David Rankin, PRO, Agricultural Consultants Association (ACA (NI)), reports that NIEA have completed Phase 1 of the Nitrates Action Programme (NAP) inspections for 2024 and are about to continue with a further number of inspections throughout Northern Ireland.
However, David feels that as the DAERA Minister Andrew Muir has highlighted that he wants to see an improvement in water quality, especially in those waterways running into Lough Neagh, he suggests that there will be an increase in the number of inspections close to the waterways that run into the lough.
It should be remembered that NIEA is an enforcement branch of DAERA and not an advisory service which is administered by CAFRE, so if NIEA find a problem – either regulatory or pollution, they will breach you. This means that as well as being financially penalised in your Basic Payments, you will have to pay to get the problem resolved.
So, what do you need to be ready for a NAP cross-compliance inspection?
In this article David looks at what is involved in a NAP NIEA Cross-compliance inspection and how a few simple management changes can help.
Firstly, there is help out there and members of ACA (NI) who are experienced in preparing farmers for inspections – go to www.acani.org to find an agent close to your farm business. Check that they are able to prepare you for an NIEA inspection.
Secondly, what paperwork do you need?
There are 3 basic records that NIEA will check for an individual year they select. Presently this can be for any year between 2019 and 2023:
Nitrogen Loading
For business not operating under derogation, the amount of total Nitrogen (N) in livestock manures applied to the area claimed for BPS (can use the MEA instead of the BPS claim) must not exceed 170 kg N per hectare per year. Derogated farmers can go to 250 kg N/ha/year but they have other requirements to adhere to.
To calculate the N produced by livestock, DAERA have produced standard figures for the N excretion rates for livestock – please refer to the NAP Guidance booklets or the DAERA Online calculators.
The N produced by livestock is counted every 2 months from 1 February to 1 December each year (6 in total). Use the Nitrate Stock Count on NIFAIS to calculate the numbers of cattle for each count. Sheep and pigs will have to come from your own records, as will poultry.
David suggests that if you are selling stock, always sell before the stock count, e.g before 1 February or 1 April etc. However, if buying, then buy after the count date. This means less stock will be counted on that specific date. This could be of help if you are running close to the N Loading limit.
Add up the Nitrogen produced by all the livestock and then add in or take off imports/exports of slurry and FYM. Divide this by the number of hectares on your SAF and this will be the N Loading per hectare per year.
If you now find that you could be above the 170 kg N Limit, the only option is to export slurry (the closed period starts at midnight on the 15 October). All farm businesses which export slurry, FYM, anaerobic digestate, pig or poultry manure must submit a Manure Export Submission to NIEA using the DARA Online system before the 31 January 2025 for the calendar year 2024.
Pig and poultry units will also have to adhere to the IPPC Directive, but they still need to complete a Manure Export Submission if slurry is being exported off their farm.
Fertiliser Applications for grassland and crops
There are limits to the amount of Nitrogen that can be applied to grassland – for dairy farms it is 272 kgs N per hectare per year but for all other livestock farms it is 222 kgs per hectare per year.
Remember this is over the whole grassland area and is completely different from the N calculation above.
For arable, forage and horticultural crops the amount of N applied per hectare must be in accordance with the crop N requirements. This is more complicated than for grassland as the N requirement is influenced by the previous crop and soil type. The AHDB Nutrient Management Guide (RB209) gives the recommended crop N recommendation. This is only a guide but knowing your soil type and crop history will help to determine your applications.
Phosphate applications both to grassland and arable fields is now more critical in determining water quality. Therefore, if you are applying a compound fertiliser with P, poultry manure or anaerobic digestate after the 1 January 2020, you will need soil analysis and a fertilisation plan.
The introduction of the Soil Nutrient Health Scheme (SNHS) and soil analysis which gives the P index for each field has greatly helped in knowing if a field needs P fertiliser or not. If you don’t need it why put it on!
If P from fertiliser, poultry manure or anaerobic digestate has been applied, NIEA will ask to see the soil analysis and fertilisation plan. Where no P is applied, they should not be asking for soil analysis, although it is always useful to show them that the fields do not require P.
The start of the closed period for spreading fertiliser (chemical N and phosphate fertiliser) to grassland is at midnight on the 15 September.
22-week storage for slurry.
This is the last calculation NIEA will check, and you must provide adequate storage over the ‘closed’ period. Farms with pig and/or poultry enterprises must have a minimum of 26 weeks storage, whereas for all other livestock enterprises it is 22 weeks.
To calculate the storage requirements, measure all your tanks and above ground stores. For tanks constructed after 1 December 2003, you will need to have provided NIEA with a chartered engineer’s certificate if not already sent. Don’t forget to deduct freeboard (usually 300mm (1 foot)) from all these ‘new’ tanks.
Rain falling on yards, silos etc and running to a tank must also be measured. Remember when walking around your yard, look up and look down to see where rainfall is running. NIEA are very observant in checking spouting and down spouts, so ensure the rain running off roofs is directed away from tanks.
Parlour washings and the water required to clean out pig and poultry houses must be added to the calculation.
Other factors to consider.
During the inspection NIEA, will check yards, silos, slurry storage facilities as well as waterways for evidence of pollution.
Old silos can be a problem, especially earth banked silos. As I said earlier, look down – what is the floor like? Is it badly worn or cracked? If so, it needs repaired to avoid effluent entering the ‘underground strata’ – a term NIEA regularly uses when inspecting yards and silos or running down the field into a waterway. Keep the effluent channels cleaned out. Are they wide and deep enough to direct the effluent to a tank, or is it running down the yard?
Heavy polythene sheets and bitumen products can help in the short term to solve a problem, but additional work will be needed before silage is put in next year.
Don’t overfill your silos and ensure the polythene cover extends beyond the effluent channel, so rainfall is not allowed to flow into and fill up your tanks.
NIEA will be inspecting fields, to check for field heaps of FYM, and also to see if slurry or even fertiliser is spread too close to a waterway – keep back at least 10m from waterways.
In addition, there are additional requirements for the storage and spreading of farmyard manure, poultry manure or anaerobic digestate close to lakes, boreholes etc.
With the introduction of LESSE for cattle farms with over 200 or more livestock units (or on pig farms with a total annual livestock manure Nitrogen production of 20,000 kgs) there are also additional requirements to consider. LESSE appears to reduce ammonia emissions in the air as well as odours, but it may not prevent run off from sloping fields. Rather than going up and down the slope why not go across.
Are you ready?
