Awareness of the Farming Rules for Water (FRFW), which were introduced in April 2018, and more importantly the Environment Agency’s interpretation of the rule ‘1a’, is becoming a ‘hot topic’ when it comes to planning manure applications.
CXCS recently attended an inspection where the EA Officer asked for a Nutrient Management Plan for the following year’s harvest, where every application of manure and fertiliser had been individually matched to the field’s soil testing results. It is vital FRFW is understood on a farm level to remain compliant, especially with FRFW focused inspections becoming more and more recurrent.
Soil testing forms part of FRFW and tests must show Phosphorus (P), Potassium (K), Magnesium (Mg) and pH. Rule ‘1b’ requires soils to be tested at least every 5 years on cultivated land. DEFRA’s definition of cultivated land, is land that you’ve ploughed, sowed, or harvested at least once in the last year, and or land that has received fertiliser at least once within the previous 3 years. As these rules have been in place since 2018, having no soil test results is simply not an option; how can you justify manure and compound fertiliser applications without knowing what is already available in your soils.
You must match every element to the proposed application to see if it is justifiable, for example, if you have soil test results showing ‘4P 2-K 2Mg’ on an arable or grassland field, an application of any manure containing phosphate would not be justified, as at a P index of 4, there is no recommendation in RB209, even though there is scope to apply manure to maintain the indices of the other elements.
Another component of FRFW is that applications of fertilisers and manures must only be applied when there is crop or soil need. Autumn applications of Nitrogen to Winter cereals have no recommendation in RB209 and therefore would not be justified, unless a FACTS qualified advisor can give a written reasoning for the additional N.
In Autumn 2021 there was an ‘exemption’ to apply manures to crops with no listed Autumn N requirement if other tight conditions were followed and the EA notified. This exemption, ‘Regulatory Position Statement 252’ is to be withdrawn on 1st March 2022 unless the decision is made to extend it.
