Articles
These short pieces of topical information are written as an update on the latest cross compliance regulations and cover topics that are of particular interest or concern to farmers over the relevant periods. The topics are based on calls coming through the cross compliance helpline as well as through subjects covered at locally organised events.
Farmers are advised to read them in conjunction with the cross compliance scheme handbooks and updates. The information comes as part of the Cross Compliance programme run by Momenta on behalf of Defra and Natural England. For further help or information farmers should telephone the helpline for free and confidential advice on 0845 345 1302.
Topics
Electronic identification should bring benefits, farmers told (July 2009)
Storage of cereals post harvest: don’t forget cross compliance feed and food safety (July 2009)
Farmers reminded about avoiding animal welfare problems under cross compliance (June 2009)
Whole Farm Approach provides real benefits for cross compliance, farmers told (June 2009)
Think ‘soils’ when farming (May 2009)
NVZ records: important deadline fast approaching (May 2009)
Livestock identification and record keeping (April 2009)
Wild birds and habitats - changes to GAEC and SMR (April 2009)
Farmers views wanted on changes to cross compliance (April 2009)
NVZs: have you assessed your storage need? (March 2009)
End of the shooting season and wild bird cover (March 2009)
Managament of uncultivated land and environmental impact assessments (January 2009)
Feed and food safety (January 2009)
NVZ farm nitrogen limits (January 2009)
The NVZ N-max calculation (December 2008)
Wild bird cover and cross compliance (December 2008)
Calf welfare (December 2008)
NVZ manure spreading closed periods (December 2008)
Animal welfare for out-wintered livestock (December 2008)
Use of sewage sludge (December 2008)
Cross compliance and the protection of water (November 2008)
Groundwater regulations (November 2008)
Nitrate Vulnerable Zones (November 2008)
Use of plant protection products (November 2008)
The new NVZ regulations (October 2008)
Repairing the damage after harvesting under waterlogged conditions (October 2008)
Restoring cross field footpaths (October 2008)
Heather and Grass Burning (October 2008)
Keep soil records up-to-date following run-off (June 2008)
Weed control in the protection zone (June 2008)
No action required on game cover amendment (June 2008)
Animal welfare at lambing (April 2008)
Cattle Identification and Movements (April 2008)
Control of weeds (April 2008)
Controlling weeds in challenging areas (April 2008)
Keeping the nutrients, keeping the money (March 2008)
Care of SSSIs (March 2008)
Spraying Safe (March 2008)
Managing and Cutting Hedgerows (March 2008)
Keeping Poultry Protected (February 2008)
Keeping Cross Compliant during Spring Cropping (February 2008)
Keeping Up to Date – Changes to Cross Compliance in 2008 (February 2008)
Supplementary Feeding in Difficult Times (November 2007)
Would your chemical store pass an inspection? (November 2007)
To cultivate or not to cultivate? (November 2007)
Hedgerows (October 2007)
The Importance of Animal Records (October 2007)
The Set-aside Challenge (October 2007)
Post harvest management – preparation of land (September 2007)
Food and Feed Law (September 2007)
Spring 2010
Soil Protection Review takes a more practical approach - Farmers Weekly 15 April
Cattle ID: Know the rules or face SFP cuts - Farmers Weekly 9 March
Winter 2010
Allowing access to waterlogged soils would offer flexibility - Farmers Weekly 12 January
Autumn 2009
NVZ grassland derogation – an option for holdings with high stocking rates
Intensive livestock farmers will be able to operate at a higher stocking densities without breaching NVZ rules next year by applying to the EA for a derogation, according to Momenta advisors, acting on behalf of Natural England to deliver Cross Compliance across England.
The derogation, anticipated to be pass through parliament in December or January 2010, allows eligible land to receive a higher maximum total organic manure load (250kgN/ha) compared to the normal 170kgN/ha, albeit subject to additional requirements, explains adviser Momenta Simon Draper.
“Arguably, intensive grassland can better use higher nitrogen levels and presents a relatively low leaching risk but additional control measures should be followed including nutrient planning, soil phosphate monitoring along with restrictions to rotation and cropping. Farmers will also need to meet clear eligibility criteria,” he says.
In contrast to 2009, farmers will need to maintain 80% of their rotation as grassland (containing less than 50 per cent clover) as of next year to qualify for the derogation.
Usefully however, crops that are under-sown with grass can be used to make up the 80%. Mr Draper points to spring barley as the obvious option if a farmer has concerns about meeting the higher grassland area while advising dairy farmers against under-sowing maize. “The chances are that the grass won’t take and leave you short on grass acreage while a late harvest would result in rutted compacted fields, far from ideal for a productive long term ley.”
Mr Draper points out that, other restrictions specified by the derogation represent good practice with a requirement for fields to be sampled for P every four years and fertiliser or nutrient management plans to be produced, all of which help target nutrient effectively and so minimise expenditure on bagged fertiliser.
Mr Draper points out that, other restrictions specified by the derogation represent good practice with soil P sampling required every four years and production oof fertiliser or nutrient management plans, all of which help target nutrient effectively and so minimise expenditure on bagged fertiliser.
“The plan should show how much N and P is needed by the crop, how much is applied as bagged fertiliser or manure and when it needs to be,” says Mr Draper, “and will need to be submitted to the EA by April 30th on an annual basis.”
Applications for the derogation should be made via Defra’s Whole Farm Approach website (www.wholefarm.defra.gov.uk) which will notify applicant instantly if the derogation is granted. Telephone applications are also accepted.
Other management restrictions associated with the derogation include:-
• Ploughing grassland on sandy soils is restricted to the spring only (not between 1 July and 31 December). This limits the risk of N leaching and ensures that N applications are made when crop growth and therefore N requirement is likely to be at its highest.
• Autumn manure spreading before grassland is cultivated is prohibited
• Farmers must immediately follow ploughed grass with crops that have a high nitrogen demand (for example cereals, brassicas, grass and maize) within four weeks of the date of ploughing, or six weeks if the following crop is grass.
• Leguminous plants such as peas, beans should be excluded from the rotation. The exceptions to this are grass with less than 50% clover and legumes under-sown with grass.
Further help can be obtained via:
NVZ helpline 0845 345 1302 (Mon-Fri am – 6pm)
Reading Defra Guidance booklet 5a [http://www.defra.gov.uk/environment/quality/water/waterquality/diffuse/nitrate/help-for-farmers.htm]
Environment Agency website www.environment-agency.gov.uk/nvzs
Summer 2009
Electronic identification should bring benefits, farmers told
Sheep farmers are being urged by the Cross Compliance Advice Programme to prepare for the introduction of new legislation covering sheep identification, being introduced from the end of this year. This will introduce electronic identification and individual recording for sheep.
“Defra has sought to negotiate concessions to reduce the implementation burden on keepers, the rules of which will be covered by cross compliance. The Cross Compliance Advice Programme is working with Defra and the RPA to help farmers understand the rules and their obligations,” says Simon Draper, adviser for the Cross Compliance Advice Programme.
Electronic tagging will not be required for sheep going for slaughter within twelve months of their birth, but these animals will need a single conventional non-electronic slaughter batch tag. All other animals born after 31st December 2009 must be electronically identified. Importantly, electronic tag reading equipment will not be required even where electronic tags are used; sheep keepers can choose to record individual numbers manually if they prefer.
Sheep that are electronically identified will need to be individually recorded in the farm register and on movement documents when they are moved. The date of identification and death will also need to be individually recorded in the farm register. Animals identified with the non-electronic slaughter batch tag can continue to be moved and recorded on a batch basis as happens now.
“Electronic identification does increase the cost of sheep production, but there are ways of reducing the impact of EID” says Simon. “In fact, the system can provide benefits to sheep keepers as an animal husbandry tool. We’ll be providing updates and demonstrations for farmers on EID over the coming months, so keep an eye on www.crosscompliance.org.uk for more information.”
Storage of cereals post harvest: don’t forget cross compliance feed and food safety
With harvest approaching farmers are being urged by the Cross Compliance Advice Programme to ensure they are familiar with cross compliance food and feed safety rules. “Much of food and feed law comes down to common sense but it’s important to familiarise yourself with cross compliance requirements which apply regardless of any additional farm assurance requirements,” says cross compliance adviser Simon Draper.
Statutory management requirement (SMR) 11 covers food and feed law, the main provisions of which prohibit the placing of unsafe food or feed on the market and the feeding of unsafe feed to food-producing livestock. This is achieved through a variety of means including traceability, under which details must be recorded and kept of both inputs, including pesticide applications, and products leaving the farm.
Additionally, steps must be taken to avoid contamination of food or feed products by waste and chemicals.
“You can take fairly straightforward steps to avoid problems with harvested grain, such as by making sure the grain store is vermin-proof and ensuring the grain dryer has been serviced and works properly in case it’s needed.”
