Response on behalf of the Agri-Partnership Organic Strategy Group</t= itle> <o:SmartTagType namespaceuri=3D"urn:schemas-microsoft-com:office:smarttags" name=3D"PostalCode"/> <o:SmartTagType namespaceuri=3D"urn:schemas-microsoft-com:office:smarttags" name=3D"PlaceType"/> <o:SmartTagType namespaceuri=3D"urn:schemas-microsoft-com:office:smarttags" name=3D"PlaceName"/> <o:SmartTagType namespaceuri=3D"urn:schemas-microsoft-com:office:smarttags" name=3D"City"/> <o:SmartTagType namespaceuri=3D"urn:schemas-microsoft-com:office:smarttags" name=3D"country-region"/> <o:SmartTagType namespaceuri=3D"urn:schemas-microsoft-com:office:smarttags" name=3D"place"/>  <style>  </style>  </head> <body lang=3DEN-GB link=3Dblue vlink=3Dpurple style=3D'tab-interval:36.0pt'> <div class=3DSection1> <o:p> </o:p> <h3 align=3Dcenter style=3D'margin-top:0cm;text-align:center'>Response from the Welsh Agri-food Partnership Organic Strategy Group prepared by Organic Centre <st1:country-region w:st=3D"on">Wales</st1:country-region= >, <st1:PlaceName w:st=3D"on">Aberystwyth</st1:PlaceName> <st1:PlaceType w:st=3D"on">Universi= ty</st1:PlaceType>, <st1:place w:st=3D"on"><st1:City w:st=3D"on">Aberystwyth</st1:City>, <st1:P= ostalCode w:st=3D"on">SY23 3AL</st1:PostalCode></st1:place><o:p></o:p></b= ></h3> <h3 align=3Dcenter style=3D'margin-top:0cm;text-align:center'>to the Welsh Assembly Government consultation on: <o:p></o:p></h3> <h3 align=3Dcenter style=3D'text-align:center'>The Protection of Waters against Pollution from Agriculture.<o:p= ></o:p></h3> <a href=3D"http://new.wales.gov.uk/consultations/currentconsultation/envandcou= ncurrcons/220807-141107nitrate/?lang=3Den">http://new.wales.gov.uk/consulta= tions/currentconsultation/envandcouncurrcons/220807-141107nitrate/?lang=3De= n</a> <o:p></o:p> <h3>Background<o:p></o:p></h3> The Organic Strategy Group was formed in March 1999, one= of the four strategy groups and four regional groups then forming the Welsh Agri-Food Partnership, which are responsible for steering the implementatio= n of the sector plans for Wales.<o:p></o:p> Since its formation one of the primary roles of the Orga= nic Strategy Group has been the implementation of the first and second Welsh Organic Action Plans published in March 1999 and July 2005 respectively.<o:= p></o:p> Organic Centre Wales (OCW) was established in 2000 with funding from the Welsh Assembly Government as a focal point for the dissemination of information on organic food and farming to producers and o= ther interested parties in <st1:country-region w:st=3D"on"><st1:place w:st=3D"on= ">Wales</st1:place></st1:country-region>. In 2003, the remit was extended to include public education, public procurement, policy and strategy development.<sp= an style=3D'mso-spacerun:yes'> OCW is based at <st1:PlaceName w:s= t=3D"on">Aberystwyth</st1:PlaceName> <st1:PlaceType w:st=3D"on">University</st1:PlaceType>, and run by a partner= ship of four organizations actively involved in organic farming research and knowledge transfer in <st1:country-region w:st=3D"on">Wales</st1:country-re= gion>: ADAS, The Organic Research Centre Elm Farm, the <st1:PlaceType w:st=3D"on">= Institute</st1:PlaceType> of <st1:PlaceName w:st=3D"on">Grassland</st1:PlaceName> and Environmental Research (IGER), and the <st1:place w:st=3D"on"><st1:PlaceType w:st=3D"on">= Institute</st1:PlaceType> of <st1:PlaceName w:st=3D"on">Rural Sciences</st1:PlaceName></st1:place> at Aberystwyth University (IRS).<o:p></o:p> <h3>Response<o:p></o:p></h3> <o:p>= </o:p> <![if !supportLists]>1. <![endif]>= Do you agree with the Welsh Assembly Government assessment that there should continue to be a targeted approach to NVZ designation in <st1:country-region w:st=3D"on"><st1:place w:st=3D"on">Wales= </st1:place></st1:country-region>?<o:p></o:p> <o:p>= </o:p> Yes<o= :p></o:p> <o:p> </o:p> <![if !supportLists]>2. <![endif]>= Do you h= ave comments on the areas proposed for designation as NVZs in Wales shown on the indicative map (at Annex B) given the Nitrates Directive's basis on which nitrate polluted waters must be identified and land draining into those wat= ers must subsequently be designated?