Dairy farms must be judged on outcomes, not size, says NFU adviser

The Wildlife Trusts’ Doing dairy differently report raises concerns about herd size including reference to ‘mega dairies’, housed systems, slurry management and water quality, while calling for stronger regulation and more nature-friendly production.

The NFU welcomes discussion about how farming can become more resilient, productive and environmentally sustainable.

Dairy farmers depend on healthy soils, clean water, productive grassland and a stable climate, nobody has a greater interest in protecting these resources than the farmers themselves.  

However, the discussion must be balanced and reflect the diversity, progress and realities of modern dairy farming.

The sector has changed significantly. GB producer numbers have fallen, as of April 2026 to 6850, while average herd size has increased to 175, driven by economic pressures, rising costs and the need to improve efficiency. Greenhouse gas emissions per litre of milk have fallen by around 22% since 1990 and methane emissions are 14% lower, through improvements in productivity, genetics, animal nutrition, animal health and resource efficiency.

The Sustainable Dairy Pathways report which was published this year sets out practical actions needed to deliver meaningful progress in sustainability by 2030. It states one of the end goals being no serious pollution incidents, legal compliance and sustainable water use. However, to achieve the delivery of a pathway to 2030 will require sector wide investment of around £2.4 billion with the large majority of that being in slurry and manure infrastructure/management and energy.  

The Doing dairy differently report draws particular attention to housed dairy systems and larger farms.

However, size alone is not a reliable indicator of environmental or welfare performance.

Across the UK there are excellent examples of both small and large dairy businesses delivering high standards of animal welfare, nutrient management and environmental stewardship.

Farming systems must be judged on outcomes rather than assumptions based on scale. 

The report states that 71% of serious agricultural pollution incidents were attributed to dairy activity but what they do not delve into is the data behind that.

Between 2025 to 2026 there were seven category one pollution incidents and 41 category two, which is down from the previous year. 

The majority of these were due to storage infrastructure and drainage which further backs the findings from the Sustainable Dairy Pathways report around investment needs.

The NFU is not rebutting the fact that pollution incidents are unacceptable and must be addressed, but what is unclear from the data is whether these incidents were down to accidents, underinvestment in slurry management, or whether there is a link between farm size and pollution incidents.

Many dairy farmers have invested substantially in slurry storage, precision nutrient application, clean and dirty water separation, improved drainage and staff training.

Further progress will require effective regulation and financial assistance, alongside practical advice and support.

The Wildlife Trust’s report calls for environmental permitting to be extended to what it describes as the “higher risk” dairy systems.

While poor environmental performance must be tackled wherever it occurs, the NFU would caution against the use of such a blunt and expensive tool, which does not account for the diverse range of dairy systems in the UK from being introduced. Nor is defining risk simply by herd size the best way to achieve emission mitigation potential in the sector. 

Environmental risk depends on several factors, including storage capacity, nutrient management, land availability, local geography, infrastructure and day-to-day management. A large farm with modern facilities and robust nutrient planning is not automatically higher risk.  

The key question is whether a farm has the land, facilities and management systems needed to operate responsibly. Existing rules already require farmers to protect water, manage nutrients and minimise pollution.

Any regulatory changes must be evidence-based, proportionate and developed alongside farmers. The objective should be to target regulatory action linked to risk potential, which is not just a matter of scale.

Supply chains also have a responsibility; farmers cannot continually absorb the cost of environmental measures while facing volatile milk prices and rising inputs.

Processors and retailers must recognise and reward environmental delivery through fair, sustainable returns. This should not become a choice between nature and food production.  

Farmers, environmental organisations, government and the supply chain share important goals: cleaner water, healthier soils, thriving wildlife and resilient businesses. Progress will come through collaboration, the Dairy Roadmap, innovation and investment, supported by sensible, proportionate regulation. 

British dairy farmers are not obstacles to environmental progress; they are essential partners in delivering it.