Autumn and Winter 2021/2 Application of Manures and Slurry
There has been a recent announcement that autumn applications of manures are no longer permitted leading to claims that it will be an end to farming as we know it.
Although it appears to be particularly aimed at the potentially more polluting poultry manures and slurry (and biosolids which are not approved under organic rules) it also covers farmyard manure (FYM).
So, what is the position and how will it affect organic farmers?
Under the Farming rules for water and regulation 4(1)(a) Reduction and prevention of Agricultural diffuse Pollution (England) regulations 2018, it is not permitted to apply organic manures (FYM, slurry or biosolids) to land where there is no nutritional requirement for the crop at the time.
Regulations particularly targeting nitrogen
Although FYM and slurry contains phosphorus (P) and potassium (K) and is usually applied as a maintenance dressing for combinable crops in arable rotations, they also contain nitrogen (N), which is the specific target of this regulation.
The farming rules for water rule uses RB209 as its guide and that specifically says that there is no need for autumn nitrogen fertiliser for autumn sown combinable crops other than oilseed rape - therefore applications of FYM are not permitted in the autumn but should be done in the spring where there is a need.
Application to soils with phosphorus and potassium indexes over 3 would also not be permitted because there is no crop need for phosphorus and potassium for the following crop. This does mean that soil analysis is required to determine which fields receive applications, with low index fields being prioritised for treatment.
This regulation is not new but has not been policed in the past, and the regulation is now being interpreted on a stricter basis because water nitrate and phosphate levels are not reducing.
Applications to growing grass have generally been permitted on the basis that there is a need. Care needs to be taken, particularly where slurry is used because the nitrogen is much more likely to be in a readily available form and more likely to be a possible pollutant and there is little requirement for nitrogen in the autumn.
New guidance regarding application of autumn manure
If you want to apply autumn manures a new regulatory position statement (RPS) has been released to give guidance. You must inform the Environment Agency that you are applying based on the RPS, and you must not cause pollution by making such applications. This will be valid until 1 March 2022.
To use this RPS you must be able to show that your planned applications of manures to land do not exceed the crop requirements for the duration of your current planned crop cycle. But it does not allow manures to be applied to bare land which will not be cropped that season.
You can still apply manures if it is not feasible to store on the farm where it is produced or in the field where it will be used, there is no off-site treatment facility (AD plant or Sewerage treatment plant) or off-site storage facility available but this is all subject to certain conditions, which are that under the RPS you must still avoid pollution and application to land is only permitted on land with a low risk of runoff and leaching. This means there must be no application on sandy or shallow soils, fields with a slope of 8 degrees or more, or on capped, compacted or frozen soil. The field must also not have been drained, moled or subsoiled in the last 12 months and not be above field capacity at time of application.
Nitrate Vulnerable Zone (NVZ) rules continue to apply where appropriate, and the land must also be out of designated groundwater protection zone 1 areas (Defra's MAGIC interactive map shows all such land). There must be no application to land 10m from surface water, streams, rivers or ditches or 50meters from springs wells and boreholes.
The application must be a rate that does not allow more than 5kg/ha potential leaching based on PLANET nutrient management. Overall applications must not exceed the needs of the crop.
What options are there for organic farmers?
There is little danger of exceeding crop needs but timing of applications is still important. For many, spring crops are important and so manure applications will have to be delayed until late winter although there is a risk of soil damage and delayed drilling.
What about composts?
Composted products have a lower readily available nitrogen and so can be applied at higher rates based on the PLANET calculations, but a dung heap is not composting. Composted manures need to have been turned as part of a composting process.
What about stubble turnips or other catch crops?
A catch crop can be grown between other crops. If there is an additional soil and crop need to the main crop to cater for a catch crop an appropriate amount of fertiliser which doesn’t exceed need can be applied but a cover crop which is used just to provide ground cover and is ploughed/disced in has no fertiliser requirement-in simple terms it needs to be harvested in some way.
What about grazing?
The rules to not apply to grazing livestock and so does not change anything although care about poaching damage and watercourses still needs to be taken.
What about before a grass reseed?
There is no requirement for N fertiliser for a grass/clover ley at establishment, in fact too much nitrogen will stop the clover fixing any nitrogen and possibly stop clover establishing.
What about on grassland?
Previous interpretations have been that applications when temperatures are above 4 degrees C are Ok because there is a growing crop with a need. This still applies but care should be taken to ensure that there is no risk of pollution, Avoiding watercourses, springs compacted and frozen soils will reduce pollution risk even with solid manures. Slurry spreading is already restricted between 15th October and 31st January on farms in an NVZ.
Slurry and manure storage: next steps
Slurry and manure storage and application are going to be under the spotlight in the next few years and there are grants becoming available as part of the Environmental land management scheme.
For more information visit the National Pig Association’s website for a detailed Q&A
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