<o:p></o:p> <o:p> </o:p> The data gathering seems to have been comprehensive and = the basis of identification appropriate. These areas include where intensive agriculture can be practiced therefore N application could exceed 170kg N/ha.<o:p></o:p> <o:p> </o:p> <o:p> </o:p> <![if !supportLists]>3. </spa= n><![endif]>How would the practical management of typical livestock and arable enterprises = need to change in order to achieve compliance with the proposed changes to the different aspects of NVZ regulations?<o:p></o:p> <o:p> </o:p> <o:p> </o:p> Most organic enterprises would not need to change. For other farmers the greatest nee= d for change is in record keeping, manure and slurry management and awareness of = and calculation of nitrogen balances. For far= mers with a higher stocking rate (>2LSU/ha) there would have to be a stock reduction or arrangements for excess manures/slurry to be spread outside the NVZ. <o:p></o:p> <o:p> </o:p> The NVZ area could be an opportunity to encourage non organic farmers to convert to organic methods to address these problems = 211; Ideally OCW could support specifically target events at NVZ farmers as described below, informing them of the Organic Conversion Information Servi= ce. Farming Connect Whole Farm plans could help to plan/ implement changes.<o:p= ></o:p> <o:p> </o:p> EOR approach is valuable so that farmers can have an assessment of their current management and proposals for improvement where necessary. Winter housing arrangements, management of dirty water, capacity= of slurry tanks / lagoons are important in a changed climate with high rainfall patterns that can overwhelm existing systems.<o:p></o:p> <o:p> </o:p> <o:p> </o:p> <![if !supportLists]>4. </spa= n><![endif]>What do consultees see as being the m= ain trends in farming within NVZ areas? How will the revised Action Programme impact on these?<o:p></o:p> <o:p> </o:p> Organically farmed areas in <st1:place w:st=3D"on"><st1:country-region w:st=3D"on">Wales</st1:country-region></st1= :place> are currently increasing by around 10% each year, and it is likely these changes are occurring in the NVZ areas.&nb= sp; Conversion to organic management and access to the Organic Farming Agri-environment scheme will offer guidance and financial support to farmer= s to enable the achievement of the action plan.<o:p></o:p> <o:p> </o:p> Impact of SFP may be some stock reductions in marginal areas and more intensive stocking in more favoured areas. Conversion to organic farming could see some change in sheep:cattle ratios on liv= estock farms, and - encouraged by Tir Gofal, cost of bought-in feed - more arable cropping where conditions allow.<o:p></o:p> <o:p> </o:p> <o:p> </o:p> <o:p> </o:p> <![if !supportLists]>5. </spa= n><![endif]>On some farms in NVZ areas soils will need to be categorised into “sandy or shallow”, and “clayey/loamy”. What difficulties, if any, have farmers had with identifying soil type under the current Action Programme? <o:p></o:p></span= > <o:p> </o:p> Generally farmers can describe their = soil types, but we can not speak to the accuracy of their assessment. <o:p></o:p= > <o:p> </o:p> What training or guidance would be required by farmers to enable them = to make this distinction between soil categories?<o:p></o:p> <o:p> </o:p> During group training sessions on the implications of the NVZ designation, soil maps should be used to indicate t= he expected soil categories in the area in question and a soils specialist sho= uld be on hand to answer questions. Farmers could be invited to bring small bags of soil from fields they are unsure of. Simple soil assessment methods could be introduced such as t= he use of ‘soil balls’. </s= pan><o:p></o:p> <o:p> </o:p> <o:p> </o:p> <![if !supportLists]>6. <![endif]>= Are ther= e any further exemptions to the closed periods that would give farmers flexibility while ensuring that there is no nitrate run-off to watercourses?