This article summarises the targets, and regulation imposed under the Clean Air Strategy, specifically the proposals for mitigating ammonia emissions from agriculture.
The consultation for the Clean Air Strategy opened 22 May 2018 and ran for 12 weeks. The NFU worked closely with Defra throughout the process of the development of the strategy, specifically around the approach to reducing ammonia emissions from farms.
The NFU submitted a comprehensive 39 page response to the consultation laying out the key concerns and asks.
The table below shows the proposed regulation from the consultation and the regulation that has been put forward in the strategy.
Regulation proposed in consultation | Regulation set in final Clean Air Strategy |
1. Introduction of nitrogen (or fertiliser) limits: The consultation talks about setting nitrogen limits at a level which reflects the cost of fertiliser application to the environment, not just the economic optimum to the farmer for that crop. The proposal states that it will task a group of independent specialists to make recommendations by November 2019 on the maximum limits that should be applied for (organic and inorganic) fertiliser which take into account commitments to reduce ammonia. | Regulate to minimise pollution from organic and inorganic fertiliser use We will task an expert group including agricultural policy experts, agronomists, scientists and economists to make recommendations on the optimal form of regulation to minimise pollution from fertiliser use. The recommendations should prioritise the use of organic fertilisers, limiting ammonia emissions, GHG emissions and water pollution and protecting sensitive habitats at least in line with government commitments. |
2. Extension of environmental permitting to large dairy farms by 2025: This would involve extending similar controls that are currently applied to pig and poultry to larger dairy farms. The consultation does not specifically say what size would be classified as a large farm. Permitting would mean that dairy farms would have to adhere to certain emission limits and apply Best Available Techniques (BAT). Regulated farms would be given till 2025 to implement the changes to comply with the permit. The consultation anticipates that permitting by itself would not be sufficient to meet ammonia reduction targets. | Extension of environmental permitting to dairy and intensive beef farms by 2025 ….we will work with the industry to agree appropriate emission limits and Best Available Technique (BAT) documents for limiting pollution from these sectors. Defra have not determined what is intensive or how they will permit. The NFU will continue to work with Defra in it’s development. |
3a) requirement to spread urea-based fertilisers in conjunction with urease inhibitors, unless applied by injection on appropriate land by 2020 | a requirement to take action to reduce emissions from urea-based fertilisers. We will consult on this policy in 2019 with a view to introducing legislation in the shortest possible timeframe |
b) mandatory design standards for new livestock housing by 2022; standards would be developed in conjunction with industry and cover at least poultry, pig and dairy housing | mandatory design standards for new intensive poultry, pig and beef livestock housing and for dairy housing. The standards will be designed in collaboration with industry experts |
c) requirement for all solid manure and solid digestate spread to bare land to be incorporated rapidly (within 12 hours) by 2022 | a requirement for all solid manure and solid digestate spread to bare land (other than that managed in a no-till system) to be incorporated rapidly (within 12 hours) with legislation to be introduced in the shortest possible timeframe |
d) requirement to spread slurries and digestate using low-emission spreading equipment (trailing shoe or trailing hose or injection) by 2027 | a requirement to spread slurries and digestate using low-emission spreading equipment (trailing shoe or trailing hose or injection) by 2025. We will also consider options for phasing in this requirement so that those spreading digestate or large volumes of slurry may be required to adopt the practice at an earlier date |
e) the requirement for all slurry and digestate stores and manure heaps to be covered by 2027 | a requirement for slurry and digestate stores to be covered by 2027. We will consider options for phasing in this requirement so that those producing or storing digestate or large volumes of slurry may be required to adopt the practice at an earlier date. No requirement to cover muck heaps |
For AD: anaerobic digestion (AD) supported by government schemes be required to use best practice low emissions spreading techniques through certification | No measures but will be required to cover digestate/slurry stores and use low emission spreading equipment |
There are still a lot of unanswered questions following the launch of the Clean Air Strategy and Defra has said it wants to work with industry to develop the regulation. We still do not know what will fall into the category of ‘intensive’? How will Defra determine what beef or dairy farms should be permitted? What will permitting for beef and dairy look like? What is classified as ‘bare’ land? And how exactly will Defra support farmers to implement these changes?
Although the strategy has introduced some very concerning regulation to farmers, the lobbying from the NFU has resulted in some significant wins for the industry which we set out in our consultation response.
Wins
- Defra’s proposal to set up a working group to set nitrogen limits has been given a broader remit to make recommendations on the optimal form of regulation to minimise pollution. Therefore, there is scope to implement a solution that will not hinder productivity but instead improve nutrient use efficiency.
- Defra has decided to look further and consult on a policy to reduce emissions from urea-based fertiliser instead of an instant ban on urea. This allows the NFU further opportunity to demonstrate the importance of urea as an input and to the fertiliser market.
- NFU asked that Defra recognised no-till systems when they proposed rapid incorporation of solid manure to bare land. This has been taken into account as part of the regulation.
- There is no requirement to cover muck heaps.
Next steps
Defra is looking to move quickly with the strategy’s regulation and is keen to work with industry in forming the design and detail. Therefore, the NFU will be working hard, alongside other organisations such as the AIC and AHDB to ensure that members are supported by government to make these changes and that the hard work that takes place to reduce ammonia emissions by farmers is recognised.