On 25 August, the Environment Agency (EA) produced an updated statement on the Farming Rules for Water. This follows pressure from the CLA and others over the lack of clarity of what the Regulatory Position Statement (RPS 252), published earlier in August, actually means for farmers and land managers on the ground.
Here we provide more information on what the statement says, what you need to do next, and what will help the CLA make your case to government.
There is some reassuring news. RPS 252 seems to have led to a misunderstanding that applications of organic manures are prohibited from this autumn, following harvest. This is not the case. The RPS has been issued to allow applications of manures this autumn, even when the applications will exceed crop and soil need, provided certain steps are followed. Without the RPS, farmers who apply manure in excess of crop and soil need would risk being in breach of the EA’s new interpretation of the Farming Rules for Water.
The publication of the RPS represents an improvement on the position the EA held earlier in the year: their proposal was to prohibit all autumn applications of manures altogether, with the exception of grass and oil seed rape, on the basis that all other applications would not be justified from a crop need perspective. The CLA had been making representations on this for months, and we will continue pressing for rules that can be understood and applied on the ground with sufficient notice.
The updated statement from the EA sets out three steps that those applying manures and fertilisers this autumn must consider:
- If you already comply with the Farming Rules for Water, then carry on.
- If you can meet the conditions of the RPS, then contact the EA and carry on.
- If you cannot comply with the conditions of the RPS, then contact the EA. The EA will assess the situation and where they do not cause significant risks, they will allow the activities or help find alternatives if necessary.
You can contact the EA by email email@example.com or call 03708 506 506.
FACTS, in conjunction with the EA, has put together a questions and answers sheet, which members should use to clarify points they are unsure of. The questions range from general to more specific.
For a full breakdown of RPS 252 click here.
We are concerned about the temporary nature of the RPS, and the possibility that autumn applications will be prohibited once the RPS is withdrawn on 1 March 2022.
While the CLA’s view is that water quality should never be compromised, banning autumn applications of manures and moving to spring time only applications, sometimes in sub-optimal weather conditions, is not the way forward. This approach carries detrimental impacts such as:
- Increased ammonia emissions and impact on air quality.
- Increased phosphate pollution.
- Impact on soils due to smaller application window and fewer/no applications:
- Reduced organic matter content
- Reduced soil carbon levels and carbon sequestration potential
- Reduced water retention and impact on flood resilience
- Reduced soil biodiversity
- Increased risk of soil damage due to wetter weather in spring- runoff and compaction
- Increased use of artificially produced ‘bagged’ fertiliser to maintain soil fertility, the manufacture of which is energy intensive and had implications for carbon emissions.
- Increased costs and pressures on manure producing livestock industries.
Improved manure and slurry storage facilities may help reduce the chances of applications being made in sub optimal conditions when stores are full, though the EA and Defra must appreciate that increased storage is costly, may require planning permission and cannot be provided overnight. Increased storage also does not solve the issue of manure application.
The CLA will lobby for grant schemes that will improve manure storage capacity, such as the Slurry Investment Scheme, to be fast-tracked.
The CLA has been speaking to concerned members and has been compiling a suite of case studies that will be put directly to Defra and the EA. The CLA will continue to challenge Defra and the EA to create more joined-up regulation that is clearly understood and also delivers on improved water quality.
If you would like to provide a case study or need further advice please contact Cameron Hughes by email firstname.lastname@example.org or call 020 7235 0511.