“Don’t forget that food and feed law covers a range of issues but for arable farmers, especially at this time of year, it’s particularly important to understand how problems associated with Fusarium mycotoxin contamination in your grain crops can be avoided. You can find a link to the Food Standards Agency, where you can find information on mycotoxin, on the ‘useful contacts’ section of www.crosscompliance.org.uk.”
Farmers reminded about avoiding animal welfare problems under cross compliance
Farmers are being reminded about the importance of maintaining good animal welfare and in particular the requirements of meet cross compliance for the Single Payment Scheme (SPS). According to the Cross Compliance Advisory Programme, animal welfare, in particular statutory management requirement (SMR) 18, is an important part of cross compliance and one that needs attention from some livestock keepers. SMR 18 covers the welfare of farmed animals and sets minimum standards for their care and husbandry.
The advisory programme, which runs the website www.crosscompliance.org.uk, is urging livestock owners and managers to develop a good understanding of their obligations under SMR 18. “The rules are pretty straightforward, easy to understand and practical to implement,” explained Simon Draper, adviser for the Momenta Cross Compliance Advisory Programme. “Like cross compliance breaches in many other areas, breaches of SMR 18 are usually completely avoidable and with a little forethought such problems may never arise.”
According to the Rural Payments Agency (RPA), farmers need to focus more on this cross compliance requirement, alongside those covering livestock ID and record keeping which also need attention. Recently published RPA statistics indicate that many breaches of SMR 18 are very easy to rectify and include, for example, medicine and mortality records not being kept.
“Ensuring that your obligations under SMR 18 are kept can be straightforward but needs a bit of common sense” said Simon. “Just making sure that records are kept, frequently checking that there are no hazards, such as sharp edges, in the field or animals’ housing and being able to recognise the signs of distressed animals are all very easy things to put right, and could mean the difference between a problem-free cross compliance inspection or SPS reductions and repeat inspections.”
Whole Farm Approach provides real benefits for cross compliance, farmers told
The Whole Farm Approach (WFA), Defra’s initiative aimed at reducing the regulatory burden on farmers and growers in England, has recently launched a tool to help farmers check that they meet their cross compliance requirements, according to the Cross Compliance Advisory Programme.
“The cross compliance self assessment tool is a very useful way of checking compliance and may help you to avoid cross compliance inspection failures and SPS reductions,” explained Simon Draper, adviser for the Momenta Cross Compliance Advisory Programme. “By inputting your farm details you can quickly and easily assess your current farming practices against both the Good Agricultural and Environmental Conditions (GAECs) and the Statutory Management Requirements (SMRs) that constitute cross compliance. It also provides you with tailored advice and guidance to help you address any problems.”
The Whole Farm Approach, which can be accessed from the Defra website, offers a faster and more efficient way of doing business between government and the farming industry. “With the recent launch of the cross compliance self assessment tool,” says Simon, “farmers participating in the WFA should be able to easily and clearly establish how well they meet requirements, take steps to correct any problems and by doing so, reduce cross compliance failures and SPS reductions.”
Spring 2009
As drilling and spraying continue, oil seed rape comes into flower and cattle are turned out English farmers have much to think about at this time of year. But it’s still important to remember your soil management and cross compliance obligations.
Good agricultural and environmental condition 1 (GAEC 1) covers the requirement for the soil protection review (SPR) to be completed by September 1 each year and for any measures to be implemented from January 1 the following year. That means that any problems, such as soil loss or degradation of soil structure resulting from last year’s sodden harvest, need to be considered when farming activities are being planned and carried out now and into harvest. Soil erosion and degradation can lower yields, contribute to flooding, pollute watercourses and deposit large quantities of soil on the road.
The SPR will help you to identify any fields and management practices causing problems, help you to plan how to resolve these problems and help you manage your soil resources more effectively. Carrying out your SPR can help improve the sustainability of soil resources on your farm and is necessary in order to avoid SPS reductions. When carrying out the SPR, you must:
Identify the soil types on your farm
Identify potential soil problems or risks
Identify appropriate management practices that will maintain organic matter levels
Identify management practices suitable for the crops being grown, soil types and the farm itself, which will help address any problems
Conduct an annual review of the SPR, making changes where ineffective practices are identified
Adapt farming activities to reflect appropriate management practices identified in the SPR
For more information on the SPR please contact the Cross Compliance Helpline on 0845 345 1302.
NVZ records : important deadline fast approaching
The new Nitrates Directive Action Programme measures, including designation of nitrate vulnerable zones (NVZs) and closed periods for muck spreading, also includes requirements for record keeping so that farmers in NVZs can demonstrate compliance with their obligations.
Statutory management requirement 4 (SMR 4) requires compliance with the Nitrates Directive and farm records will be the main focus of inspection during any cross compliance inspection by the Environment Agency.
Your records must show the area of your farm, existing manure/slurry storage capacity and any additional capacity required and the number and type of livestock kept. This will help you to calculate the total amount of nitrogen in livestock manure produced on your farm. Farmers in existing NVZs must complete these calculations by the 30th of April but farmers in newly designated NVZs have until 30 April 2010 to get this done.
You must also be able to provide information on any livestock manure moved onto or off the farm, the dates when field sites are used for temporary muck storage.
Additionally you should produce a nitrogen fertiliser plan showing crop type and date sown, soil nitrogen supply (SNS), crop nitrogen requirement and details of each planned and actual application of organic manure and manufactured nitrogen fertiliser.
Livestock identification and record keeping
As calving and lambing get well underway, and in some parts of the country are well and truly over, farmers need to make sure that young animals are properly identified and recorded.
Livestock identification and record-keeping are still major areas of cross compliance failure, so it is important that livestock keepers understand their obligations in order to reduce the likelihood of inspection breaches and payment reductions, according to the cross compliance advisory programme, run by AEA, the company behind Momenta.
SMR 7 requires all calves to be double tagged within 20 days of birth and recorded with BCMS within 27 days of birth. SMR 8 states that sheep must be tagged before the age of nine months, or six months if they are housed overnight, although if animals leave the holding before this age they must be tagged. Animals intended for slaughter in the UK before they reach twelve months of age only require one tag but all other animals require either a tag and a tattoo or two identical tags. Animals, which have already been officially tagged with an individual animal number before 11 January 2008, do not require any further tags.
“One of the major reasons for inspection failure occurs when movements and deaths of animals are not properly recorded,” a cross compliance adviser explained. “Cattle deaths must be recorded in the farm register within 7 days, and, depending on the age of the animal, either BCMS or the TSE helpline must be notified.” BCMS can be contacted on 0845 050 1234 and the number for the TSE helpline is 0800 525890.
“When moving sheep, animals must be correctly tagged and the movement should be recorded in the flock register. A movement document (AML1) must be completed, and it is the responsibility of the recipient of the sheep to complete the form and send off to Trading Standards.”
“Make sure you are familiar with the relevant statutory management requirements, SMRs 7 & 8, which cover your obligations. Tagging and record-keeping can seem an unnecessary bureaucratic burden but to help with traceability and to avoid cross compliance breaches and payment reductions it is important that you fully understand the rules.”
Following the recent ‘Health Check’ a number of changes have been made to GAECs and SMRs. Among these changes amendments have been made to GAEC 6 and SMRs 1 and 5 which cover wild birds and habitats, according to the cross compliance advisory programme, run by AEA, the company behind Momenta.
“SMR 1 covers the protection of wild birds and lays down rules on the taking or killing of wild birds and the disturbance, destruction or taking of nests and eggs. It also includes rules on disturbing or damaging fauna and features within a Special Protection Area (SPA),” a cross compliance adviser explained. “SMR 5 covers the protection of protected species and habitats, including Special Areas of Conservation (SAC) and GAEC 6 covers Sites of Special Scientific Interest (SSSIs).”
“The wording of the GAECs and SMRs has changed but your obligations remain the same. No longer are rules not relevant to agriculture but which relate to public bodies and undertakers included, and changes have been made to the wording covering prohibited methods of taking or killing wild birds. However, other UK and EU legislation continues to apply and so in practice there are no changes to the law.”
“Farmers will hopefully now have received new pages covering these, and other, cross compliance changes, which can be added to their copies of the Cross Compliance Handbook.”
Farmers views wanted on changes to cross compliance
Farmers are being urged to share their views with Defra on proposed changes to Good Agricultural and Environmental Conditions. “Now that set-aside has been abolished, Defra is looking to recapture the environmental benefits provided by this type of land management, and has presented a number of options for consideration by agricultural businesses. If you want to have a say in this, you need to get your response to Defra by the 27th of May,” according to the cross compliance advisory programme, run by AEA, the company behind Momenta.
