With rules ranging from when you can spread slurry to how you should stack silage bales, all farmers will be impacted by the DAERA Nutrients Action Programme (NAP) proposals currently out for public consultation.

That includes those who might think if they sell their farm support entitlements, they will be free to operate as they like.

“The NAP regulations apply to all agricultural businesses, irrespective of whether they are in receipt of support payments or not,” states the DAERA consultation.

From January 2027, DAERA plans to strengthen its enforcement capability.

There will be an increase in the number of “on the spot inspections in focused areas” and fixed and variable monetary penalties introduced for minor and moderate offences related to the NAP.

The extra cost associated with inspections and compliance with rules, is estimated at an additional £2.85m per year.

High-risk

There is also reference made in the consultation to a “focused approach for high-risk areas and sensitive sites,” with work being done on a pilot programme in 2025 and 2026.

The principle being worked on is that if the standard measures set out in the NAP are not achieving desired improvements in water quality in these high-risk areas, then additional measures could be introduced. These could include reduced stocking rates on farms in the catchment and longer closed periods for slurry spreading.

Main focus is on phosphorus in agriculture

Running through the Department’s NAP consultation is an underlying assumption that there is more than enough phosphorus (P) in slurry and manures to meet NI crop needs.

This surplus P comes from two sources – chemical fertiliser and bought-in animal feed.

At present, P fertiliser can only be spread when there is a crop need identified by a soil analysis.

The latest proposals would tighten those rules, with P fertiliser restricted in a grassland situation to when a farmer is reseeding, establishing clover or where a deficit cannot be met by importing organic manures. An exemption and supporting evidence will have to be registered with the NI Environment Agency (NIEA).

Where a farm is low in P, the Department would argue this should be addressed by importing slurry from an intensive farm. At present, these exports have to be notified to NIEA annually, however, the Department intend upgrading the system.

Once done, it will require both the exporter and importer to notify the Department – in the case of the importing farm, they will have to verify receipt of the slurry within 4 days of the movement taking place.

At present, this importing farm could take in slurry up to the manure nitrogen (N) limit of 170kg N/ha/year. In a scenario where the farm has a manure N loading below 150kg, but imports push the farm above this threshold, then the farm will be subject to the same P balance limits expected of intensive farms. Ultimately, that will curtail the amount of slurry that can be imported in many situations.

Database

As the new recording system for slurry, DAERA intends to introduce a fertiliser database as the new recording system for sales and usage by 2027. It is also proposed to include livestock feed sales as part of the database. According to the DAERA consultation, this database “will provide an overall picture of nutrient loading at a farm level.”

Ammonia filters through into NAP

There are two measures proposed in a DAERA strategy to tackle ammonia emissions from agriculture, which the Department intends implementing via the NAP.

The first is the proposal to ban the use of splash plate spreading of slurry across all farms by 2030.

The second is a proposed ban on the use of straight urea fertiliser from 1 January 2026. From that date on, protected urea would have to be used.

Heavy rain warning system proposed

Included within the NAP consultation is a proposal to put in place a system to provide a warning to farmers when heavy rain is forecast and conditions will be unsuitable for spreading slurry.

The alert could come by text message or email and include the start time and duration of the temporary closed period. Failure to comply would be seen as a breach of the regulations.

Currently, all new or substantially altered slurry or silage stores are required to be notified to the Department 28 days prior to use.

Under the latest NAP proposals, DAERA intends on changing this so that notification of the location and design of the facility is made 28 days prior to construction beginning.

It will mean that the Department can consider the location and design of the facility and in doing so, enable any modifications to be made prior to construction commencing,” states the consultation.

In addition, DAERA will seek verification that construction has been completed to required standards.

In recent years, the maximum volume of slurry which can be spread in one application during February and October, was reduced from 50m3/ha (4500 gallons/acre) to 30m3/ha (2750gallons/acre).

The latest NAP now proposes lowering this further to 25m3 (2,250 gallons/acre).

Buffer strips

Other measures to prevent nutrients getting into water include a proposal for a 3m wide uncultivated buffer to be left alongside a waterway in arable fields.

When it comes to stacked silage bales in a field, the NAP proposes increasing the distance from a waterway to 20m (currently 10m) and requiring that the bales are stacked a maximum of two high.

If stored in a location where effluent can be collected, the rule around stacking does not apply.

?In their consultation document DAERA has confirmed it intends retaining the derogation that allows a grassland farm to operate at a manure nitrogen (N) limit of 250kg N/ha/year, rather than the typical 170kg requirement.

Any farmer in derogation must apply each year and submit various information to the NIEA, including a fertilisation plan. They must also work to a P balance limit of 10kg P/ha/year. In recent years, just over 400 farmers per year have operated under the derogation.

Going forward, the Department intends tightening some rules, while derogated farms will have to reduce their P balance to 8kg P/ha/year in 2029, in line with other intensive farms.

As well as controls around phosphorus, the NAP consultation also suggests intensive farms (manure N over 150kg/ha) should undertake a mandatory liming programme, aimed at improving soil health and reducing the need for nutrients.

These farms will also need to have a valid soil analysis for all the land being farmed, states the DAERA document.