The Agriculture Water Quality Working Group has put forward that the “use of concentrate feed with a lower crude protein content should be encouraged where possible” as one of the key recommendations in its final draft report.

The group, which is made up of representatives from key stakeholders within the farming and agri-sector including the Department of Agriculture, Food and the Marine (DAFM), has agreed on a series of recommendations around five key themes.

These recommendations will shortly be submitted to the Minister for Agriculture, Food and the Marine to consider as part of the interim review of the Nitrates Action Programme (NAP).

The minister set up the working group in May 2023 to put forward new measures to protect water and examine how to “minimise agriculture’s impact on water quality”.

The working group has now agreed on a number of recommendations focused on five key themes:

Reducing nutrient load and loses;
Sustainability measures;
Improving compliance and enforcement;
Nutrient use and advice to farmers
Research and policy development.

The recommendations contain a number of “targeted measures” to improve water quality.

These include the recommendation that “the use of concentrate fed with a lower crude protein content should be encouraged where possible” and there should be a greater emphasis on the UFL (energy) value when compound feed is being marketed.

Among the group’s other key recommendations are that:

The current concentrate 15% crude protein limit for adult bovines at grass during the summer period “should be extended to all farms, with the existing provision for an exception to be retained”.
Farmers “who voluntarily” reduce the level of crude protein beyond legal obligation should receive recognition which would recognise such herd’s lower nutrient excretion rates – if a farmer opts for in 2024, the average level of crude protein fed to dairy cows in 2024 “should determine the dairy cow’s nutrient excretion rate within the respective dairy band that year”.
Subsequently the crude protein fed in the previous year should “determine the current year’s nutrient excretion rate within the respective dairy band”.
The UFL value of compound feed should be displayed.

The working group has also stated that it believes that a “5% cut in the chemical fertiliser nitrogen maximum allowances for those stocked at a grassland stocking rate of above 170kg N/ha is achievable”.

But it has also cautioned that there is a need for “scientific justification” if any further reduction was proposed.

The group has also stressed that any agri-environmental or industry led sustainability schemes “should support those farmers engaging in additional voluntary practices to improve water quality”.

Soil fertility and nutrient

In its recommendations the group has stated that “all nutrients being applied to land should be considered and chemical fertiliser allowances for land in receipt of organic manures should be adjusted accordingly”.

It also recommended:

Development of an app to link the online system for developing nutrient management plans (NMP) to GPS;
That farmers should have access to “improved advice on organic nutrient management and application”;
New supports and incentives should be introduced to improve nutrient management planning, especially in sensitive areas;
Shallow cultivation requirement on arable land should be enhanced through schemes to establish a cover/catch crop.

The Agriculture Water Quality Working Group also highlighted that it is aware that the Environment Protection Agency (EPA) is “due to conduct a review of the management and oversight of sludges being applied to land” which it believes is a priority.

Sustainability measures

Among the recommendations put forward by the group which they believe could deliver environmental benefits include that:

All farms should adopt the current requirement for derogation farmers when reseeding perennial rye grass based swards to incorporate at least 1.5 kg/ha of naked clover seed or at least 2.5 kg/ha of pelleted clover into the reseed;
The phasing out of straight urea should be prioritised;
The closed period for the application of nutrients to land “should be respected by all farmers and agricultural contractors”;
There should be a focus on improving slurry storage capacity on farms – this should include a 70% capital grant for all farmers investing in slurry storage facilities and these investments should be prioritised for fast-track TAMS approvals;
Planning permission for farmers who want to invest in slurry storage should be “expedited”;
The livestock manure movement notification system should be developed to require “movement notifications closer to real time.” and GPS tracking should be considered;
Routine controls should be expanded to include soil phosphorous sampling on land where poultry litter, food processing waste or sewage sludge is deposited;
The Anaerobic Digestion (AD) sector should be developed to “provide flexibility for farmers to address reductions in stocking rate limits”.

Water quality

The group has recommended the development of a new water quality improvement campaign specifically targeted at farmers.

Also among its key recommendations are that:

Local Authorities should carry out at least 4,500 targeted water quality risk-based farm inspections each year;
Penalties should be applied to famers where there are “breaches” found;
Land more than 30km away from the main holding “should not be given a livestock manure allowance greater than 170 kg N/ha”.

But one recommendation that the group has not backed is the development of a National Feed Database – “to enable the accurate calculation of nutrient use efficiency on farm when combined with the National Fertiliser Database”.

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