“There are two main options: the first would be a mandatory, incentive led scheme, which would require a small proportion of farmland (around 5%) to be taken out of production or farmed more extensively. The second option would be a voluntary scheme which would build upon the benefits, and success, of Environmental Stewardship, as well as leading to the creation of Farm Environment Action Plans,” a cross compliance adviser explained.
“Full details of the consultation can be found on the Defra website and individual farmers are strongly encouraged to apply, even if they are members of the NFU and CLA which will be submitting collective responses.”
Nitrate Vulnerable zones – have you assessed your storage need?
As part of recently amended Nitrates Directive rules livestock producers within NVZs must take steps to ensure that they have sufficient storage capacity for slurry and manure. This is needed to comply with the closed periods for application as well as to meet the specific requirements for sufficient storage of these materials for defined periods.
“Slurry is defined not only as liquid manure but also as effluent from muck heaps and silage clamps,” explains Simon Draper, adviser for AEA, the company behind the Momenta cross compliance programme. “This should be kept separate from dirty water to avoid contamination; were this to happen it would mean that dirty water became classified as slurry and extra storage would be required.”
The storage requirements are six months capacity for pig slurry and poultry manure and five months for other livestock slurry.
For many farms which operate a weeping wall system, consideration should be given to preventing effluent entering dirty water lagoons and contaminating them. Alternatively, increasing the size of the lagoon may be necessary or it may be better to stop up the weeping wall system, or collect the effluent in another pit or tank. Where FYM or silage are stored or clamped on concrete, effluent will need to be separated to stop it entering the dirty water system.
“The first step is to carry out the calculations for the storage requirements for your holding which can be found in Leaflet 4 of the new Defra NVZ guidance. This document will take you through the calculations that will show how much storage capacity you need,” says Simon.
For 1996 or 2002-designated NVZs, these calculations have to be completed by the end of April to determine any new storage requirement for the farm. For new NVZs additional storage requirements must be established by the 30th of April 2010. Once this is done, the storage then has to be in place by January 2012. Up until the storage is in place the closed periods for slurry and manure application will not apply, as long as these calculations have been completed and you can show what actions are going to be taken to comply with the new standards.
End of the shooting season and wild bird cover
Wild bird or game cover can be a difficult area for the cross compliance regulations and its management will depend on how the land has been entered into the single payment scheme.
“If you’ve not got round to dealing with wild bird cover now that the shooting season is well over you should be thinking what you do with it,” explains Simon Draper, adviser for AEA, the company behind the Momenta cross compliance programme.
If wild bird cover has been designated as a crop then as long as the following crop is sown by May 15th, it is treated as any other crop grown under the cross compliance rules.
The majority of game cover strips will be considered as land not in agricultural production and therefore managed under GAEC 12. On this land, vegetation may not be cut between the 1st of March and 31st of July although a green cover should be established as soon after the 1st of March as practicable.
Where long-term game strips have been established, and managed in long term GAEC 12, then vegetation must be cut at least once every 5 years.
Many game cover strips will have been established under Environmental Stewardship so the rules for these schemes should be consulted for their management.
Winter 2008
Management of uncultivated land
As winter progresses farmers are being urged to remember cross compliance rules when looking at how they manage areas of uncultivated land over two hectares. “Certain rules apply when some types of uncultivated land or unimproved pasture are subject to improvement or cultivation for arable production, so if you are planning on applying fertiliser to land for the first time, or putting land into arable production, you need to be aware of these,” advises Simon Draper, adviser for AEA, the company behind the Momenta cross compliance programme.
“Good Agricultural and Environmental standard 5, which covers environmental impact assessments, states that permission must be granted by Natural England before any improvement activity (including cultivation or applying fertilisers or pesticides) is carried out on semi-natural areas or land which has not been actively managed in the last fifteen years. Semi-natural areas include species-rich hay meadows, fen, marsh and swamp, scrub, bracken patches, unimproved grassland and wet grassland,” says Simon.
“You should contact your local Natural England office if you do wish to undertake work on such land. NE will then have up to 35 days to consider whether the project can proceed or will require consent. If work is likely to have a significant environmental impact, then it may not proceed without this consent. Applicants who wish to apply for consent must submit an environmental statement to NE, who will then consult publicly and with other bodies before making a decision on whether consent is granted.”
A breach of these regulations, for example, failure to consult NE before beginning work or undertaking work for which consent has not been granted, could constitute a cross compliance breach and lead to a penalty.
Putting animals out for the spring and summer is still a long way off so it is important to continue to ensure that feed is stored correctly and is safe not only for the animals themselves, but also for the consumers of eggs, milk and meat. “Making sure that livestock feed is safe and that there is appropriate traceability not only makes sense for your animals, but it is also helps to maintain the safety of British food,” reminds Simon Draper, adviser for AEA, the company behind the Momenta cross compliance programme. “These rules are also an important part of cross compliance so farmers need to have an understanding of them.”
Statutory Management Requirement (SMR) 11, covering food and feed law, requires farmers to not place unsafe food or feed on the market or feed unsafe feed to food-producing animals. This means that if unsafe food or feed is detected, it must be withdrawn from the market and destroyed. In such cases, the local authority and the Food Standards Agency must be informed. Farmers are also obliged to put measures in place to ensure traceability of feed inputs, such as keeping appropriate records which provide details of the feed supplier, the type of feed supplied and the date that the feed was delivered. Similar information must be recorded for food and feed products leaving your farm.
“Good hygiene practices must be observed when handling food and feed on-farm and much of this is common sense. For example, feed should not be stored near to chemicals or where it can be contaminated by waste or hazardous materials. Veterinary medicines and pesticides should be used correctly and withdrawal periods observed, and brought-in feed should be sourced from establishments which are registered or approved with the local authority,” says Simon.
Additional requirements apply to producers of raw milk and eggs but all producers of food and feed must ensure that they are familiar with the cross compliance requirements.
The new nitrates regulation, which was introduced from the beginning of this year, places additional obligations on farmers who manage land within nitrate vulnerable zones. An important aspect of these rules is calculating the amounts of nitrogen (N) from mineral fertiliser, organic manures (including slurry) and deposits while grazing, which may be applied to land. For land designated as NVZs in 2002 and 2006, farmers must comply with these rules from 1 January 2009. For land designated in 2008 by the new regulations, farmers will have until 1 January 2010.
“Depending on whether or not you use organic manures, there are up to three N limits which you must be aware of when working out how much fertiliser or manure you can apply,” explains Simon Draper, adviser for AEA, the company behind the Momenta cross compliance programme. “N max limits apply to the most commonly grown crops, including grass, and set maximum quantities of N from manufactured nitrogen fertiliser and crop available nitrogen from livestock manures which may be applied to crops. The N max limit applies for each crop type averaged across the farm, so it may be exceeded in some fields, provided other fields growing that crop have correspondingly less N applied. With this in mind, no fields or areas of land may receive applications of organic manure from a spreader which exceed a rate of 250kg N/ha in any 12 months.”
“There is an additional nitrogen limit, the livestock manure N farm limit, which applies across the whole farm. Across the holding as a whole, livestock manure and slurry, and grazing deposits, must not exceed 170kg N/ha per calendar year. So even if individual fields receive more nitrogen (up to the 250kg N/ha field limit) the limit across the farm as a whole, from livestock manures and slurry, may not exceed 170kg N/ha,” says Simon.
Defra has applied to the European Commission for a derogation to allow an increased farm limit of up to 250kg N/ha for some farms. If this is granted there will be extra conditions that farmers will have to comply with. Those cattle farmers with 80% or more of their area under grass who think they can comply with the extra conditions can plan their 2009 compliance with the 250 kg N/ha limit.
NVZ leaflet 5, ‘The livestock manure N farm limit,’ which has been distributed at the NVZ launch events held across England in recent months, and which is also available from Defra, contains the information you need on how to assess your compliance with the farm limit. Further information on the derogation is contained in the Question and Answer publication on the Environment Agency web site or call the NVZ Helpline on 0845 345 1302.
Nitrate vulnerable zones – the N max calculation
Defra has recently introduced new regulations in order to help lower nitrate levels in England’s ground and surface waters. “There are many sources of nitrate pollution in water courses but certainly one of the main contributors in the United Kingdom is agriculture and these new rules are likely to have quite an impact on farmers affected,” explains Simon Draper, cross compliance adviser for AEA, the company behind Momenta.
“The new rules began to apply from the 1st of January within the 68% of England which now falls with nitrate vulnerable zones (NVZs), although for newly-designated NVZs the rules apply from next year. Among the obligations for farm businesses within NVZs is a requirement to make sure that the farm average application of nitrogen (N) from manure does not exceed the maximum application rate (N max) for the crop type. Farmers can ensure that they avoid exceeding N max limits for each crop type grown by using the method below,” says Simon.
