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Recommendations to the Government on Nutrient Management

In May 2024, the day before the Election was called, Defra published the report they had commissioned from a Nutrient Management Expert Group (NMEG) which sets out recommendations on the optimal policy approach to reduce pollution from nutrients in agriculture. It should be noted, some content surrounding fertiliser prices and ELM policy development is out of date because the report publication was delayed by two years.


Through the Clean Air Strategy 2019, the previous government committed to setting up an expert group of agricultural policy experts, agronomists, scientists and economists to make recommendations on the optimal policy strategy to minimise pollution from fertiliser use. The remit of the group widened as the systemic nature of nitrogen pollution was recognised - meaning one form of nitrogen pollution cannot be managed in isolation of the rest. Consequently, the report covers air quality, water quality, soil health, the circular economy and climate change.


Nitrogen is a nutrient required for crop growth. Excessive use of nitrogen in farming systems, whether conventional or organic, pollutes surrounding environments as well as those further afield. It contributes to global warming as nitrous oxide, while deteriorating water quality is driven by excess nutrients in water systems and nitrogen in the air causes biodiversity loss in sensitive habitats and damages human health as air pollution and ozone layer depletion. As such, this blog pulls out relevant recommendations from the NMEG report with comments and suggestions relating to the Alliance’s policy recommendations.


A Beef herd at Belmont Estate


The NMEG report primarily calls for a long-term, coordinated and strategic approach to nutrient management with continual monitoring and adaptation. Introducing a comprehensive approach will avoid perverse or unintended side-effects, such as pollution swapping between water and air. The report also specifies that the extent of change required spans food production, supply and consumption.


Air quality

Improved nutrient management in food production will require more ambitious interpretations of best practice, more effective application of nutrients by increasing N use efficiency and achieving N balance on farms while reducing nutrient loads. Accompanied by independent on-farm advice through public and private collaboration, proper implementation of nutrient management planning will be central to achieving better outcomes, which the report recommends should be linked to new, ecologically meaningful targets.


While proper enforcement of regulation is important, the report notes that it will only be effective when rolled out together with a comprehensive package of supporting measures, including training, targeted advice, and support for peer-to-peer learning and knowledge exchange network - all of which would need to be properly resourced and funded.


Further mitigations to reduce impacts on air quality include reform of planning rules to spatially target limits on nutrient intensity of particular farming systems, for example using nitrogen budgets, in areas within a certain radius of sensitive sites. The Alliance suggests the government introduces a spatially-scaled nitrogen balance sheet to inform the spatial target limits, building on the Alliance’s UK Nitrogen Balance Sheet work and on Defra’s Nitrogen Futures projects. Intensive livestock units should also be limited in areas near to sensitive habitats, as the waste produced is likely to be spread in nearby areas, contributing to nitrogen pollution even if the units are outside of the nutrient neutrality zoning.


Many high risk agricultural actions are not currently included as ‘plans or projects’ for which planning permission or an environmental assessment is required. A reformed planning policy should include these as required for activities which cause environmental damage.


Water quality

At the time of writing the NMEG report, environmental permitting was being extended to beef and dairy. The SNA supports the re-introduction of this policy with landscape-level budgeting to ensure the cumulative contribution of smaller farms to environmental pollution is accounted for.


Private funding from the water sector could provide a crucial contribution to assisting farmers in implementing technological solutions and infrastructure to reduce water pollution. However, current regulations prohibit funds from supporting an actor in reducing pollution when there are regulations in place to do the same. The regulations in place in this case are the Farming Rules for Water (FRfW) which are widely recognised as not being enforced properly. The government should support farmers in accessing this funding from water companies to invest in appropriate infrastructure to mitigate pollution while ramping up enforcement of the FRfW.

The report also notes that there are downsides to nutrient management approaches such as closed application seasons, where manure application is prohibited in winter to reduce leaching to waterways (pollution peaks either side), despite being easier to police. Increasing storage capacity through the Farming Investment Fund is helpful, so long as it doesn’t lock farmers into an economically and environmentally unsustainable production system. The report goes on to suggest that grants and loans for improving slurry storage could be made subject to conditions specifying nutrient commitments, for example, the maximum allowable nutrient loading limits for the land on which the slurry will be spread. Farm level and landscape level nitrogen budgets would enable the calculation of the contribution to the wider catchment to ensure loading limits did not surpass the level that a catchment could ecologically manage.


