fertiliser controls under cross compliance dr al grogan fertiliser association of ireland meeting 6...
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Fertiliser Controls under Cross Compliance
Dr Al Grogan
Fertiliser Association of Ireland Meeting6th Feb 2007
2INTEGRATED CONTROLS DIVISION
OVERVIEW• Reform of CAP• Cross Compliance Requirements• Managing Fertilisers and nutrients
– Organic– Chemical
• Nitrogen• Phosphorus• Records• Inspections
3INTEGRATED CONTROLS DIVISION
CAP Reform
A farmer is now free to engage in an Agricultural production activity or not as he pleases and receive the single payment.
• Agricultural activity includes the production, rearing or growing of agricultural products
• A farmer may choose not to produce anything• but is obliged either way to maintain lands
– in Good Agricultural and Environmental Conditions (GAEC)GAEC) and
– Comply with all Statutory Management Requirements (SMRsSMRs) applying to him
4INTEGRATED CONTROLS DIVISION
Reformed CAP
Full decoupling introduced
Series of reforms…ID checks in place for some time but Cross Compliance type checks first introduced with GFP in 2000
Coupled schemes had compliance requirements mainly in the identification area and GFP
Decoupled Payments introduced the Cross Compliance requirements of GAEC and SMR’s (Statutory Management Requirements)
5INTEGRATED CONTROLS DIVISION
Cross Compliance The 19 Community legislative acts categorised into 3
Areas and the GAEC from the implementing legislation entail Cross Compliance
EnvironmentEnvironment
• 5 directives on environment – Wild Birds, Habitats, Groundwater, Sewage Sludge and Nitrates
Public, animal and plant healthPublic, animal and plant health • 4 Directives/Regulations on the identification and
registration of animals • 7 Directives on public, animal and plant health WelfareWelfare
• 3 Directives on animal welfare (2007)GAECGAEC
• 19 Standards
RETURN
6INTEGRATED CONTROLS DIVISION
Commission Line
• “Farmers are not paid to respect environmental and other legislation but if they don’t respect that part encompassed through cross compliance they render themselves subject to reduction of direct payments”
7INTEGRATED CONTROLS DIVISION
Fertilisers
Impact particularly under the SMR’s relating to:
– Groundwater,
– Sewage Sludge,
– Nitrates
8INTEGRATED CONTROLS DIVISION
Fertiliser Controls under the Nitrates Directive
• Impacts on Nitrogen and Phosphorus from organic and chemical sources– Farmyard
•Collect all organic fertilisers produced in buildings or yards (livestock manure, soiled water, FYM etc.)
•Ensure that storage facilities are free of structural defects
•Provide Adequate capacity for the zone
9INTEGRATED CONTROLS DIVISION
Managing fertilisers and nutrients
Application limit of 170 kg N/ha/yr from livestock manure (e.g. 2 dairy cows/ha/year)
• DAF will provide a Nitrogen and Phosphorus Statement for cattle using CMMS for the previous calendar year. The N and P from other livestock/sources on the farm must be added to this
• Total nitrogen produced by livestock divided by net area of the holding (from SPS) is used to determine compliance with the 170 Kg limit
10INTEGRATED CONTROLS DIVISION
Managing fertilisers and nutrients
Derogation Option:Available up to 250 kg N/ha/yr
Applicable to holdings with at least 80% grass
Annual application to Competent Authority
Must comply with additional requirements
11INTEGRATED CONTROLS DIVISION
Managing fertilisers and nutrients
Additional Derogation Requirements:
Fertilisation Plan
Fertilisation Accounts
Soil Testing (N and P)
Additional land management
requirements
Additional monitoring and controls
required
12INTEGRATED CONTROLS DIVISION
Managing fertilisers and nutrients
• Buffer zones and weather and soil conditions to be respected
• An occupier of a holding shall take all such reasonable steps are necessary for the purpose of preventing or minimising the application to land of fertilisers in excess of crop requirements
• Fertilisation rates in the Regulations must not be exceeded
• Must assume Phosphorus Index 3 unless a soil test shows otherwise
• In the case of grazing livestock must take account of:
– N and P in livestock manures over storage period– P in concentrates fed to grazing livestock
13INTEGRATED CONTROLS DIVISION
N Fertilisation Rates
<170>170-210>210-250
Max Fertilisation Rate of Available N on Grassland
Grassland Stocking Rate kg/ha Available N (kg/ha)
306279
226
14INTEGRATED CONTROLS DIVISION
What impacts on application rates of available nitrogen
The annual Maximum Available Nitrogen on Grassland from chemical fertiliser and other non livestock fertilisers is determined by stocking rate band and the county zone
Grassland Stocking Rate
kg / ha A B C1 C2 A B C1 C2<170 210 208 206 204 205 203 200 197
>170-210 287 284 282 279 280 277 274 271>210-250 256 253 250 247 248 245 241 237