<o:p></o:p>= <o:p> </o:p> We have concerns over the use of clos= ed periods, as weather is increasingly unpredictable, and some winter temperat= ures allow grass growth and therefore take-up of nutrients, whereas at other tim= es rainfall and cold could present high risks. As farmers are required to underta= ke a field inspection to consider the risk of runoff prior to spreading, and giv= en the requirement listed under 6.5.3, the closed periods seem somewhat artificial. Please also see n= ote to question 12.<o:p></o:p> <o:p> </o:p> <![if !supportLists]>7. </spa= n><![endif]>To what extent will farms be able to satisfy the storage requirements?<o:p></o:p> <o:p> </o:p> If our interpretation that storage is required for the likely production under the current farming practice (i.e.= if extended grazing is practiced, storage for 22 weeks’ production of sl= urry from all livestock is not expected.) Some element of risk assessment will be necessary for exceptional weather conditions. <o:p></o:= p> It is likely there will be problems f= or some farmers. Hopefully EORs = can be used to give an indication of the situation.<o:p></o:p> There should also be increased emphas= is on appropriate stocking rates (if you have limited facilitates, keep less stock) – again assessed as part of Whole Farm Plans under Farming Connect.<o:p></o:p> <o:p> </o:p> <![if !supportLists]>8. <![endif]>= How impo= rtant would it be for the Welsh Assembly Government to pursue with the European Commission the possibility of a derogation to the 170kg/ha/annum Nitrogen loading limit?<o:p></o:p> <o:p> </o:p> We are unsure. It should be possible to meet the = limit in most situations. –farmers could learn from organic systems that operate within these limits.<o:p></o:p> <o:p> </o:p> <![if !supportLists]>9. </spa= n><![endif]>The Nitrates Directive does not explicitly require cover crops to be included in the Action Programme. Howe= ver, it is considered that the evidence indicates that they are a cost-effective method for tackling diffuse water pollution. Views about their inclusion in= the Action Programme would be welcomed.<o:p></o:p> <o:p> </o:p> A recommendation for use of cover cro= ps and explanation of their benefits (including preventing soil erosion) will = be helpful, but it would not be practical to oblige their use, as conditions w= hich may prevent their establishment often overtake the best laid plans. <o:p></= o:p> <o:p> </o:p> Information on the use of different c= over crops would need to be explained, and the difference between N fixers and N lifters. Also the suitability of different crops in different weather regio= ns.<o:p></o:p> <o:p> </o:p> <o:p> </o:p> <o:p> </o:p> <![if !supportLists]= >10. <![endif]>= The NVZ Management Plan template that will be issued by the Welsh Assembly Government will provide a step-by-step guide to help farmers make the necessary calculations on which to base decisions regarding compliance with the revised Action Programme measures. = What further guidance and training could be usefully provided to help farmers in= NVZ areas to make the best decisions both for compliance with Action Programme measures and for their businesses? When and where would such training/guida= nce be best delivered?<o:p></o:p> <o:p> </o:p> Workshops should be held introducing farmers to their new obligations, and they should be assisted with the calculations. An on-line calc= ulator which enables results and input figures to be printed would be most helpful. Generally, our feeling is that when farmers understand the benefits of nutr= ient conservation, they will aim to benefit from support offered and to comply w= ith the requirements.<o:p></o:p> <o:p> </o:p> Incorporate in to FC whole farm management plans<o:p></o:p> <o:p> </o:p> <![if !supportLists]= >11. <![endif]>= To what extent would consultees wish to (or be able to) assist the Wel= sh Assembly Government with developing the NVZ Management Plan template?<o:p></o:p> <o:p>&nb= sp;</o:p> We are strong supporters of integra= ted management plans and would be happy to assist with developing the template, using experience from nutrient planning for organic farms.<o:p></o:p></span= > <o:p>&nb= sp;</o:p> <![if !supportLists]= >12. <![endif]>= Are ther= e any improvements that consultees would like to see in the current Field Record Sheets (Annexes 6 & 7 of “Guidelines for farmers in NVZs”)?