Soil health

The NMEG report comments that crop residues return organic matter to the soil but are at risk of increasing nitrous oxide emissions, particularly green residues, which also release carbon dioxide emissions when ploughed in. However, grazing off cover crops is an opportunity that the report does not include. Various agroecological practices are promoted, such as intercropping with legumes and the use of legumes as herbal leys provide benefits to soil health. The report calls for a reduction of inorganic inputs as part of balancing a farm budget and an increase in soil organic matter which could help stabilise yields in the face of climate change. Systems such as organic or regenerative, can provide fertilisation through nitrogen-fixing plants, while building up SOM and offering environmental and climate benefits.


The report flags research gaps on nutrient uptake in organic compounds and on soil organic matter with policy needing to account for this uncertainty. The Alliance recommends research focuses on identifying the optimum level and timing of nitrogen provided through organic versus inorganic fertiliser when using a combined approach to ensure greater financial security and climate resilience for farmers as well as the government when paying for these practices through ELMs. For example, if herbal leys perform better without addition of synthetic fertilisers, farmers should not receive ELMs payments if they are using synthetic nitrogen in tandem. Further research is needed on the role of soil biology in securing crop productivity and how chemicals and fertiliser impact this, singly and in combination. Finally, the narrative that systems using non-synthetic nitrogen produce lower average yields must be tested to fill evidence gaps in the timeframe that yield drops are expected to last and what practices can be used to mitigate this. Identifying the validity of the narrative would enable the government to set a nitrogen reduction strategy in combination with an organic fertiliser strategy to encourage provision of natural fertility to reduce environmental impacts or increase nutrient recycling.


The proposed Soil Health Action Plan for England (SHAPE) was dropped by Defra after the NMEG report was commissioned. The Alliance advocates that the new government should develop a SHAPE and address NMEG’s suggestion of incorporating nutrient management plans into regulation, building from what’s in the FRfW and the Nitrate Regulations.


A field of wheat at Helen Browning's Organic, Eastbrook Farm


Circular economy

Globally, nitrogen use efficiency is low. The NMEG report suggests that fertiliser products should be required to have low embedded environmental impacts, in the absence of a non-environmentally damaging fertiliser, and follow the 4R approach (applied in the right place, at the right amount, at the right time and in the right form).

The strengths and weaknesses of anaerobic digestion (AD) and compost are compared. AD maximises nutrient recovery but presents greater applications risks of losses, such as ammonia and nitrous oxide emissions, and in some cases, pollution of nearby waterways. Composting involves nutrient losses but much lower risk around application. The report suggests regulatory frameworks should focus on nutrient recovery and quality assurance of the recovered nutrient products. This puts more weight behind the benefits of nutrient recovery than the risks of nutrient losses. AD already represents a large contribution to ammonia emissions in the UK, although due to an accounting tactic this is not included in emission reporting. The government must not undervalue the impact of pollution from AD, as well as the ability to prop up the intensive livestock industry by providing an opportunity to pay the polluter.


Climate change

Carbon auditing is identified as a useful approach to evaluate farm-based actions to improve the farm-gate greenhouse gas balance. The report recommends that the government set standards for audit toolkits to ensure consistency among providers. Also, to meet the Net Zero target, the government must promote more efficient nutrient use and management by “embedding the principles of reduced GHG emissions and increased carbon storage and sequestration into the mix of policy instruments”.


The report identifies options to improve nutrient use efficiency, such as nitrification inhibitors, replacing synthetic fertiliser with legumes or manure and the optimal timing and rates of fertiliser and manure applications which match the plants’ needs and conditions. But, the report falls short of calling for a synthetic nitrogen fertiliser use reduction strategy which would certainly reduce climate emissions, alongside embedding the principles of nutrient recycling and the treatment of organic manure as a resource rather than as waste.

Raising the regulatory baseline for nutrient management standards is recommended as it would provide benefits towards water quality and towards Net Zero. While nutrient management plans are currently a requirement of the Farming Rules for Water, as discussed earlier, these are rarely enforced and so compliance is low. Instead of the equivalent being included as an option in the Environment Land Management scheme (ELMs), an opportunity for this would be the introduction of a baseline regulatory requirement to be met in order to receive ELMs funding.


Much of the carbon reductions in the 6th carbon budget are driven by action towards diet change and food waste yet the NMEG report only notes this importance with no recommendations towards how this may be implemented. The SNA recommends that the government gives consideration to this issue.


Conclusion

The SNA advocates that the new government should pick up the opportunity presented by implementing the recommendations in the NMEG report to meet multiple targets during their time in power. The NMEG report highlights the opportunities of taking a system-wide approach to reducing nitrogen pollution in the co-benefits achieved from an integrated approach to policy. Taking action on nitrogen is key to cleaning up rivers, meeting climate goals, reducing air pollution and improving nature and biodiversity, and the first steps to doing so are laid out in this report.



Shropshire sheep in an agroforestry system, Broome Farm

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