Proposed Nitrates Action Programme Regulations (NI) 2014
Ulster Angling Federation
Proposed Nitrates Action Programme Regulations (NI) 2014 and Revisions to Associated Regulations
5/08/2014
Abbreviations used in the text:
UAF Ulster Angling Federation
NGO Non Government Organisation
WFD Water Framework Directive
UK United Kingdom
DARD Department of Agriculture & Rural Development
DCAL Department of Culture Arts & Leisure
GFG Going for Growth
The Ulster Angling Federation is the representative body for game angling associations in Northern Ireland. We have a membership of some 60 associations with a total individual membership of some 7,000 anglers. The Federation represents anglers in discussions with Public Bodies, Government and other NGO’s and has been in existence since 1930. We are represented on a wide range of committees to ensure the concerns of anglers are heard.
Our member Angling Associations are very concerned about the effects of nitrates on rivers and lakes, as in the past nitrates have proved to be detrimental to the river and lake environment generally and to fisheries in particular.
It is important that the natural integrity of rivers is protected to allow continuation of the natural ecology of the stream, and to allow existing fish populations to prosper.
The Pricewaterhouse Coopers Report of July 2007 for DCAL on the social and economic value of angling in NI, states that all forms of angling in NI support some 780 full time equivalent jobs, and are worth some £40m p.a. to the NI economy, mostly from game angling. If this jobs/economic benefit is to maintained and enhanced, the provision of good water quality and satisfactory fish stocks are absolutely vital for our fisheries and tourism. The following comments are made in that light.
Background
The aim of the EU Nitrates Directive (91/676/EEC) (the Directive) is to improve water
quality by reducing water pollution caused or induced by nitrates from agricultural sources and preventing further such pollution. In particular, a key objective is to promote better management of animal manures, manufactured fertilisers and other nitrogen-containing materials spread onto land. The Directive requires EU Member States to set out action programmes to reduce nitrates from agricultural sources entering the aquatic environment and address both high nitrate levels in surface and ground waters and eutrophication in surface waters. The Directive allows Member States to either designate discrete areas of land as Nitrate Vulnerable Zones (NVZs) or establish an action programme to be applicable to the whole territory.
In Northern Ireland, following extensive consultation in 2004 and 2005, the total territory
approach was adopted to establish Northern Ireland as an area to which an action
programme should be applied. This approach was supported by a scientific report, which
identified eutrophication as the major pollution problem throughout Northern Ireland’s
water environment and highlighted the extent of the agricultural contribution to the
problem. On 1 January 2007 the Nitrates Action Programme Regulations (Northern Ireland) 2006 5 (the 2006 NAP Regulations) came into operation. The action programme established closed periods for the application of organic and inorganic fertilisers, a livestock manure application limit to land of 170kg nitrogen/ha/year and the requirement for sufficient slurry storage capacity on farms; with the aim of providing greater protection for surface waters and ground waters in Northern Ireland.
Progress to Date
The UAF is keen to secure environmental protection that can go hand in hand with sustainable agriculture where a stronger decoupled market can flourish. We are keen to support a programme of measures that seeks to minimise the financial burden imposed on farmers whilst securing good water quality and delivering biodiversity objectives. The UAF is therefore broadly supportive of the measures suggested in the consultation. We would however make some specific comments on the progress to date.
Despite what has been recorded in the consultation that “nitrates levels remain static or are reducing” the facts are that only 22% of rivers and lakes in Northern Ireland are of sufficient quality to meet Good Ecological Status as defined in the Water Framework Directive (WFD), and also only 28% of water bodies to be restored to Good Ecological Status out of a target of 55% exist. Much more remains to be done to comply with the WFD.
Whilst the introduction of the Nitrates Directive was welcomed it appears this alone will not resolve the problems associated with our waterways. In fact this was highlighted by the Stormont Audit Committee in 2013 when it advised that the Nitrates Directive would be insufficient to restore our waters to Good Ecological Status by 2015 and called for additional measures to be introduced. This plea has virtually been ignored by Government as to date no real additional measures have been introduced.
Additional Measures
1. Incidents of pollution of the environment in Northern Ireland are not treated with the seriousness they deserve.
2. Northern Ireland is the only area of the UK without an independent environmental protection agency. Given the lack of progress by the various different Departments consideration should be given for this to be established.
3. The above measure would also address the issue of so many different Government Departments (NIEA, DARD, Rivers Agency and DCAL) having input for water quality etc.
4. A programme of education which will support farmers to ensure they are compliant with the Directive
5. As part of the new NAP regulations buffer strips should be introduced across the province this will create a win win situation as it will establish a boundary for spreading, create a natural corridor for wildlife and help stop pollution reaching a watercourse.
6. Originally during the last consultation the UAF supported the proposal to end the practice of field storage of poultry litter. We shared the Commission’s concern that the storage of poultry litter in fields provides a concentrated source of nutrients which are prone to leaching and thus present a significant risk to water quality. The Federation is concerned however that the agriculture industry has not yet progressed a solution for poultry litter. The proposal to cover field litter with a plastic membrane is not always practicable or suitable. The continued failure to develop a solution to the problem of poultry litter is therefore likely to result in significant fines from the European to the Northern Ireland Executive (which would ultimately come from the public purse) as well as heavy environmental price through damage caused to local water quality from enriched phosphorous status of local soils.
The environmental impact of the “Going for Growth” plan and potential mitigation
Measures.
The UAF like the Commission have concerns about possible environmental impacts of
expansion in some agricultural sectors, particularly in relation to manure management,
nutrient loading on farms and protection of the improvements in water quality.
The Commission has highlighted that they wish to see measures included in the NAP to
mitigate against potential increases in nutrient loading and associated problems with
manure management and risks to water quality. The Commission has also drawn
attention to a deficiency in the information available on manure exports and imports by
farms, both within Northern Ireland and cross-border and the drawbacks associated with
this, in terms of identifying farms with high nutrient loadings and adequately accounting for the end-use of different manures.
In response to the Commission’s concerns, the 18 Departments will include a reference to the Going for Growth Strategy within the new NAP and are consulting on revision of record keeping controls on the export and import of organic manures and a requirement for organic manures which contain a high proportion of P relative to N to be applied within a crop P requirement limit.
Furthermore, to support the measures within the NAP, in co-ordination with authorities in
Ireland (the Department of Agriculture, Food and the Marine), the Departments are taking steps to ensure that cross-border imports and exports of livestock (and other organic) manures are properly recorded and comply with both veterinary and NAP requirements.
The Minister for Agriculture and Rural Development and the Minister for Enterprise, Trade and Investment have circulated proposals to Northern Ireland Executive Ministers on the way forward on the GFG report. These include a plan identifying action needed,
responsibilities and timeframes for delivery on agreed objectives within Going for Growth.
These proposals have still to be considered by the Executive. Any agreed actions will
require assessment of their potential environmental impact. The Departments wish to highlight that, if potential environmental impacts from the Going for Growth strategy are identified which would lead to consequences for the implementation of NAP, or threats to improvements in water quality, amendments to the 2015-2018 NAP may be required, in order to mitigate against such impacts. If as highlighted the Commission wish to see measures included in the NAP, surely these measures need identified and included in this consultation now so we know what is being proposed before any additional damage is done?
R F Marshall
Development Officer
Ulster Angling Federation
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