Written evidence submitted by Agricultural Industries Confederation (AIC) (FR0090)


EFRA Committee call for evidence on the Farming Rules for Water (FRfW)


Thank you for your kind attention to the following submission.


AIC is the association of the Agri-supply trade industry providing the farming sector with seeds, animal feeds, fertiliser, crop protection, agronomy services, crop marketing and trade assurance. Our members invest 50 million per annum on farm applied research and are part of a 40 million a year investment in professional advice delivery. Overall, the industry has a farmgate value of over £8 billion. The entire sector has made commitments out to 2050 in its Roadmap for a Sustainable food chain including expanding the circular economy for nutrients, decarbonisation of fertiliser production and feed,  increasing on-farm resource efficiencies and providing innovative farming solutions.


Over 90% of the arable farmed area in England and an estimated 40% of fertilised grasslands are managed with crop nutritional advice of FACTS Qualified Advisers (part of BASIS qualifications).  Feed nutritionists (FAR Advisers) are also involved in shaping grassland farming strategies. If farmers themselves have equivalent qualifications and farmers receive their advice from these qualified professionals, they will be a strong position to comply with the Farming Rules for Water and to deliver longer-term goals for improved Farm Nutrient Balance.


What impact, if any, is the EAs implementation of Farming Rules for Water preventing farmers from spreading organic fertiliser? 








Are there changes that should be made to the rules - or how they are applied?  


The rules are written to allow flexibility of interpretation – this was a welcome development which requires a culture change in the way regulations are implemented.


We need:


i)                     an agreed policy, industry communication on the water problems and solutions (general and specific messages) including where the key catchments in England are.


ii)                   Clearer open to all guidance on the approach towards monitoring FRfW compliance mirroring that which appears in the draft Sustainable Farming Inventive i.e.:


-          Farmers will be given flexibility to decide what works on their farm to deliver the outcomes for water by showing their own Nutrient Management plans and risk assessments (with FACTS advice or own qualification if needed)

-          A two-way relationship has to exist between local EA teams involving communication of key water issues and geographical hotspots and realistic timescales for changing practices if required and the farmer and or adviser competence to put together appropriate Farm Nutrient Management Plans. 

-          where things go wrong, the emphasis should be on fixing the problem with an industry-led solution based on a starting assumption of good faith rather than wrong-doing.


iii)                 An acceptance that national crop nutrient management recommendations for nutrient application rates (AHDB & Partners) are guidelines and not a prescription and therefore not a reason in isolation for non-conformance with FrRW 1.  (part a and b of this rule are interdependent but significant loss to water and environmental impact is not only determined by the nutrient application.


iv)                 A framework for assessing risk of nutrient losses from organic applications (low to high to give an indication of likelihood of nutrient loss and need for interventions (lowering applications, moving application to another field).


v)                   Clearer guidance on what significant risk to water quality is and how to determine it from the site and situation, application rates, timing, material type, pathways of loss & mitigation. New/improved technical tools and further CPD for farmers and advisers will be needed.


vi)                 Definitions & clarity of what is meant by: i) Planning nutrient applications & what nutrient management involves ii) ‘significant risk’ to water (dealing with Nitrate and Phosphate separately iii) outcomes etc.



What are the best ways of preventing agricultural diffuse pollution? 









Footnote: See Industry communication made by FACTS which paves the way: https://www.basis-reg.co.uk/news?article=frfw-regulatory-position-statement-from-ea