First, the crop requirements need to be calculated to gauge how much mineral fertiliser should be applied. This is done by establishing soil nitrogen levels for fields where each crop type is grown and calculating the amount of nitrogen provided by any applications of organic manures. This figure is then subtracted from the crop N requirement. The remainder, or N deficit, can then be met with manufactured nitrogen. Figures for crop N max are available in the RB209 fertiliser guidelines and leaflet 3 of the new NVZ literature.
The amount of nitrogen that becomes available to the crop from applications of manure or slurry is a specified standard (further information and figures can be found in NVZ leaflet 3) and cannot be changed even if the manures are applied at the time of year when less N may be actually available to the crop.
Average applications of all nitrogen (manure and mineral fertiliser) must not exceed the N max for each specific crop, figures for which can be found in leaflet 3. The N max limit is a figure in kg/N per ha which applies across the farm rather than to individual fields. If the crop requirements for N in a particular field exceed the N max limit for that crop then any higher applications of nitrogen must be matched by lower N applications on other fields to ensure that the N max is not exceeded across the farm as a whole.
“Although the calculations may appear to be just additional paperwork they serve a useful purpose, not only in limiting environmental nitrogen pollution but also in reducing fertiliser wastage and applying only what is needed to the crop, thus potential saving on fertiliser costs” commented Simon.
Many game cover strips are grown to provide wild bird cover and food under cross compliance or environmental stewardship. With game shooting finishing in a few weeks farmers might be thinking about what they do with these areas when the season ends at the beginning of February.
“The management of these areas depends on what scheme they were established under” explains Simon Draper, cross compliance adviser for AEA, the company behind Momenta. “Where they were put in under the entry level environmental stewardship scheme (ELS) then it is important to ensure that the prescription agreed upon under ELS is followed.”
The main requirements of the ELS (EF2) ‘wild bird seed mixture’ option are:
- A combination of at least three species of small seed-bearing species must be sown chosen from barley, triticale, kale, quinoa, linseed, millet, mustard, fodder radish, and sunflower, with no single species making up more than 70% by weight of the mix.
- Blocks or strips at least 6 m wide should be sown. The area of either should be between 0.4 ha and 2 ha and there should be no more than 3 ha of cover in total per 100 ha of arable land to ensure that the strips or blocks are well distributed across the farm.
- Areas should be re-established as necessary but not before the 1st of March each year.
- Herbicides should only be applied for the control of injurious weeds or invasive alien species, and fertiliser should only be applied where necessary to aid establishment, but not within 10m of watercourses.
- The area should not be used for access, turning or storage, and not should it be grazed.
Not all cover strips are managed under ELS, however: “Where these strips are being grown on long term fallow areas as ground cover outside of the ELS scheme, GAEC 12 rules apply and the green cover must be maintained throughout he year” explains Simon. “If it needs to be re-seeded and a new green cover re-established this should be done as soon as practicable after the 1st of March.”
Green cover needs only to be cut once every 5 years although in practice it may be cut more often than this. However, it cannot be cut between the 1st of March and 31st of July in order to protect nesting birds. Non-farm vehicles should not be allowed on to this land and neither should fertiliser be applied unless it is managed as a winter feeding area for geese.
The welfare of calves is covered under the cross compliance regulations which means that additional rules – on top of those which apply to all farmed animals – apply. Simon Draper, cross compliance adviser for AEA, the company behind Momenta explains: “SMR 16 covers calf welfare and requires the animals to be inspected at least twice a day if inside, once if outside. You must make sure that the animals can move freely and rest and groom themselves without difficulty.”
Additional requirements within SMR 16 include minimum sizes for calf stalls or pens. The width of such enclosures must be at least the height of the calf at the withers and the length should be 1.1 x the calves’ length. Many calf pens breach cross compliance rules due to the presence of solid partitioning walls; walls must allow direct visual and physical contact with calves in neighbouring pens. Where calves are housed in groups the floor space of the pen must allow a minimum floor area for each calf, depending on their weight.
Further requirements include ensuring that housing is clean and designed to avoid injury to the animals. Calves must also have access to a well-drained lying area and suitable, dry bedding material, and weaned calves should be fed at least twice a day with the correct feed. SMR 18 covers animal welfare in general and includes requirements for appropriate feeding and the provision of drinking water.
“Farmers don’t need to be told that looking after their animals will give them better returns, and calves are no exception to this. Calves kept in comfortable, clean and dry conditions will grow into healthier, stronger and more valuable animals,” reminds Simon.
NVZ manure spreading closed periods
The new Nitrate Vulnerable Zones regulations, affecting farmers within NVZs from January 2009, introduce amended closed periods during which manures containing ‘highly available’ nitrogen (N), such as slurry and poultry manures, cannot be applied within NVZs. Whilst closed periods have always been a part of the NVZ rules the new regulations have altered the dates and scope of the closed period which now applies to all soil types. Depending on soil type and land use (cropped or grazed) these closed periods vary, but generally fall from late summer or autumn until late December or mid January.
“The idea of this requirement is to prevent rapidly leachable nitrogen from certain types of manure being lost to watercourses and groundwater,” explains cross compliance adviser Simon Draper. “Therefore, it makes sense for both farmers and the environment to have these closed periods during the winter so that when N is applied, it is retained and utilised by the crop.”
Were the maximum permitted field loading, which is 250kg/ha N, applied during the closed period as slurry or manure, then the amount of nitrogen the crop would receive could be as low as 12 kg/ha due to leaching cause by winter rainfall. Where the same amount applied outside of the closed period the amount of N available to the crop could increase to 125 kg/ha. “This represents a saving of up to £120/ha in fertiliser costs” said Simon Draper, “which makes this one bit of legislation that’s worth observing.”
Animal welfare for out-wintered livestock
With the winter now upon us, cattle and sheep which graze on outlying fields or on fodder crops such as stubble turnips need to be provided with a dry lying area and water to ensure that their welfare meets cross compliance regulations.
“Farmers need to ensure that there is a dry lying area in the field; this can either be an area which has been strawed down or the ground beneath a shelter. For fodder crops the lying area would ideally be somewhere which has not been cropped so that poaching is kept to a minimum,” suggests Simon Draper. “Providing these areas allow animals to get out of wet areas reducing the risk of health problems such as foot and leg ailments.”
As well as a dry lying area animals should also have access to drinking water at all times. “This could be as simple as a 50-gallon drum cut in half and filled with water,” says Simon Draper. “Much of the animals’ water requirement will be met through the plants they are eating and therefore the demand for water will be relatively small.”
With recent rapid hikes in potash and phosphate fertiliser costs renewed interest has been shown in the use of sewage sludge, and water companies are now seeing a demand for the product which for many cannot be matched.
“Don’t forget that the application of sewage sludge does have to meet rigorous standards which are not only a legal requirement but are also covered under cross compliance,” reminds Simon Draper.
Generally, water companies and their contractors apply most sewage sludge and so it is their responsibility to ensure that it is spread in accordance with the appropriate regulations. However, the landowner must make sure that:
- The sewage sludge and the soil in the field to which it is being applied are both properly sampled and analysed.
- The application rates are set to ensure that there are no excessive amounts of heavy metals applied and sludge must not be applied to any field where heavy metal levels are already high.
- The fields to which the sewage sludge is being applied are not too acid and have a pH of 5 or above.
- Sewage sludge is not applied to any field where fruit or vegetable crops are being grown or harvested at the time of application, and subsequent crops that are eaten raw must not be harvested for ten months after application.
- Animals are not grazed or forage crops harvested within three weeks of application.
- Where untreated sewage sludge is being applied it needs to be worked into the soil within 24 hours of application.
The nutrient needs of the crop must also be taken into account and the amount of other fertilisers should be adjusted to reflect levels of elements provided by the sludge. “The use of sewage sludge can save significant fertiliser costs,” says Simon Draper, “so it’s worth getting your sums right.”
In any case where sludge is being applied in a nitrate vulnerable zone, part of the rules applying to these areas require calculations to be made relating to the nitrogen content of the sludge to show any adjustments made to application rates. These calculations will need to show that the ‘N max’ figure – the total amount of nitrogen applied across the farm, in kg N/ha, for each crop grown – has not been exceeded and that the crop N requirement, taking into account soil N residues, has not been exceeded.
Cross compliance and the protection of water
Farmers are being reminded about the importance of safeguarding water quality, both for environmental protection reasons and also to help meet their cross compliance obligations. “The protection of water is an important element of cross compliance, and great care needs to be taken to maintain this valuable resource”, reminds Simon Draper, cross compliance adviser.
“There are three statutory management regulations (SMR) which cover water quality and pollution which must be observed, where relevant”’ he adds.
