The term 'consultation' really is a bit of a misnomer in the context of the proposed Nitrates Action Programme issued jointly by the Department of Agriculture and Rural Development and the Department of the Envionment on Monday.
The plain fact is that the proposals contained within the document represent the very minimum which the European Commission is likely to accept with regard to the bedding down of an acceptable water protection policy in Northern Ireland.
In reality, the programme, once implemented, will give legislative teeth to the plethora of proposed environmental protection measures that have been in the public domain for months:
* Chemical fertilisers cannot be applied from September 1 through to February 15 and only then made available at rates that specifically match crop requirements.
* Organic manures cannot be spread from October 1 through to January 31, with a limited quantity allowable during February.
* Farmyard manure can be spread throughout the year as long as soil and weather conditions are suitable.
* Dirty water can be applied to land throughout the year, provided it is not polluting waterways or groundwater.
* The total livestock manure storage capacity on farms must be at 26 weeks for pigs/poultry and 22 weeks for all other farms.
* The total organic Nitrogen limit on farms will be 170 kilos of N per hectare, unless a specific derogation is achieved. No more than 250 kilos of organic N per hectare can be applied to any individual field in a 12-month period.
* With regard to Phosphorous - the chemical causing most of the eutrophication problems in our rivers and lakes - farmers will be expected to maintain an application:utilisation surplus, working out at no more six kilos of P per ha per year by 2012.
* Farmers will be expected to keep accurate records of all crop nutrient applications including timings and loading levels.
At Monday's Press briefing, held to launch the action programme, a number of additional points became obvious.
Key among these is DARD's intention to profile the Nitrates Directive as an aid to good farming practice and not merely a tool which can be used to siphon off Single Farm Payment Monies from those producers deemed to be breaking the rules.
Also now clear is the formal link between the Nitrates Directive and cross-compliance. And this principle will hold both in terms of farmers' adherence to the Nitrates code of practice and the inspection procedures put in place.
DoE will be charged with the responsibility of policing the Nitrates Directive in Northern Ireland. Representatives from that Department have made it clear to Farming Life that farm inspections will, initially, be targeted at those areas where water quality problems are known to exist.
Significantly, DARD is not prescribing application rates for Phosphate. Rather it is working with the feed and fertiliser sectors to come up with reduced loadings for the mineral in their products. In fact, where fertiliser is concerned, the way forward will be through compounds containing zero phosphorous. Given that local soils are already P rich, it is now inevitable that local farmers will have to secure official clearance to spread phosphate fertiliser at some date down the line.
Inextricably linked to the Nitrates Directive is the Farm Nutrient Management Scheme (FNMS). DARD has confirmed to Farming Life that well over 2,000 farmers had signalled their intention to avail of the grant aid available by the middle of February. The closing date to provisionally register for the capital grant scheme is Tuesday, March 1.
In line with DARD's policy to promote the Nitrates measures in the context of good farming practice, representatives are pointing out that producers should view FNMS as an opportunity to put in place more than the bare minimum storage requirement cited by the Nitrates Action Plan. If this approach is taken, it should allow all eventualities to be covered when it comes to making best use of slurry as a plant resource.
On the issue of planning permission for larger slurry tanks, both DoE and DARD have again given a commitment that everything possible will be done to speed up the application process. However, it is now clear that FNMS grant aid will not cover the initial fee (up to £1,000) paid to Planning Service by applicants.