= <o:p></o:p> <o:p> </o:p> The record sheet seems to have little use, given there is no encouragement for summing applications, noting applications from grazing, or calculating nutrient off-take from crops. An audit of farm records would ass= ist the farmer in identifying the most efficient way of keeping the necessary records and help the records to be of use in farm management.<o:p></o:p></s= pan> <o:p> </o:p> <![if !supportLists]>13. <![endif]>= What mechanisms could be put in place= to support farms that produce a surplus of manure/slurry? For instance an initiative to link arable holdings that have straw as a by-product, but req= uire manure/slurry, with livestock farms that need to export manure/slurry but w= hich require straw.<o:p></o:p> <o:p> </o:p> An initiative such as this may be use= ful but transport of fresh manures or slurry is expensive and energy demanding. Working with= the farmer to identify appropriate stocking rates for the land through Whole Fa= rm Plans including nutrient balances would be helpful.<o:p></o:p> <o:p> </o:p> <![if !supportLists]>14. <![endif]>= Where capital expenditure is required, what are likely to be the main items, e.g. clean/dirty water separation, upgrading of storage facilities, new storage facilities? What scale of investment might be required?<o:p></o:p> <o:p> </o:p> Dirty water separation and covering of slurry stores are the most basic necessities. Many slurry stores, sheep dipping facilities and farm buildings especially in the hills and uplands are old a= nd inadequate. Low farm incomes mean there has been little investment. Scale of investment could be assessed by comparing with the rate of grant aid for fa= rm buildings under Farming Connect – before it was stopped!<o:p></o:p></= span> <o:p> </o:p> <![if !supportLists]>15. <![endif]>= What are the possible implications for farms that straddle the NVZ boundaries (or have discrete parcels of land bo= th within and outside of NVZ areas), bearing in min= d that good agricultural practice should be maintained on land that is not in an N= VZ area?<o:p></o:p> <o:p>&nb= sp;</o:p> It is important farmers are supported to manage their en= tire holding sensitively, or in the longer term, risk extension of NVZ areas.<o:= p></o:p> <o:p>&nb= sp;</o:p> <![if !supportLists]= >16. <![endif]>= In order= to comply with the proposed changes, what length of transitional period would = be appropriate (assuming that some flexibility is possible)?<o:p></o:p>= <o:p>&nb= sp;</o:p> Transition time will depend on support given, both advisory and capital. The priority should be on assisting with understanding of nutrient cycling, and benefits to productivity and profitability from appropriate management.<o:p></o:p> <o:p> </o:p> <o:p> </o:p> General comment<o:p></o:p>= Our further important point relates to the requirement = for record keeping. Given the imperative to reduce bureaucracy, requiring farmers to keep field records w= hich are not then used by either the farmer or the Environment Agency to monitor compliance or understand changes in nutrient loading, seems a wasted opportunity. Unlike <st1:place w:st=3D"on"><st1:country-region w:st=3D"on">England</st1:country-region></s= t1:place>, we are dealing with very small area and number of holdings. It should there= fore be possible to very efficiently and effective target support (technical and capital) to those affected farms/ farmers.<o:p></o:p> For farmers familiar with IT, on-line record forms which calculate loadings, demands, risk factors (by including weather or climate data) and collate information will enable farmers to recognise the impacts = of management changes: it would also enable the follow up of pollution inciden= ts or changes in nutrient levels. </spa= n><o:p></o:p> This experience could be used to pilot support and advi= ce networks, with feedback from monitoring results, to create a real partnersh= ip between farmers, the Welsh Assembly Government and the Environment Agency w= hich could be expanded in future years.<o:p></o:p> <o:p> </o:p> <o:p> </o:p> <o:p> </o:p> </div> </body> </html>