SMR 2, which requires compliance with the Groundwater Directive, is aimed at protecting groundwater from contamination. Groundwater is defined as water that is below the water table and in direct contact with the land; for instance, water extracted from aquifers used for drinking water or irrigation.
“Most contamination of groundwater occurs through pesticides, including sheep dip, and fertiliser entering via boreholes and springs, although in some cases it could be through watercourses”, Simon explains. “This happens when these chemicals are applied or disposed of too close to these points of entry to underground water sources.”
“In particular,” he stresses, “great care should be taken with sheep dip, when this is next used in the spring, as this is highly toxic and even small quantities can cause serious damage to the groundwater and its receptors.”
Even if there appears to be no connection between the disposal site of sheep dip and the water source (e.g. aquifer) there is always the potential for contamination, so you should always ensure that chemicals are disposed of safely. If in doubt, contact your local Environment Agency office to find out where it can be disposed of.
Recent changes to nitrate vulnerable zone (NVZ) measures (covered under SMR 4) include an increase in the area of land covered by this Directive as well as changes to the action programme measures operating within NVZs, which govern things like fertiliser use and storage. These changes include limiting applications of total N from livestock manures (deposited during grazing and by spreading) per calendar year, averaged across the farmed area, to 170 kg/ha.
Organic manures with high available nitrogen content may not be spread during specified closed periods, and facilities for storing manure on-farm, sufficient for six months worth of manure or slurry from pigs and five months from cattle, must also be provided. Farmers are also required to plan their applications of nitrogen to crops and to comply with an upper cap on nitrogen applications (N max).
To comply with these requirements, farmers must be able to calculate manure levels produced by livestock on the holding, how much manure storage is necessary to enable closed periods for manure application to be adhered to and nitrogen (N) requirements of different crops. Information on making these calculations can be found at http://www.crosscompliance.org.uk/cms/nvz/ and by calling the National NVZ Helpline on 0845 345 1302.
Use of plant protection products
Restrictions on the use of plant protection products, covered under SMR 9, are intended to minimise the risk of these products harming humans, animals and the environment. In the last two years IPU (Isoproturon) and Trifluarlin have both been withdrawn after excess levels were found in watercourses.
“The regulations allowed a two year period for the chemicals to be used up”, Simon explains, “and this is the last autumn that they can be legally used. As they are mainly used as autumn herbicides do ensure that you check your spray sheds and use up any material containing these ingredients now.”
IPU and Trifluarin can be applied post-emergence to winter cereal crops. However, IPU leaches and can cause problems in watercourses so the chemical should only be applied in dry conditions when rain is not forecast so that the loss from leaching is minimised.
The last use-up dates for IPU and Trifluarlin are June the 30th and March the 20th 2009 respectively. Advice on disposing of unwanted non-approved pesticides (which will include IPU and Trifluarlin after their use-up dates) can be found in the Pesticide Safety Directorate's Code of Practice for Using Plant Protection Products. Disposing of unapproved pesticides – which may constitute hazardous waste – is a complicated and potentially expensive process. You may need to use a licensed waste-disposal contractor and you may also need to pay a fee to the Environment Agency. If you need more guidance, contact the Environment Agency.
Autumn 2008
New NVZ regulations have been announced by Defra and will come into force on the 1st of January 2009. Nitrate vulnerable zones’ in England will be extended from covering 55% of land to around 70%.
“From January 2009, farmers in NVZs will have to step up action to cut the amount of nitrates from fertiliser and manures that get into rivers, “ reminds cross compliance adviser Simon Draper. “The revised action programme will also include changes to the permitted times of year when fertiliser and manure can be spread and additional requirements for storing manure.”
The new requirements will need to be observed by any farmer who’s land falls within the new NVZ areas. Other new measures relate to on-farm storage of manure and slurry and changes to farm nitrogen limits. There is also a requirement to plan nitrogen application according to requirements of crops.
Maps of the new nitrate vulnerable zones have now been published and can be found at http://web.adas.co.uk/defra/. Further information, including details of NVZ events, can be found at www.crosscompliance.org.uk/cms/nvz (13/10/08) or by calling the NVZ helpline on 0845 345 1302.
Repairing the damage after harvesting under waterlogged conditions
Defra announced in September that a cross compliance derogation would allow crops to be harvested when ground was waterlogged, activity normally prohibited under good agricultural and environmental condition (GAEC) 3. Such activity is likely to lead to soil damage that could potentially lead to soil erosion and future localised flooding.
Simon Draper, cross compliance adviser, considers what options are available to reduce the risk of this occurring once soil has been damaged. “The best option is to wait until the land dries before any more work is carried out to address soil damage, but unfortunately if more rain is forecast this may not be the most sensible and less efficient options, such as those described below, should be considered.”
Subsoil rutted headlands
Headland ruts converging at the gateway act as a trap for water and eroded soil and can be subject to localised flooding following heavy rainfall. Therefore, where conditions are marginal the first job should be to cultivate or subsoil these ruts to encourage drainage. Disturbing the soil further in this way does, however, carry a risk as subsequent heavy rainfall may lead to increased runoff and soil erosion.
These risks can be minimised by trying to cultivate when the conditions are at their best, normally immediately after harvest. If it does stay dry for a few days after harvest ruts should dry out further, become more stable and able to withstand heavy rainfall without significant run-off.
Cultivate the top 25 metres of the field
Where conditions are suitable, cultivate the highest side of the field when you get the opportunity to do so. This is where runoff begins and generally erosion increases with the force and speed of the flow of water downhill. By cultivating the top of the field, not only is there increased infiltration and hence a reduced volume of water to runoff, but the speed of runoff flow is reduced and so is the risk of erosion.
Broadcast a cover crop
Where it is not possible to cultivate at all due to poor soil conditions then broadcasting a quick-growing cover crop, such as mustard, will start to ‘hold’ the soil in place once it becomes established.
Complete the soil protection review
Whatever options you choose to address waterlogged soil problems, do make sure that you complete your cross compliance soil protection review, as required under GAEC 1, noting in which field the problem has occurred and what you plan to do, or have done, to correct it. Completing the soil protection review when soil damage occurs is a cross compliance requirement.
Restoring cross field footpaths
Public rights of way (PROW), including footpaths, must be reinstated if they are disturbed by ploughing and other cultivations taking place at this time of year.
“Good agricultural and environmental condition (GAEC) 8 requires that public rights of way remain accessible,” advises cross compliance adviser Simon Draper. “However, where a footpath or bridleway crosses a field, and you need to disturb it through cultivation then a breach of cross compliance will be avoided if the surface of the path is made good afterwards.”
The surface of the cross-field footpath or bridleway has to be reinstated to not less than the minimum width, which is 1 metre for a footpath and 2 metres for a bridleway, within 14 days of the first disturbance if you are sowing a crop, or within 24 hours in all other circumstances. The route of the reinstated footpath or bridleway should be indicated (canes are a good way of doing this) to members of the public to ensure it is visible.
Where fields that are crossed by footpaths or bridlepaths are to be sprayed off prior to cultivation only pesticides that have been approved for use on public footpaths should be used, and instructions on the product label should be read and followed carefully.
If a PROW crosses or runs alongside a field to be sprayed, members of the public should not be exposed to drift. This may mean that notices warning people that pesticides are being applied and to keep to the PROW should be erected. If members of the public are using the PROW when pesticides are being applied then spraying should be paused if there is a risk of exposure or spray drift.
It is possible to close a PROW but this is not usually done for pesticide application. If it is intended to apply pesticides that require public access to be restricted then the local authority should be contacted first.
The Heather and Grass Burning Code came into force in October 2007 after lengthy consultation with experts from farming and game shooting organisations. Farmers and land managers who burn heather and grass must comply with good agricultural and environment condition (GAEC) 10 covering heather and grass burning under the Heather and Grass etc. Burning (England) Regulations 2007.
“The new Code is a welcome development and means that the guidance is now much clearer for this important grass and heather management tool,” said Hugo Straker of the Game and Wildlife Conservation (GCT) Advisory Service. “Following the Code means that farmers and land managers responsible for heath and moorland management will not only be observing cross compliance requirements, but will also ensure that environmental protection is not compromised by irresponsible burning.”
SPS claimants are obliged to adhere to the burning season which runs from the 1st of October until the 15th of April, inclusive, in upland areas and from the 1st of November to the 31st of March, inclusive, on all other land.
The Code covers the burning of heather, grass, bracken, gorse and vaccinium (bilberry) and requires that all burning be controlled for their entire duration, and started only between sunrise and sunset. Consideration must also be given to the soil; fires must not leave soil smouldering for more than 48 hours and burning which may create a high risk of soil exposure and erosion is prohibited.
