It is now nearly two weeks since DAERA published proposals for a new Nutrients Action Programme (NAP) in NI, and in that intervening period it has become clear just how draconian many of the suggested actions actually are.

In one regard it is possible to understand a situation evolving, where the Department might initially take a tough line before compromising on some issues after a public consultation process. Except what has actually been proposed runs the risk of alienating a lot of farmers, as it goes well beyond what could be seen as reasonable or achievable in practice.

Perhaps the most obvious example are the DAERA proposals to introduce a P balance of 10kg/ha/year on intensive farms by 2027. It is hard to argue with the principle, but that 10kg limit is a case of going too far and too fast.

To achieve a P balance of around 10kg or below, a lot of hope is being put on our ability to separate slurry, take the solids to anaerobic digestion and process the resultant digestate to mine out the P. Good progress has been made, but we are a long way from a situation where we will be selling 5,000t of a high P fertiliser outside of NI. A longer lead-in time around the whole issue of P balance is needed.

But this is not just about intensive farmers. Take the example of a beef and sheep farmer, reasonably stocked at 100kg of manure nitrogen (N) per hectare and doing a good job by grazing for over seven months of the year.

To minimise risk of disease, the farm doesn’t import any slurry. And with stock outside most of the year, there is only enough of the farm’s own slurry to cover silage ground. Compound fertiliser is used to maintain soil fertility on grazing land.

Under the latest NAP proposals, this farm will not be allowed to use any P fertiliser and will have significant restrictions put on the amount of straight N that can be spread. The farmer will either have to import slurry (and spread it) or start feeding more concentrate to make up for a gap in forage supplies.