MIME-Version: 1.0 Content-Location: file:///C:/2D3946C5/OrganicNVZresponse.htm Content-Transfer-Encoding: quoted-printable Content-Type: text/html; charset="us-ascii" Response on behalf of the Agri-Partnership Organic Strategy Group</t= itle> <o:SmartTagType namespaceuri=3D"urn:schemas-microsoft-com:office:smarttags" name=3D"PostalCode"/> <o:SmartTagType namespaceuri=3D"urn:schemas-microsoft-com:office:smarttags" name=3D"PlaceType"/> <o:SmartTagType namespaceuri=3D"urn:schemas-microsoft-com:office:smarttags" name=3D"PlaceName"/> <o:SmartTagType namespaceuri=3D"urn:schemas-microsoft-com:office:smarttags" name=3D"City"/> <o:SmartTagType namespaceuri=3D"urn:schemas-microsoft-com:office:smarttags" name=3D"country-region"/> <o:SmartTagType namespaceuri=3D"urn:schemas-microsoft-com:office:smarttags" name=3D"place"/>  <style>  </style>  </head> <body lang=3DEN-GB link=3Dblue vlink=3Dpurple style=3D'tab-interval:36.0pt'> <div class=3DSection1> <o:p> </o:p> <h3 align=3Dcenter style=3D'margin-top:0cm;text-align:center'>Response from the Welsh Agri-food Partnership Organic Strategy Group prepared by Organic Centre <st1:country-region w:st=3D"on">Wales</st1:country-region= >, <st1:PlaceName w:st=3D"on">Aberystwyth</st1:PlaceName> <st1:PlaceType w:st=3D"on">Universi= ty</st1:PlaceType>, <st1:place w:st=3D"on"><st1:City w:st=3D"on">Aberystwyth</st1:City>, <st1:P= ostalCode w:st=3D"on">SY23 3AL</st1:PostalCode></st1:place><o:p></o:p></b= ></h3> <h3 align=3Dcenter style=3D'margin-top:0cm;text-align:center'>to the Welsh Assembly Government consultation on: <o:p></o:p></h3> <h3 align=3Dcenter style=3D'text-align:center'>The Protection of Waters against Pollution from Agriculture.<o:p= ></o:p></h3> <a href=3D"http://new.wales.gov.uk/consultations/currentconsultation/envandcou= ncurrcons/220807-141107nitrate/?lang=3Den">http://new.wales.gov.uk/consulta= tions/currentconsultation/envandcouncurrcons/220807-141107nitrate/?lang=3De= n</a> <o:p></o:p> <h3>Background<o:p></o:p></h3> The Organic Strategy Group was formed in March 1999, one= of the four strategy groups and four regional groups then forming the Welsh Agri-Food Partnership, which are responsible for steering the implementatio= n of the sector plans for Wales.<o:p></o:p> Since its formation one of the primary roles of the Orga= nic Strategy Group has been the implementation of the first and second Welsh Organic Action Plans published in March 1999 and July 2005 respectively.<o:= p></o:p> Organic Centre Wales (OCW) was established in 2000 with funding from the Welsh Assembly Government as a focal point for the dissemination of information on organic food and farming to producers and o= ther interested parties in <st1:country-region w:st=3D"on"><st1:place w:st=3D"on= ">Wales</st1:place></st1:country-region>. In 2003, the remit was extended to include public education, public procurement, policy and strategy development.<sp= an style=3D'mso-spacerun:yes'> OCW is based at <st1:PlaceName w:s= t=3D"on">Aberystwyth</st1:PlaceName> <st1:PlaceType w:st=3D"on">University</st1:PlaceType>, and run by a partner= ship of four organizations actively involved in organic farming research and knowledge transfer in <st1:country-region w:st=3D"on">Wales</st1:country-re= gion>: ADAS, The Organic Research Centre Elm Farm, the <st1:PlaceType w:st=3D"on">= Institute</st1:PlaceType> of <st1:PlaceName w:st=3D"on">Grassland</st1:PlaceName> and Environmental Research (IGER), and the <st1:place w:st=3D"on"><st1:PlaceType w:st=3D"on">= Institute</st1:PlaceType> of <st1:PlaceName w:st=3D"on">Rural Sciences</st1:PlaceName></st1:place> at Aberystwyth University (IRS).<o:p></o:p> <h3>Response<o:p></o:p></h3> <o:p>= </o:p> <![if !supportLists]>1. <![endif]>= Do you agree with the Welsh Assembly Government assessment that there should continue to be a targeted approach to NVZ designation in <st1:country-region w:st=3D"on"><st1:place w:st=3D"on">Wales= </st1:place></st1:country-region>?<o:p></o:p> <o:p>= </o:p> Yes<o= :p></o:p> <o:p> </o:p> <![if !supportLists]>2. <![endif]>= Do you h= ave comments on the areas proposed for designation as NVZs in Wales shown on the indicative map (at Annex B) given the Nitrates Directive's basis on which nitrate polluted waters must be identified and land draining into those wat= ers must subsequently be designated?