The new Code also requires observation of designated land such as sites of special scientific interest (SSSIs) and that consideration is shown to others nearby, including those using public highways.
Other key requirements include:
• all burning equipment must be fit for purpose and carried out in accordance with a written burning plan (contact Defra for Best Burning Practice Guide 1).
• not burning a single area of more than 0.5 ha on slopes over 45 degrees, or where half that area is covered by exposed rock or scree.
• individual fires must not expose a single area of more than 0.5 has of bare soil, usually caused by a hot or slow fire that leaves 2% or less vegetation cover.
The Game & Wildlife Conservation Trust Advisory Service, which can provide further information, can be contacted on 01425 651013. The code itself can be found on the Natural England website:
http://www.naturalengland.org.uk/planning/farming-wildlife/burning/default.htm.
Spring 2008
Keep soil records up-to-date following run-off
Farmers need to record any erosion or field run-off of water and soil following recent and sudden heavy downpours of rain.
“Where soil or water has run-off fields, or formed a gully in the field, the farm’s Soil Protection Review needs to be updated and the event recorded,” says cross compliance technical advisor Simon Draper.
The Soil Protection Review is a cross compliance document that must be made available for inspection and be updated every year or more often if necessary. Simon advises that any update should be made on the appropriate cropping page. “Under the remarks section of the Review document the field should be identified alongside a summary of any action taken to prevent a re-occurrence of the erosion or run-off. Prevention options are listed in the Cross Compliance Guidance for Soil Management booklet.”
Run-off or erosion prevention options range from simply using a spade to check that the soil structure across the field is favourable, to detailed plans relating to cultivation methods and crop choices, to soils and risks.
Weed control in the protection zone
Farmers and landowners need to know their options for controlling weeds in cross compliance protection zones alongside hedgerows and watercourses to prevent certain injurious and invasive weeds from spreading on their land or onto neighbouring land.
“For many farmers the strip known as the protection zone has been welcomed as the resulting luxuriant and grassy hedgerow growth has led to some knock-on benefits to the farm and field environment as a whole,” says cross compliance technical advisor Simon Draper.
The protection zone is a cross compliance requirement for farmers and landowners under ‘Good Agricultural and Environmental Condition (GAEC) 14 – Protection of hedgerows and watercourses’. It is the edge of a field, two-metres from the centre of a hedgerow or one-metre from the top of a watercourse bank, which cannot be sprayed, fertilised or cultivated. This is to protect not only the hedgerow, but also the surrounding habitat and help reduce the risk of water pollution.
The weeds listed as injurious under the Weeds Act that must not be allowed to spread, even in the protection zone, are common ragwort, spear thistle, creeping thistle, broad-leaved dock and curled dock. Other, less frequent, invasive weeds that must not be allowed to spread are rhododendron, Japanese knotweed, giant hogweed and Himalayan balsam. Spot application of herbicides is permitted to control these weeds in the protection zone. Giant hogweed should not be cut unless full protective clothing is worn as the sap can react with sunlight and cause blisters.
Mowing or cutting is the weed control option you should try first. The strips can be cut at any time of year but to protect ground nesting birds, it is advisable not to cut between 1 March and 31 July. Buffer strips in Entry Level Stewardship (ELS) or other agri-environment schemes which are additional to those required under cross compliance, are subject to their own management prescriptions, as set out in your agreement or handbook.
If cutting fails to control the weeds and you want to use herbicides in the protection zone e.g. to control a severe infestation of weeds not listed above (GAEC 11), you will have to seek a derogation from the Rural Payments Agency (RPA). You should bear in mind that green cover should be maintained on the protection zone margins. For growers that have obtained a derogation to spray, Simon recommends spot treating them with a knapsack sprayer using selective herbicides, where possible. If weed populations are too high for spot treatment then farmers can apply to the RPA for a derogation to use alternative application techniques such as a field sprayer.
“Grass weeds, including sterile brome and blackgrass, and broadleaved weeds such as cleavers that quickly spread from field boundaries and threaten cereal yields, are the main issue for arable farmers. Herbicide control tends to be expensive but control is achievable if the strips are mown before the nesting season starts and repeated after 1 August, at the end of the season,” advises Simon Draper.
No action required on game cover amendment
A revision of the Single Payment Scheme rules means that farmers who have entered wild bird or game cover on their claim form under the fallow land option will still receive payment without any further action.
Land used to grow cover has been confirmed as land in production under the OT1 code on the SPS claim form. There had been some debate that the cropping option came under the fallow land OT2 code and would have to be managed under cross compliance code under the Good Agricultural and Environmental Condition (GAEC) 12 regulations.
“Any land used to grow wild bird or game cover that has already been coded as OT2 does not need to be amended on the 2008 SPS claim form,” advises Simon Draper, cross compliance technical advisor. “And there will be no requirement for anyone who has used the code OT2 for wild bird or game cover to request an exemption as the land is not out of production and is not subject to the GAEC 12 conditions.”
If anyone has already written to the Rural Payments Agency, the Agency will reply confirming the agreed position. If an inspection takes place and the land has been coded as OT2 for wild bird or game cover land, the inspector will deem it to be in production and not subject to the GAEC 12 conditions.
The legislation makes it clear when land is deemed to be out of production. In most cases it is from the day after the day when harvest on the land was completed; the land otherwise ceased to be used for agricultural production; or the land ceased to be set-aside.
“Without any set-aside requirement this year any previous set-aside is now classified as GAEC 12, or land not in agricultural production, and is subject to a set of specific management regulations. However, a significant amount of this land is being returned to cropping this summer and is deemed to be back in production at the point when preparations begin for the following crop. This includes land being cultivated or being sprayed off with, for example, glyphosate as part of preparation for the following crop,” says Simon Draper.
More information on these and other topics is available from www.crosscompliance.org.uk or by calling the cross compliance helpline on 0845 345 1302.
We all know that animals should be inspected at least once a day by skillful staff, and that sick animals should be cared for. However, what records should an inspector require showing that these requirements have been carried out when lambing?
At the very least you will need to have medicinal treatment records showing dates of treatment, and what has been given to each animal. These should be kept for three years.
You will also need to have a record of births and deaths. With lambing it is all too easy to ignore those lambs that are born dead. However, recording the details of birth date, and to which ewe they were born to, is an important management tool as well as showing that you are remaining cross compliant.
Do ensure that whether outside or in, the sheep have access to a dry lying area and have drinking water, as both these items are likely to be checked on inspection.
Cattle Identification and Movements
With summer grazing now being considered in some areas it is an appropriate time to review the cross compliance issues relating to cattle ID and movements.
The cattle identification and movement rules were introduced to make effective management of diseases possible, and keep track of where animals are across the country. The rules are not new, difficult or complicated, so why is it that cattle regulations are the most frequent cross compliance challenge for everyone?
It’s probably down to lack of time, but the old adage is true; a stitch in time saves nine. A little time spent now will make things easier for you to manage and avoid a Single Farm Payment penalty.
Some of the rules can appear complicated, but they’re not. Here is a summary:
· Calves born on your holding should be tagged within 20 days of birth or before they leave the holding, whichever is sooner. Dairy calves must be tagged with one tag within 36 hours and the second within 20 days.
· Tags should not be removed without prior permission from Defra, while illegible or lost tags must be replaced within 28 days.
· A birth should be notified to BCMS and an application for a passport must be made within 7 days of a calf being tagged (i.e. no more than 27 days after birth)
· When cattle are moved their signed and completed passports should accompany them.
· Deaths must be notified to BCMS within 7 days.
· BCMS must be notified of movements on and off holdings within 3 days.
On a busy farm it is all too easy for the paperwork to slip and not notify BCMS about changes to your herd. However, it is in your interest to contact BCMS if you find a mistake. Leaving it may compound the error and make things much more difficult in the longer term.
We all know the huge environmental benefits of having a wide variety of flora and fauna on our farms. We also know what a nuisance some weeds can be, particularly when it comes to grazing or productive arable land.
In cross compliance terms common ragwort, creeping, field and spear thistle as well as curled and broad leaved dock, can, and should, be prevented from spreading across your own and other people’s fields or farms. Other invasive species such as Japanese knotweed, giant hogweed, Himalayan balsam and rhododendron are also included in the list of injurious weeds, although are less of a problem in most areas. All of these weeds should be controlled following the Defra codes of practice.
When attempting to get rid of any of these weeds it is best to stick to the principles used for all weed control. If you are going to use herbicides, consider which product is most suitable and at what rate as you ideally want to target just the weed and not other, more valuable, species. In general terms it is probably best to take advice from a BASIS registered agronomist who will be able to guide you on the most effective weed control, as well as telling you the rate, size of weed that can be controlled and the latest application.
