At the outset, AgriSearch Vice Chair, Ian McCluggage, stressed that AgriSearch fully recognize the need for the ruminant livestock sector to play its part in reducing nutrient loss to the environment as part of an overall Northern Ireland Strategy. In this context, it has funded a number of historical and ongoing projects to examine options to minimize nutrient losses from the sector.
SCIENTIFIC ASSESSEMENT
In presenting his scientific assessment of the proposed new programme, Dr Sinclair Mayne (Scientific Adviser to AgriSearch) commented that it was essential that proposed new measures are based on robust science, based on peer reviewed scientific papers, rather than subjective assessment. This was the basis for the first Action Programme agreed with the EU Commission in 2007, and subsequent revisions in 2007, 2010, 2014 and 2019.
Dr Mayne noted that DAERA is proposing to carry forward all of the measures in the 2019 NAP Regulations and to add a number of new additional measures ‘based on scientific research.’ However, he noted that a number of the proposed new measures were presented without presenting the appropriate scientific evidence base and gave three examples:
i. Review of Chemical Nitrogen Fertiliser Limits for Grassland.
DAERA are proposing to adopt the AHDB Nutrient Management Guide (RB209) as a basis for chemical fertilizer recommendations, based on ‘completion of trials at AFBI’, but no data are presented by DAERA to support the new proposal. RB209 recommendations were evaluated in previous reviews of the NAP, and rejected on the basis that the recommendations failed to take account of local grass growing conditions and were impractical for application at farm level.
Under the new proposals, maximum N fertilizer limits for high yielding silage swards would be reduced from current levels of 272 to 242 kg N/ha/year for non-derogated farms and to 210 kg N/ha/year for derogated farms. For high producing grass swards under grazing, maximum N fertilizer limits would be reduced from 272 to 180 kg N/ha/year.
The practical implication of these lower limits is that less grass will be grown, resulting either in additional land being needed to maintain cow numbers or, in many cases, extra concentrates being fed or cow numbers being reduced. AgriSearch estimates suggest that this new proposal will increase phosphorus loading by around 230 t P per year, contributing to additional P losses.
AgriSearch also expressed concern that the N Fertiliser limits published in the new proposals do not accurately reflect the published RB209 guidelines.
ii. Proposed changes to NAP Derogation
AgriSearch are pleased to note that DAERA plan to retain the derogation limit of up to 250kg N/ha/year for ‘grassland cattle farms’ but are very concerned regarding two proposed amendments to the terms of the derogation.
Significant effort (including a comprehensive scientific case) was required to secure previous derogations and in the consultation document, DAERA note that ‘the derogation continues to be an important measure to facilitate more efficient use of manure in intensive grassland agriculture in NI.’ DAERA also confirm that ‘evidence from monitoring carried out by AFBI shows that risk of P losses from derogated farms is less than that of non-derogated farms.’
As noted earlier, DAERA are proposing lower chemical fertilizer limits for derogated farms than non-derogated farms, even though the reason for the derogation is to facilitate higher stocking rates (based on manure N outputs up to 250 kg/ha). Furthermore, DAERA are also proposing that ‘it will be necessary for all derogation applications to undergo a Habitats Regulations Screening which will inform the decision to grant, refuse derogation applications or apply further conditions.’
AgriSearch considers that these additional measures will effectively render the derogation of limited value, significantly reducing uptake and thereby negating the positive environmental impacts observed on derogated farms up to the present.
iii. Additional Measures – focused approach for high-risk areas and sensitive sites.
AgriSearch are extremely concerned regarding the proposal to introduce ‘new focused NAP measures for high-risk areas and sensitive sites.’ No details are provided of the measurements to be undertaken or the timescale for assessment. Given that a previous scientific review of 25 river catchment studies across the Republic of Ireland, Europe, USA, New Zealand and Brazil (Melland et al., 2018) concluded that measurements of water quality change in medium-sized catchments need to account for long time lags from 4 to 20 years, it is untenable to threaten ‘curtailing of farming activities if outcomes not achieved’ in 2028, for measures introduced in 2027.
INITIAL IMPACT ANALYSIS
Jason Rankin (Strategy Manager at AgriSearch) presented an initial impact analysis of the NAP Consultation proposals using data from AgriSearch’s Beacon Farm Network. These farms are among the most efficient in Northern Ireland and make excellent use of grazed grass and silage so these figures should be seen as the upper end of what is achievable.
No purchased P fertiliser was included in any of the P Balance calculations. In addition, the new lower P% content of concentrates was also used in these calculations (4.7g/kg dairy concentrate, 4.3g/kg other concentrates).
Figure 1: Correlation between milk yield and farm phosphorus balance
The analysis shows that it is almost impossible for any herd with a milk yield of above 8,000 litres per cow to achieve a P balance of 8kg/ha. Furthermore, this analysis is based on 2023 which was a relatively benign year. The poor weather of 2024 saw most farmers feed an extra ½ t of concentrate per cow to compensate for poor forage quality. This would add an extra 4-5 kg P/ha above the figures shown. None of the herds was severely impacted by TB which would increase the number of replacements needed to be kept as well as the dairy-beef calves and the herds were all calving heifers at 24 months old. The recently completed AgriSearch dairy farmer survey indicates that 55% of the cows in Northern Ireland are in herds with a yield of greater than 8,500 litres per cow. Adverse weather, TB breakdowns and other disease incidence can add considerably to a farmers P balance.
There are emerging technologies being developed looking at solutions to remove P from farms and NI but these will not be ready by 2027/29 and will be dependent on considerable government support.
Jason Rankin highlighted that even farms with a milk yield of under 7,000 litres a cows are not safe. Almost all these farms operate within a Nitrates Derogation (between 170-250 kg (organic)N/ha/year). If these farms operate close to a sensitive habitat then they could be denied a derogation (>90% of NI farmland is within 7km of a protected site).
A simple mistake in the submission of a fertilisation account could see them being denied a derogation in future years. These farms are also likely to be adversely affected by the 180kgN/ha/year chemical fertiliser limit on grazing ground and the effective ban on fertilisers containing phosphorus.
Many of these farms are also in areas identified as candidates for “focus areas” which could impose additional restrictions curtailing their farming operations.
Jason Rankin also outlined two real work examples from within the Beacon Farm Network.
Table 1: Practical examples of the impact of the proposed NAP regulations on two NI dairy farms
As can be seen from the table above both farms would be faced with the choice of either acquiring a huge amount of extra land (which given the current state of the land market is an impossible task) or have to make devastating cuts to their stock numbers. Either of these options would leave the farms financially unviable. While there is the theoretical option to export slurry, the new rules mean that many of those beef and sheep farmers who had previously imported slurry would be extremely reluctant to do so given the increase bureaucracy. Especially if those slurry imports pushed them over the 150 kg N/ha barrier it would see them face the full suite of new rules being proposed in the NAP consultation.
Jason Rankin said that AgriSearch’s initial analysis had also indicated that the P balance targets could also severely impact beef finishing units
CONCLUSION
Norman McMordie (Vice-Chair AgriSearch) concluded the event by saying that AgriSearch would continue its work in scrutinising the science behind the NAP proposals and examining how these proposals would affect its farmer levy payers if implemented in their current form. AgriSearch will be coordinating its activities with key industry stakeholders to ensure a joined up approach to one of the most significant consultations that DAERA has issued in recent years.
A copy of the slides from the event can be seen here: HTTPS://WWW.AGRISEARCH.ORG/PUBLICATIONS/BALMORAL-BREAKFAST-2025-POWERPOINT-SLIDES/VIEWDOCUMENT/740