<o:p></o:p> <o:p> </o:p> The data gathering seems to have been comprehensive and = the basis of identification appropriate. These areas include where intensive agriculture can be practiced therefore N application could exceed 170kg N/ha.<o:p></o:p> <o:p> </o:p> <o:p> </o:p> <![if !supportLists]>3. </spa= n><![endif]>How would the practical management of typical livestock and arable enterprises = need to change in order to achieve compliance with the proposed changes to the different aspects of NVZ regulations?<o:p></o:p> <o:p> </o:p> <o:p> </o:p> Most organic enterprises would not need to change. For other farmers the greatest nee= d for change is in record keeping, manure and slurry management and awareness of = and calculation of nitrogen balances. For far= mers with a higher stocking rate (>2LSU/ha) there would have to be a stock reduction or arrangements for excess manures/slurry to be spread outside the NVZ. <o:p></o:p> <o:p> </o:p> The NVZ area could be an opportunity to encourage non organic farmers to convert to organic methods to address these problems = 211; Ideally OCW could support specifically target events at NVZ farmers as described below, informing them of the Organic Conversion Information Servi= ce. Farming Connect Whole Farm plans could help to plan/ implement changes.<o:p= ></o:p> <o:p> </o:p> EOR approach is valuable so that farmers can have an assessment of their current management and proposals for improvement where necessary. Winter housing arrangements, management of dirty water, capacity= of slurry tanks / lagoons are important in a changed climate with high rainfall patterns that can overwhelm existing systems.<o:p></o:p> <o:p> </o:p> <o:p> </o:p> <![if !supportLists]>4. </spa= n><![endif]>What do consultees see as being the m= ain trends in farming within NVZ areas? How will the revised Action Programme impact on these?<o:p></o:p> <o:p> </o:p> Organically farmed areas in <st1:place w:st=3D"on"><st1:country-region w:st=3D"on">Wales</st1:country-region></st1= :place> are currently increasing by around 10% each year, and it is likely these changes are occurring in the NVZ areas.&nb= sp; Conversion to organic management and access to the Organic Farming Agri-environment scheme will offer guidance and financial support to farmer= s to enable the achievement of the action plan.<o:p></o:p> <o:p> </o:p> Impact of SFP may be some stock reductions in marginal areas and more intensive stocking in more favoured areas. Conversion to organic farming could see some change in sheep:cattle ratios on liv= estock farms, and - encouraged by Tir Gofal, cost of bought-in feed - more arable cropping where conditions allow.<o:p></o:p> <o:p> </o:p> <o:p> </o:p> <o:p> </o:p> <![if !supportLists]>5. </spa= n><![endif]>On some farms in NVZ areas soils will need to be categorised into “sandy or shallow”, and “clayey/loamy”. What difficulties, if any, have farmers had with identifying soil type under the current Action Programme? <o:p></o:p></span= > <o:p> </o:p> Generally farmers can describe their = soil types, but we can not speak to the accuracy of their assessment. <o:p></o:p= > <o:p> </o:p> What training or guidance would be required by farmers to enable them = to make this distinction between soil categories?<o:p></o:p> <o:p> </o:p> During group training sessions on the implications of the NVZ designation, soil maps should be used to indicate t= he expected soil categories in the area in question and a soils specialist sho= uld be on hand to answer questions. Farmers could be invited to bring small bags of soil from fields they are unsure of. Simple soil assessment methods could be introduced such as t= he use of ‘soil balls’. </s= pan><o:p></o:p> <o:p> </o:p> <o:p> </o:p> <![if !supportLists]>6. <![endif]>= Are ther= e any further exemptions to the closed periods that would give farmers flexibility while ensuring that there is no nitrate run-off to watercourses?