Alternatively you may consider cutting or digging up of the weeds. The only word of warning here is don’t cut Himalayan Balsam as this will encourage the spread of this problematic weed. Giant hogweed should also not be cut unless full protective clothing is worn as the sap can react with sunlight and cause blisters.
Ragwort is one of the worst offenders for control and spreading. Help is on hand in the form of advice on the chemical and mechanical control of this particular weed in the Defra publication;
Guidance on the disposal options for common ragwort.
Controlling weeds in challenging areas
There are often calls to the helpline about whether weeds can be cut or sprayed in the 2m hedgerow and watercourse protection zone. Even if these areas are infested with weeds they cannot be blanket sprayed except with derogation from the RPA. However, they can still be cut, and spot spraying is allowed if necessary.
On most fallow land no spraying or cultivation should take place in the period between the 1st March and 31st July to avoid damage to ground nesting birds. If problem weeds are present they can still be controlled in this period through the use of graminicides, which will control pernicious grass weeds whilst avoiding destroying ground cover.
Bare fallow, that is land which is being fallowed to reduce the weed pressure for the forthcoming crop, should ideally not be cultivated or sprayed until the end of the ground bird nesting season. However, if necessary some grass weed sprays can be used. For example, glyphosate can be used as a preparatory spray when the ground is being returned to cropping.
If you are in doubt on any of these related topics speak to the Cross Compliance helpline on 0845 345 1302.
Keeping the nutrients, keeping the money
Proposed changes to the NVZ regulations have yet to be agreed, and until they are, it is worth remembering that the old rules continue to apply. However, there are still environmental and financial benefits to applying nutrients later in the spring anyway.
The existing rules mean that livestock slurries and poultry manures (with the exception of some duck manures) have closed periods for application to sandy or shallow soils.
The “no spreading” periods for fields not in grass or to be sown with an autumn sown crop are from 1st August until the 1st November. For fields in grass or to be sown with an autumn sown crop they apply from 1 September to 1 November.
It is likely that these closed periods will be extended and will apply to all soil types. However, with the increases in fertiliser prices in the past year, there are potentially large financial benefits from applying these high nitrogen content manures in the spring rather than the winter.
Standard figures indicate that in a cubic metre of cattle slurry, for example at 6% dry matter, there is 3.0 kg of nitrogen, 1.2 kg of phosphate and 3.5 kg of
potash. While this may not seem a lot, in a normal 50 cubic metres per hectare application that is 150 kg/ha of nitrogen, 60 kg/ha of phosphate and 175 kg/ha of potash. If all that were available to the crop then the value of the cattle slurry per hectare would be £261. Unfortunately, much can be lost to the environment through leaching and run-off.
You can make better use of this slurry by applying in the spring when the availability of nitrogen for crop growth increases to around 35% or better on all soil types.
Availability of nitrogen can be further increased in spring by incorporating slurry into the soil within 6 hours on arable land (45%) or by soil injection (50%). This represents a fertiliser value of £200/ha. This compares to a much poorer 5% to 20% availability for autumn applications and a potential net loss of £110/ha depending on soil type and method of application.
The very structure of the English landscape has been influenced, managed and in some places, created by man. In many cases grazing land over the generations has helped produce the vegetation structure and composition that are essential for valuable plant and animal life. This is particularly true for SSSIs, which are examples of some of the country's very best wildlife and geological sites.
Across the country, some of our most spectacular and beautiful habitats are to be found in more than 4,000 SSSIs, covering 7% of the country’s land area. Yet the condition of many SSSIs is under threat, often damaged through inappropriate grazing and feeding. While insufficient grazing may result in an increase in scrub and less valuable species, heavy grazing can lead to the loss of vegetation. Poaching and compaction may also occur in areas of higher grazing intensities, reducing the ability of the land to absorb heavy rain. This can lead to erosion and local flooding, with a detrimental impact on water quality.
Part of Good Agricultural and Environmental Condition is the requirement to avoid overgrazing and unsuitable supplementary feeding on such environmentally valuable land.
If you graze, farm or manage a SSSI area in any way, please be aware of the cross compliance regulations covering the land. This is particularly true if you think you may be affected by over or undergrazing, moor and heather burning or drainage issues. These areas may well be the starting point of an inspection.
Natural England will advise and help the owners of SSSIs ensure that these sites are managed in the best possible way. It may be possible to give financial help to carry out the necessary management. For specific technical questions contact the cross compliance helpline on 0845 345 1302 or for local advice contact your local Natural England office (details from the home page of www.naturalengland.org.uk)
Simon Draper, technical adviser to Momenta, the organisation responsible for delivering cross compliance advice on behalf of Defra, explains what to look out for when it comes to spraying and SMR9, the use of plant protection products.
“The product label provides instructions on the safe use of the product. Instructions in the statutory area, now called Important Information, must be complied with. For example, you cannot use a product on a crop which does not appear on the label or exceed a maximum individual dose.”
“It’s really quite simple,” continues Simon, “and your spray records should show how you’ve complied with the rules as they will state, as a minimum, the product/s, quantities of chemical/s and water, field/s and whether any LERAPs apply. Remember that an inspector will want to double check what’s on the label and compare it with how you’ve used it.”
“The ‘Directions for Use’ contain all other recommendations required to use the product safely. However, you can deviate from the recommendations depending on individual circumstances. If you do use sprays in a different way the Code of Practice entails carrying out an appropriate risk assessment, which must show the different way is just as safe. Speak to your agronomist about this as specialist advice is vital.”
You should also note that, by law, there are certain situations where you will need to have a qualification called a ‘certificate of competence’. In general, you will need a certificate of competence if you supply, store or use
agricultural pesticides. These are pesticides used in agriculture, horticulture, forestry, in or near water and as industrial herbicides.
The circumstances in which you need a certificate of competence are explained and set out in the Green Code, available at www.pesticides.gov.uk
For general information about spraying, SMR9 or cross compliance please visit www.crosscompliance.org.uk or contact the cross compliance helpline on 0845 345 1302.
Managing and Cutting Hedgerows
Please remember that hedgerows should not be cut from 1st March to 31st July as it is the main breeding season for birds. All wild birds, their young, their eggs and active nests are protected by law.
If you are laying or coppicing hedges you will know that it is often difficult to complete the work by this period, so you can carry on until the end of April. However, do check for nesting birds before going ahead.
With all the recent publicity about the welfare of housed poultry now is a good time to ensure that you are fully up to date with the cross compliance regulations covering all aspects of animal welfare.
There are specific regulations for some animals, such as pigs and calves, but many of the regulations apply to all species.
Simon Draper, technical adviser to the Cross Compliance programme, outlines the main requirements: “The first thing to think about is staffing. Given that the aim here is to set minimum standards for care and husbandry, animals must be cared for by people who have the correct skills and knowledge.”
“For animals that need frequent human attention, such as housed poultry, there should be thorough checks at least once a day. Obviously a good lighting system is important to ensure a thorough inspection can be carried out at any time. Any faults found with automated or mechanical equipment need to be put right immediately.”
He adds: “Although the standards of animal welfare in the UK overall are really good, it’s worth checking the cross compliance handbooks again, just to be sure that you are up to date and to avoid negative attention from the public or regulatory bodies.”
Keeping Cross Compliant during Spring Cropping
Both practical and legal considerations have to be borne in mind when ploughing and preparing for spring crops.
The Soil Protection Review should have been completed by January 2007 and updated by the 1st January 2008.
Simon Draper explains: “The green pages at the back of the form are where you should start your review. In essence you simply fill in the boxes relating to any areas where there have been soil issues, such as poaching or erosion, and what actions have been taken to prevent further problems in the future.”
Mr Draper continues: “The fact that soil damage or erosion may have occurred is not the issue with regards to cross compliance, it is how these issues have been dealt with. The Soil Protection Review is evidence of any changes that have been made illustrating effective soil management and future planning.
“It’s important that the Soil Protection Review is completed on an ongoing basis.
You may well not remember what happens on each field over the course of a year, so treat your SPR as a working document helping you to identify problems, and then act to improve management required on key fields. This document could actually become very useful to you in the future as it can help reduce soil loss and compaction problems. Ultimately this will keep the productivity of the land at high levels. It will also make life much easier at the end of the year when all you then have to do is transfer the information to the summary page.”
Keeping Up to Date – Changes to Cross Compliance in 2008
Key changes outlined in the recently distributed Cross Compliance Single Payment Scheme booklets relate to fallow land, habitats and species, including sheep movement and tagging regulations.
- Fallow Land
With the change in regulations from Europe there has been much debate about how to safeguard the environmental benefits of land that has previously been set-aside.
Unless you are going to grow a crop by the 15th May, rules relating to fallow land now require that you must establish and maintain a green cover on or after 1st March following the date when the land ceased to be in agricultural production. The green cover can be created through seeding or natural regeneration. Manures and fertilizers cannot be applied.
