While most of the focus on the proposed changes to the Nutrients Action Programme (NAP) in NI has rightly been on a requirement for intensive farms to comply with a Phosphorus (P) balance, there are many more points to note in the current consultation document.

At a recent meeting in Cookstown, Aileen Lawson from the Ulster Farmers’ Union (UFU) highlighted some of the detail that has generally been missed.

1. Definition of LESSE

An amendment is proposed to the definition of Low Emission Slurry Spreading Equipment (LESSE). The amendment provides clarity that small-scale splashplates or other modifications fitted to trailing hoses which increase the surface area of the slurry being spread, will not be classified as LESSE. All farms will have to use LESSE by 2030, except on steep slopes.

2. Notification of new facilities

At present, farmers are required to notify the NI Environment Agency (NIEA) of new slurry storage 28 days prior to use.

In their NAP consultation, the department has proposed changing this to 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 NAP document.

3. Cover on slurry stores

The likes of the farm at Greenmount uses lightweight expanded clay aggregate to reduce ammonia emissions coming from their above ground slurry stores. However, the NAP consultation document is clear that all new above ground stores will have to be covered with a tight lid, roof or tent structure.

4. Penalties for false information

Under the current regulations, enforcement action for providing “false or misleading information” can only be taken against the “controller” which is effectively the farmer.

However, the department has proposed amending this to also allow action to be taken against an “appropriate person” (such as a form filler) providing information on the farmer’s behalf.

5. New penalties

The NAP consultation is clear that more water quality related inspections will be undertaken in future and these won’t just be done under the umbrella of cross compliance. The plan is to deal with minor and moderate breaches of rules by a new system of fixed or variable monetary penalties that can be applied to anyone, including those who don’t claim area payments.

6. Slurry moves

It looks inevitable that the department will look to tighten down on slurry exports off more intensive farms. The NAP consultation proposes an enhanced online system where the farm receiving the slurry must confirm receipt within four days of the movement taking place.

7. New databases

Work on a fertiliser database is already underway, with the aim to have it in place by 2027. The department has proposed including feed sales within the database, effectively giving DAERA information on all nutrients coming onto the farm.