<o:p></o:p>= <o:p> </o:p> We have concerns over the use of clos= ed periods, as weather is increasingly unpredictable, and some winter temperat= ures allow grass growth and therefore take-up of nutrients, whereas at other tim= es rainfall and cold could present high risks. As farmers are required to underta= ke a field inspection to consider the risk of runoff prior to spreading, and giv= en the requirement listed under 6.5.3, the closed periods seem somewhat artificial. Please also see n= ote to question 12.<o:p></o:p> <o:p> </o:p> <![if !supportLists]>7. </spa= n><![endif]>To what extent will farms be able to satisfy the storage requirements?<o:p></o:p> <o:p> </o:p> If our interpretation that storage is required for the likely production under the current farming practice (i.e.= if extended grazing is practiced, storage for 22 weeks’ production of sl= urry from all livestock is not expected.) Some element of risk assessment will be necessary for exceptional weather conditions. <o:p></o:= p> It is likely there will be problems f= or some farmers. Hopefully EORs = can be used to give an indication of the situation.<o:p></o:p> There should also be increased emphas= is on appropriate stocking rates (if you have limited facilitates, keep less stock) – again assessed as part of Whole Farm Plans under Farming Connect.<o:p></o:p> <o:p> </o:p> <![if !supportLists]>8. <![endif]>= How impo= rtant would it be for the Welsh Assembly Government to pursue with the European Commission the possibility of a derogation to the 170kg/ha/annum Nitrogen loading limit?<o:p></o:p> <o:p> </o:p> We are unsure. It should be possible to meet the = limit in most situations. –farmers could learn from organic systems that operate within these limits.<o:p></o:p> <o:p> </o:p> <![if !supportLists]>9. </spa= n><![endif]>The Nitrates Directive does not explicitly require cover crops to be included in the Action Programme. Howe= ver, it is considered that the evidence indicates that they are a cost-effective method for tackling diffuse water pollution. Views about their inclusion in= the Action Programme would be welcomed.<o:p></o:p> <o:p> </o:p> A recommendation for use of cover cro= ps and explanation of their benefits (including preventing soil erosion) will = be helpful, but it would not be practical to oblige their use, as conditions w= hich may prevent their establishment often overtake the best laid plans. <o:p></= o:p> <o:p> </o:p> Information on the use of different c= over crops would need to be explained, and the difference between N fixers and N lifters. Also the suitability of different crops in different weather regio= ns.<o:p></o:p> <o:p> </o:p> <o:p> </o:p> <o:p> </o:p> <![if !supportLists]= >10. <![endif]>= The NVZ Management Plan template that will be issued by the Welsh Assembly Government will provide a step-by-step guide to help farmers make the necessary calculations on which to base decisions regarding compliance with the revised Action Programme measures. = What further guidance and training could be usefully provided to help farmers in= NVZ areas to make the best decisions both for compliance with Action Programme measures and for their businesses? When and where would such training/guida= nce be best delivered?<o:p></o:p> <o:p> </o:p> Workshops should be held introducing farmers to their new obligations, and they should be assisted with the calculations. An on-line calc= ulator which enables results and input figures to be printed would be most helpful. Generally, our feeling is that when farmers understand the benefits of nutr= ient conservation, they will aim to benefit from support offered and to comply w= ith the requirements.<o:p></o:p> <o:p> </o:p> Incorporate in to FC whole farm management plans<o:p></o:p> <o:p> </o:p> <![if !supportLists]= >11. <![endif]>= To what extent would consultees wish to (or be able to) assist the Wel= sh Assembly Government with developing the NVZ Management Plan template?<o:p></o:p> <o:p>&nb= sp;</o:p> We are strong supporters of integra= ted management plans and would be happy to assist with developing the template, using experience from nutrient planning for organic farms.<o:p></o:p></span= > <o:p>&nb= sp;</o:p> <![if !supportLists]= >12. <![endif]>= Are ther= e any improvements that consultees would like to see in the current Field Record Sheets (Annexes 6 & 7 of “Guidelines for farmers in NVZs”)?