The Environment Agency are cracking down on the enforcement of the Farming Rules for Water Regulations in England. In a nutshell this means that manure which has traditionally been incorporated under the winter wheat during the autumn cannot be spread (unless agronomically justified). This applies to both grassland and cereal crops but does not include linseed or winter oilseed rape.
This is going to change the way we farm and put increasing pressure on farmers in England. So, what exactly are they meant to do with their manures? This will be the biggest area of concern for many large livestock farms, with probably the only realistic options being to increase storage, export manures, or simply downsize!
The following key points cover some of the background regulation and thought processes behind the rules, which came into force in April 2018.
Key points
- The Farming Rules for Water (FrFW) rule 1/ Regulation 4 is not an outright ban on the use of organic manures or spreading in Autumn and doesn’t impose a closed period, however it does require that organic manures/fertilisers are applied only when there is an agronomical need and that this can be agronomically justified so that it does not exceed the crop and soil’s needs.
- Most Autumn soils will have enough residue Nitrogen in the ground to get established, and therefore do not need additional fertiliser until the main time for nutrient uptake – in Spring.
- Some crops such as oilseed rape and linseed do have an Autumn seedbed requirement for nitrogen in the Autumn, of around 30kg/ha (See RB209).
- The reasoning behind the new regulations are founded in the Code of Good Agricultural Practice (CoGAP) and follow recommendation tools such as RB209, which is science based, to get the most economic and environmentally efficient use of nutrients. RB209 is now hosted by AHDB and is independent of the Environment Agency.
- The EA refer to the regulations as the Agricultural Diffuse Pollution Regulations to signify that these are no optional rules, but part of UK law.
- The basis for using organic manures/fertilisers in the Spring has been in the CoGAP guidelines since around 1987 and reflected the move from Spring to Autumn cropping to reduce wastage of nutrients and impacts on the environment over winter.
- Applications can be made if there is an agronomical justification which is in line with RB209 or similar recommendation systems. However, it is unlikely that an agronomic justification can be made for applications of slurries, FYM, and other organic wastes to stubbles in Autumn because there is no growing crop, no rapid uptake of nutrients, and it is the wettest part of the year meaning a high risk of runoff or leaching, thus nutrients will not be used efficiently. Also, RB209 does not support applications at this time of year.
- Farmers in NVZ areas must comply with both regulations so manures may still not be able to be spread (without an agronomic justification) even outside of the closed period.
- The FRfW cover all organic manures and fertilisers including digestates, composts, FYM, slurry, sewage sludges and wastes and non-wastes including food wastes and make no distinction like the Nitrate Regulations do about high or low Readily Available Nitrogen manures.
- These regulations are likely to drive the need for farms to minimise slurry production, ensure good clean and dirty water management and increase storage capacity to ensure that organic manures are only spread when there is an agronomic justification (mostly in Spring). The regulations do not specify an exact storage capacity figure which may be similar or higher than in the Nitrate regulations or Silage Slurry and Agricultural Fuel Oil (SSAFO) regulations requirements. We, however, suggest 6 months of storage may be the most realistic in most cases.
- Currently the regulations are not connected to Cross Compliance, although the EA reserves the right to use other enforcement options if necessary.
