Analysis by dairy experts within DAERA suggests that most intensive farms will be able to meet new rules being implemented under a new Nutrients Action Programme (NAP) without having to take drastic action such as cutting livestock numbers, MLAs have been told.

At last Thursday’s meeting of the Stormont Agriculture committee, Brian Ervine from DAERA said officials had looked at the potential impact of five different actions on driving down phosphorus (P) surplus on farms.

Under current NAP proposals, intensive farms will have to adhere to a limit of 10kg P/ha/year in 2027, falling to 8kg P/ha/year by 2029. At present the NI average across all farms is over 11kg, with many intensive farms well beyond that. The first action is for these intensive farms to stop using chemical P fertiliser. Under the proposals, the use of P fertiliser will effectively be banned across all farms, in most situations.

Feed efficiency

The second action is for intensive dairy farms to look to increase feed efficiency by getting more milk from forage, thereby feeding less concentrate per litre of milk produced.

Action three is for these dairy farmers to get their slurry separated, with the solids fraction taken off the farm. The principles behind that are currently being investigated as part of a DAERA-led Sustainable Use of Livestock Slurry (SULS) project, where the slurry solids are used as a feedstock in anaerobic digestion. The plan is to harvest off the P in the resultant digestate, process it and sell it outside of NI.

Some initial analysis from the SULS project suggests around one quarter of the P in fresh slurry is recovered in the solids post separation, so it will help lower P balances on farms.

Exports

According to Ervine, for most of the dairy farms caught in new rules around P balance, fully implementing these three actions should allow them to meet the new P limits.

However, for the “highest input systems”, he said they will have to find an extensively run farm to which they can export slurry.

“Processing the slurry in the SULS model just wouldn’t be enough because they have such a nutrient surplus to deal with in the first place. Those very intensive systems have more nutrients than their land can take. They are farming beyond their land base so they’re intensive like pig and poultry farms,” said Ervine. If these farms are unable to find a new home for their slurry, that leaves a final option which is to reduce stocking rate.

“That is a last resort, because you would exhaust all the other ones first,” said Ervine.

Main source of P is animal feed

In 2023, there was a surplus of approximately 7,100t of phosphorus (P) within NI farming, Brian Ervine from DAERA explained to MLAs last Thursday. Most of the total P input is in animal feed, with nearly 13,000t going out onto NI farms in 2023. In addition, there was around 2,500t of P within chemical fertiliser. Set against that is the output of P in the likes of milk and meat from NI farms, which is estimated at 8,300t.

“If you’re bringing surplus P into the system every year you get a build-up of P in soil. The livestock eat the feed, absorb a small proportion of the P and the rest goes into the manure - the manure goes onto land and the land absorbs the P,” said Ervine.

He maintained that around 40% of agricultural land in NI is now above the optimum P level required for crop growth. The consequence of high soil P is that it gradually dissolves out with rainfall, ending up in sheughs, rivers and lakes.

“In the 10 year period from 2012 to 2022, there’s been a 55% increase in soluble reactive P levels in rivers.

“We have very clear data and evidence. There is a lot of science around this,” he said.

More sustainable

To get to a “more sustainable” position, he said it will be necessary to take up to 4,000t of P out of the system. Initially around 2,000t can be removed by restricting the use of chemical P on grassland, leaving 1,500 to 2,000t to be removed by either reducing feed or by slurry separation and processing as in the DAERA Sustainable Use of Livestock Slurry (SULS) project.

However, achieving that reduction in P on the back of slurry separation will be a challenge, acknowledged Ervine.

In practice it will probably require 2,500 to 3,000 cattle farms, as well as larger pig farms, to be separating their slurry, with the solids fraction going for anaerobic digestion and the resultant digestate processed to take out most of the P.

“We already have some manure processing - Stream Bio Energy for the poultry sector, with nutrient removal outside Ballymena at Tully quarry. That’s proved successful, but that’s a big plant, that takes about 350t out of the system, so it gives an idea of how much is needed,” said Ervine.

LESSE will be ‘challenging’ for small livestock farms

The revised Nutrients Action Programme (NAP) currently out for consultation, includes a number of references to the need for more inspections, especially in targeted areas, as well as proposals to introduce a new system of penalties for those in breach of the rules.

Despite the threat of more enforcement action, “it is the last place we want to go” insisted Brian Ervine.

“We want farmers to be following this because it’s actually efficient and good agricultural practice and by using nutrients efficiently, then there’s less loss to the environment.

We want people to be doing it because it’s the right thing to do,” he said

Devastating

However, a number of MLAs raised concerns about how the NAP proposals will negatively affect both farmers and processors, with the harshest criticism coming from former DUP Agriculture Minister, Michelle McIlveen.

“I would question whether or not this [consultation] was drafted by the minister’s officials or by his buddies in Friends of the Earth because the impact across the sectors will be quite devastating,” she said.

While the NAP rules all generally relate to water quality, included within the proposals are two measures designed to help lower ammonia emissions.

The first is a proposed ban on the use of straight urea from 1 January 2026, with the second being a requirement for all farms to use low emission slurry spreading equipment (LESSE) from 2030 onwards.

At last Thursday’s committee meeting, Fiona Dickson from DAERA said she recognised LESSE will be challenging to implement for smaller farms.

“We have heard that issue raised and if that is something to be fed back through the consultation process, please encourage anybody who is concerned about that, to do that,” she said. She also confirmed that DAERA is working on a new sustainable farming investment scheme to replace the grant aid available under the farm business improvement scheme.

Technology

The current proposal is that the new scheme will initially focus on providing financial support for technology and equipment to help deal with ammonia emissions, carbon emissions and nutrient loss. “You could read into that that’s LESSE,” said Dickson.

But even if a 40% grant is available, DAERA officials accepted it would be difficult for a small farm to economically justify an investment in LESSE.

CAFRE to offer training in NAP

Once an updated NAP is put into legislation, CAFRE will undertake a series of awareness events to talk farmers through how they can be compliant with the new rules, confirmed Mark Scott.

He said the updated NAP regulations will also be covered in new Business Sustainability Groups, while water quality will be a specific topic for new themed groups, with two pilot groups proposed for the current financial year. In addition to training farmers, earlier this year CAFRE launched a new ‘Supporting agri-professionals’ programme targeted at advisers, consultants etc. who work directly with farm businesses.

“We’ll train those people. They’ll then carry the messages of the department and of CAFRE up those farm lanes and help those farmers to better comply with these [NAP] proposals as and when they come into regulation,” said Scott.

Consultation open to 26 June

The public consultation on the proposed changes to the NAP is open to responses until midnight on 26 June 2025, so rather than a normal 12-week consultation, it is running for eight weeks.

“By closing the consultation at the end of June that will give us the summer months to be able to consider the responses and look at any revisions that we need to make,” explained Fiona Dickson from DAERA.

She said the Department hope to bring the draft regulations forward to the Stormont Assembly this autumn, ahead of the rules coming into force in 2026.