= <o:p></o:p> <o:p> </o:p> The record sheet seems to have little use, given there is no encouragement for summing applications, noting applications from grazing, or calculating nutrient off-take from crops. An audit of farm records would ass= ist the farmer in identifying the most efficient way of keeping the necessary records and help the records to be of use in farm management.<o:p></o:p></s= pan> <o:p> </o:p> <![if !supportLists]>13. <![endif]>= What mechanisms could be put in place= to support farms that produce a surplus of manure/slurry? For instance an initiative to link arable holdings that have straw as a by-product, but req= uire manure/slurry, with livestock farms that need to export manure/slurry but w= hich require straw.<o:p></o:p> <o:p> </o:p> An initiative such as this may be use= ful but transport of fresh manures or slurry is expensive and energy demanding. Working with= the farmer to identify appropriate stocking rates for the land through Whole Fa= rm Plans including nutrient balances would be helpful.<o:p></o:p> <o:p> </o:p> <![if !supportLists]>14. <![endif]>= Where capital expenditure is required, what are likely to be the main items, e.g. clean/dirty water separation, upgrading of storage facilities, new storage facilities? What scale of investment might be required?<o:p></o:p> <o:p> </o:p> Dirty water separation and covering of slurry stores are the most basic necessities. Many slurry stores, sheep dipping facilities and farm buildings especially in the hills and uplands are old a= nd inadequate. Low farm incomes mean there has been little investment. Scale of investment could be assessed by comparing with the rate of grant aid for fa= rm buildings under Farming Connect – before it was stopped!<o:p></o:p></= span> <o:p> </o:p> <![if !supportLists]>15. <![endif]>= What are the possible implications for farms that straddle the NVZ boundaries (or have discrete parcels of land bo= th within and outside of NVZ areas), bearing in min= d that good agricultural practice should be maintained on land that is not in an N= VZ area?<o:p></o:p> <o:p>&nb= sp;</o:p> It is important farmers are supported to manage their en= tire holding sensitively, or in the longer term, risk extension of NVZ areas.<o:= p></o:p> <o:p>&nb= sp;</o:p> <![if !supportLists]= >16. <![endif]>= In order= to comply with the proposed changes, what length of transitional period would = be appropriate (assuming that some flexibility is possible)?<o:p></o:p>= <o:p>&nb= sp;</o:p> Transition time will depend on support given, both advisory and capital. The priority should be on assisting with understanding of nutrient cycling, and benefits to productivity and profitability from appropriate management.<o:p></o:p> <o:p> </o:p> <o:p> </o:p> General comment<o:p></o:p>= Our further important point relates to the requirement = for record keeping. Given the imperative to reduce bureaucracy, requiring farmers to keep field records w= hich are not then used by either the farmer or the Environment Agency to monitor compliance or understand changes in nutrient loading, seems a wasted opportunity. Unlike <st1:place w:st=3D"on"><st1:country-region w:st=3D"on">England</st1:country-region></s= t1:place>, we are dealing with very small area and number of holdings. It should there= fore be possible to very efficiently and effective target support (technical and capital) to those affected farms/ farmers.<o:p></o:p> For farmers familiar with IT, on-line record forms which calculate loadings, demands, risk factors (by including weather or climate data) and collate information will enable farmers to recognise the impacts = of management changes: it would also enable the follow up of pollution inciden= ts or changes in nutrient levels. </spa= n><o:p></o:p> This experience could be used to pilot support and advi= ce networks, with feedback from monitoring results, to create a real partnersh= ip between farmers, the Welsh Assembly Government and the Environment Agency w= hich could be expanded in future years.<o:p></o:p> <o:p> </o:p> <o:p> </o:p> <o:p> </o:p> </div> </body> </html>