Written evidence submitted by Mr Julian Gibbons (FR0081)
Consultation on Farming Rules for Water
In considering the recent decision by government to ban autumn applications of all organic manures for crops without a proven requirement under the Farming Rules for Water three points come to mind…
Firstly, the recently announced Sustainable Farming Incentive stated that under the Arable and Horticultural Soils Standard, farmers in the introductory payment rate are expected to test for soil organic matter (OM) every 5 years and increase soil organic matter on a minimum of 10% of land entered into the standard every year. In addition, farmers in the advanced payment rate will have to increase their soil OM on a minimum of 20% of land. Of course, the first source of increasing soil OM, as stated in the SFI documentation, is organic manures. Applying the required rates of organic manures in order to produce a noticeable rise in soil OM can not be restricted to spring applications. Many spring crops on an arable farm are legumes and no requirement for nitrogen. A large area of spring barley will be grown for malting and distilling markets, where the uncontrollable nutrient release of organic manures can be deleterious to achieving market specifications. In the case of biosolids, these are in many cases contractually banned on spring malting barley by the maltsters and distillers. Spring soils are wet soils that are becoming drier they are therefore more prone to damage then late summer autumn soils that generally are dry soils getting wetter.
Government is also trying to encourage the integration of arable with livestock farming, as mixed farming practices show evidence of greater sustainability. The grazing of sheep and cattle results in fertiliser deposits of similar nutrient levels compared to the application of organic manures.
Secondly, although crops may not have an autumn nutrient requirement for nitrogen fertiliser, this does not mean that they will not utilise it. Winter wheat crops that have had late summer application of farmyard manure (FYM) or biosolids will utilise the fertiliser by increasing shoot number and leaf number resulting in higher tiller. This is seen in crops grown after peas and beans that leave significant amounts of N for the succeeding winter cereal. This then results in lower levels of spring applied inorganic N.
The table below shows winter wheat plant and shoot (tiller) counts taken early spring 2021
Field Plants Tillers Previous crop
Park 210 840 Peas
Brickiln 262 1050 Peas
Pond 214 963 Peas
Redhill 214 749 Oats
Old Pauls 275 1375 Beans
Severals 288 1588 Beans
Ashes 206 515 Oats
Middle Field 261 1174 Beans
Lukes Common 220 990 Beans
Peaked Common 248 1113 Bean
Gaston Common 179 805 Beans
Grahams 206 1031 Beans
The tiller counts behind oats with low residual nitrogen levels are significantly lower
Finally, large areas of the country are subject to Nitrate Vulnerable Zone rules including our own farm and another I advise on. This correctly restricts the use of slurries and manures with high levels of available nitrogen. Except in the case of poultry manures these are generally slurries (including digestate from Anaerobic digesters). There are well developed application techniques that are available for spreading onto growing crops in the spring that utilise the “tramlines” used for pesticide and other fertiliser applications. These are not available for solid applications that need to be incorporated into the soil. It could be that restrictions for poultry manures and slurries could be brought in on non-NVZ land. This could be based on drilling date of the following crop and/or soil type to reduce risk of diffuse pollution.
Existing established good practise that are reflected in farm assurance standards prevents spreading of any manures and slurries when heavy rain is expected, requires prompt incorporation and must comply with no spreading areas ( water courses, boreholes,wells)
Because biosolids contain a similar amount of available Nitrogen to FYM, any derogation granted to water companies would unfairly penalise FYM. However not granting a derogation would leave the water industry needing to find a different method of disposal as the land would not be available in the spring. They have looked at thermally dried sewage sludge that produces a material that can be spread with a conventional fertiliser spreader, however the production uses a lot of energy and can be unreliable. It would also come with a high carbon footprint.