trying to deliver a set objective within the appropriate parameters.
Also, as animal management practices and building/yard design has changed dramatically over the years, with many farms now collecting, separating and treating water, water from farms will show different degrees of contamination from minimal to potentially highly polluting. So it is crucial that the risk is assessed and managed effectively.
Therefore, pig units are potentially collecting a lot of water unnecessarily, and this winter has really highlighted a distinct lack of resilience with regard to slurry storage.
NPA has suggested that a review of what constitutes a dirty yard and therefore dirty water and dilute slurry would be beneficial.
Where best practice is adopted, are there opportunities to use biological treatment such as swales for lightly or intermittently contaminated run-off to reduce the overall volume which has to be stored and spread, similar to EPR? This could also include FYM, silage clamps and open yards.