Fertiliser N in 2007 by Zone Fertiliser N in 2010 by Zone
15INTEGRATED CONTROLS DIVISION
What influences maximum application rates
They will be reduce somewhat as the higher N
efficiency rates apply between now and 2010How are the limits arrived at:
• Determined by Grassland stocking rate and the storage zone applicable and
• The appropriate N efficiency factor
4.35.3.*)52/22201816*(279* orororororalsNfromGAnimndAREANetGrasslaN
4.35.3.*)52/22201816*(306* orororororalsNfromGAnimndAREANetGrasslaN
4.35.3.*)52/22201816*(226* orororororalsNfromGAnimndAREANetGrasslaN
16INTEGRATED CONTROLS DIVISION
Nutrient Availability
Fertiliser Availability1 (%)
NItrogen Phosphorus
From Jan 1 2007
From Jan 1 2008
From Jan 1 2010
From Jan 1 2007
Chemical 100 100 100 100
Pig and poultry manure 35 40 50 100
Farmyard manure 20 25 30 100
Spent mushroom compost 35 40 45 100
Cattle and other livestock manure (including that produced on the holding)
30 35 40 100
1Refers to the year of application
17INTEGRATED CONTROLS DIVISION
2007 T0 2010 Nitrogen Limit Changes (kg/ha)
190200210220230240250260270280290
A B C1 C2<170 170-210 210-250
190200210220230240250260270280290
A B C1 C2
18INTEGRATED CONTROLS DIVISION
What impacts on application rates of available nitrogen
Grassland stocking rates can increase above the 170 value where at least 5% of farm is arable
GRASSLAND STOCKING RATE & % GRASSLAND
170180190200210220230240250260
68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95
% OF FARM IN GRASSLAND
GR
AS
SL
AN
D S
R
19INTEGRATED CONTROLS DIVISION
Controls for Tillage CropsNitrogen Index status determines the Max
level of N that can be used
Nitrogen Index is determined by the previous cropping history (available from the historic area aid and SFP applications)
Where a second crop is planted such as Kale this will be taken into account based on records provided
Additional N may be applied to higher yielding cereal crops (based on historic yields). Evidence will need to be provided
20INTEGRATED CONTROLS DIVISION
Sample of Maximum N fertiliser rates
Crop Nitrogen Index
1 2 3 4
Available Nitrogen (kg/ha)Winter Wheat1 190 140 100 60Spring Wheat1 140 110 75 40Winter Barley1 160 135 100 60Spring Barley1 135 100 75 40Oats (Spring) 110 90 60 30Sugar Beet 195 155 120 80Fodder Beet 195 155 120 80Potatoes: Main crop 170 145 120 95Potatoes: Early 155 130 105 80Potatoes: Seed 155 130 105 80
21INTEGRATED CONTROLS DIVISION
Maximum Fertilising Rates of Phosphorus on Grassland determined
by P Index and SR
Grassland Stocking Rate
kg / ha 1 2 3 4<130 35 25 15 0
>130-170 39 29 19 0>170-210 44 34 24 0>210-250 49 39 29 0
Phosphorus Index
22INTEGRATED CONTROLS DIVISION
Maximum Fertilising Rates of Phosphorus on Grassland determined
by P Index and SR
0
10
20
30
40
50
Kg P
1 2 3 4
Phosphorus Index<130 >130-170
>170-210 >210-250
23INTEGRATED CONTROLS DIVISION
• Determine the P allowed on the farm based on– plot area and – P index and – in the case of grassland stocking
rate– Max fert rates appropriate to
grassland and the other crops• Adjust for p in stored livestock
manure and p in concentrates fed to grazing animals
Phosphorus Controls
24INTEGRATED CONTROLS DIVISION
Controls …. records
Total area of the holding
• Net area of the holding
• Crop areas
• Livestock numbers and type
• Estimate of annual fertiliser requirement
• Quantities and types of chemical fertilisers moved onto or off the holding
RETURN
25INTEGRATED CONTROLS DIVISION
Controls …. records
• Details of livestock manure and other organic fertilisers moved onto or off the holding
• Copy of any NMP prepared (e.g REPS plan)
• Results of any soil tests
• Description of facilities for the storage of livestock manure, soiled water, FYM, etc.
• Quantities and types of concentrated feedstuff fed to grazing livestock
• Location of any water abstraction point
RETURN
26INTEGRATED CONTROLS DIVISION
Controls Inspections
• 1% of applicants selected on the basis of a risk analysis
• Inspector will record details which in combination with the records submitted before 31 March of the following year will be used to determine compliance with the requirements.– Any plot details varying from the
application– Stock details– Housing details
RETURN
27INTEGRATED CONTROLS DIVISION
Sanctions Summary• Negligence
– generally 3% but could be increased to 5% or reduced to 1% depending on the seriousness of the non-compliance. Could be 0%
• Intent– generally 20% but could be increased to 100% or reduced
to 15% depending on the seriousness of the non-compliance
– Penalty could be extended outside the year of the finding• Repetition
– Where in breach again within 36 months, repetition impacts according to a defined set of rules
• the penalty will be multiplied by 3 to a limit of 15% after which the breach is considered an intent breach