Written evidence submitted by Philp Farming Ltd (FR0051)

1. What impact, if any, are the EAs implementation of Farming Rules for Water Regulation prevents farmers from spreading organic fertiliser?

The EA have decided that to reduce diffuse pollution to rivers I cannot spread organic manure to land post harvest in late summer early autumn. The decision making is based on a guideline given to Farmers called RB209.The author of this guideline has categorically said that this should not be rubber stamped by the EA as law, but they have!

I now have to spread most of my organic manures in spring at considerably more cost and greater risk of damaging the soil in wet spring conditions.

I also have been told I cannot spread any phosphate containing manures (which is all of them) to land that has a phosphate soil index above a certain level. This is 66% of my land that cannot have any organic nutrients so I will have to apply inorganic fossil fuel derived fertilizer instead! WHERE IS THE COMMON SENSE AND LOGIC WITH THE GOVT DEPARTMENTS!

2. Are there change that should be made to the rules or how they are applied?

Don’t go by date. Go by the principle of the polluter pays. For example organic slurry applied in early march to cold wet ground sloping down to a river is legal but will likely lead to diffuse pollution. While the slurry could have been applied illegally to an arable field in August after harvest in dry conditions with less risk of diffuse pollution.

Please do not penalise farmers for actively trying to improve their soils through applying organic manures. Phosphate cannot leach from a soil into rivers unless it is carried through a medium of soil or wind erosion. The best way to stabilise soils to prevent that is healthier soils higher in organic matter!   

3. What are the best ways methods of preventing agricultural diffuse pollution?

Polluter pays, and that includes the water companies. There is a massive fealing of injustice where farmers feel penalised for doing the right thing, but getting the blame for water pollution when in effect water companies have got away with sewage discharges for years. Farmers don’t open the valves to their slurry stores and pump it into the rivers just because they have not invested in greater capacity to cope with more sewage.

The EA must realise that Nitrate and Phosphate pollution are different. Greater levels of improved soil management will lead to less soil erosion which will lead to less soil Phosphate in rivers. However Phosphate in rivers will continue to be a problem unless sewage discharges are reduced. 

December 2021