If you plan to manage the land as bare fallow there is no requirement to establish a green cover immediately, although planting or natural green regeneration must be in place within the 15 month period. Cutting or ploughing is not allowed unless controlling an infestation of blackgrass, couch, creeping thistle or dock. Certain grass herbicides are allowed if controlling blackgrass or couch. Finally, ensure that the land is recorded as not being in agricultural production in your Soil Protection Review with appropriate soil protection measures identified and taken.
If the field is long term fallow it still must be cut once very 5 years. Only half the area is allowed to be cut in any one year. You can cut more often if you need or want to so long as this is not done in the closed period (1 March and 31 July).
- Habitats and Species
The changes to the Habitats and Species regulations are to protect wild species and in many cases should not affect normal farming practice. However, the big change is that farmers who destroy a protected species or damage habitat can no longer use the defence that the damage was the incidental result of an otherwise lawful activity.
An example would be hedgerow management in the West Country. Dormice are known to inhabit many of the region’s hedgerows, and should therefore be assumed to be present in all of them. The regulations also have implications for those who manage forests. By following best practice guidelines it can be shown that all reasonable steps have been taken to comply with the legislation and the risk of prosecution is reduced if you inadvertently cause some damage.
For the details of protected habitats and species, as well as best practice guidelines contact your regional Natural England office (found on the home page of www.naturalengland.org.uk).
· Sheep and goat identification (SMR 8a)
The new rules have been simplified and there will be separate publicity relating to this topic. If you haven’t already received one, a helpful booklet, ‘PB 12912: Guidance for Keepers in England: Rules for identifying sheep and goats (January 2008)’ is obtainable from Defra publications free of charge.
Autumn/Winter 2007
Supplementary Feeding in Difficult Times
As the autumn turns to winter thoughts inevitably turn to how to keep animals in the best possible condition over the forthcoming months, particularly given FMD and BlueTongue complexities. Whether it be out wintered cattle or grazing sheep many of these animals will be kept on areas of open land that is the very nature of the English landscape such as moor, marsh or common.
As David Gardner, technical adviser to Momenta, the organization responsible for delivering cross compliance advice on behalf of Defra explain, “looking after animals in these sometimes challenging environments and conditions can make feeding and day to day management very hard work at times. Supplementary feeding is vital, although please make sure that if your animals are on areas of natural or semi-natural grassland areas that the feeders are moved regularly so that the land doesn’t become overgrazed, trampled, poached or rutted. This will ensure you meet your cross compliance regulations.”
Natural England has recently produced a leaflet entitled ‘Grazing Your Landscape’, which provides advice on how to identify and avoid overgrazing and unsuitable supplementary feeding. Farmers should visit the Natural England website for a copy of this leaflet (www.naturalengland.org.uk). For free and confidential advice telephone the helpline on 0845 345 1302.
Would your chemical store pass an inspection?
With much of the cultivation work coming to an end now is an ideal time to check that everything is in order in the chemical store. Simon Draper, technical adviser to Momenta, the organisation responsible for delivering cross compliance advice on behalf of Defra explains what to look out for.
“Firstly, farm assurance has helped many farmers keep a close eye on what plant protection products they are using, as well as how to comply with the latest regulations, so there shouldn’t be too much extra to sort out.”
“The aim of SMR 9 is to ensure that plant protection products are used in accordance with the law to minimise any risk to health and the environment. This is nothing new and farmers should already be doing this. To avoid any doubt it is worth keeping all your spray records and checking with your agronomist that you are not storing products that are no longer approved to use or have.”
Some areas of product use have caused some confusion recently, particularly in respect of reduced volume spraying and up to date approvals on products. Advice on this and other questions that have been asked can be found on the PSD website at www.pesticides.gov.uk or via the cross compliance helpline on 0845 345 1302.
To cultivate or not to cultivate?
The recent publicity surrounding the removal of the set-aside requirement for the forthcoming year has highlighted many practical as well as wildlife issues associated with cultivating land that was previously in long term set-aside.
As Simon Draper ,technical adviser to Momenta, the organization responsible for delivering cross compliance advice on behalf of Defra explains, “if the decision is made to re-crop set-aside please remember to update your Soil Protection Review, including identifying any new risks and/or measures taken to address these.”
“You will also need to make sure the land you cultivate is definitely set-aside and not permanent pasture. You can do this by checking your SP5a form, if it says PP1 (permanent pasture) you’ll need to re-consider your decision as the rules relating to this are different to set-aside.”
“Finally, don’t forget the 2m protection zones for hedgerows and watercourses. These should not be cultivated under cross compliance and are vital wildlife habitats. If you can provide more than the specified width there will be significant benefits in both practical and environmental ways.”
“Also do not forget that ploughing uncultivated, natural or semi-natural grassland, or may require a Environmental Impact Assessment (EIA). It is always best to check with Natural England if you feel this may effect your activities. The NE EIA unit is contactable on 0800 0282140. It is far better to be safe than sorry in this respect.”
The Curry Group have established a five point plan, summarised here, for how farmers can rise to the challenge of delivering the same level of environmental benefits from a smaller area.
1. Assess the environmental value of permanent set-aside land
2. Provide seed food for birds through the winter by leaving stubble and/or planting wild bird mix (game cover works well too)
3. Provide insect-rich habitats and nesting sites for birds through the summer; buffer strips, rough grassland, ditch banks and skylark plots are all ideal
4. Protect soil and water from erosion and run-off on banks, margins and steep slopes; heavy land may still not be ideal and light land may require cover crops and/or buffer strips
5. Find out more about helping scarce species and protecting the environment on your farm. You can gain further information from many organisations including the RSPB, FWAG, GCWT, all of whom will be able to help you consider wildlife options on your farm, including through agri-environment schemes, such as Entry Level Stewardship (ELS).
Notes to Editors
The Momenta consortium is delivering the cross compliance advice programme and comprises Momenta (part of AEA Technology), Farmcare, Kingshay, LEAF, The Game Conservancy Trust, the West Country Rivers Trust, The Arable Group and leading independent advisers.
As we come round to the hedge cutting season again, there will almost certainly be the regular debate about when is the best time, if at all, to cut hedges without affecting winter food for birds. Although there is no official guidance on this, the longer you leave the nuts and berries for birds, the better.
Although there are a few notable exceptions that can be checked with the Cross Compliance handbooks or helpline, the only normal requirement is that hedges should not be cut in the main bird breeding season,between 1st March and 31st July. For particular queries about removal or management of hedgerows, you should contact your local authority.
For best practice guidance on hedge cutting, Natural England has produced a booklet which can be obtained by visiting the hedge cutting section at www.naturalengland.org.uk.
The Importance of Animal Records
The recent Blue Tongue and Foot and Mouth outbreaks and the end of the summer grazing period highlight the need to ensure that your record keeping is up to date. The knowledge of the precise location of all livestock is essential for effective control and eradication of disease.
Keeping records up to date shows that, as an industry and country, English farmers are committed to ensuring farm animals’ health and welfare as they progress through the food chain. On a practical front, sorting out paperwork as you go along saves a lot of time and confusion later, and will ensure you are fully observing the requirements of Cross Compliance.
1) Cattle
As a reminder, when cattle are moved their signed and completed passports should accompany them and BCMS must be notified of movements on and off holdings within three days. To complement this process you must also keep an up to date on-farm register detailing births, movements and deaths.
Many farmers are now using CTS online to help make this process easier. For more information on CTS online, visit www.bcms.gov.uk. For further information on the Cross Compliance requirements, please check the 2006 Cross Compliance handbook.
If you have any further queries, contact the BCMS helpline on 0845 050 1234 or the Cross Compliance helpline on 0845 345 1302.
2) Sheep
Although it is likely that the regulations regarding sheep and goat identification will change, details are still being finalised. On this basis, it is still worthwhile covering a summary of what is required under existing Cross Compliance legislation. Any changes in the rules will be communicated to all farmers.
The responsibilities for identification and movement are with the keeper. This means the person with day-to-day responsibility for the animals, regardless of who owns them and whose land they are grazing. It is recommended that there is written confirmation of responsibility in case of inspection.
If a sheep (or goat) was born after 9th July 2005, it must be tagged with a UK tag within six months if intensively reared, nine months if extensively reared or before it leaves the holding of birth, whichever is the soonest. This tag shows an animal’s individual number and the flock number, which is specific to a holding. When animals leave a holding that is not their holding of birth, they should also have an S tag. This shows the flock number from where the animals are leaving.
Movement records should also be kept. A separate flock or herd register is required for each different holding where you keep sheep or goats. When the animals are moved, the records must be completed within 36 hours and one line should be used for each batch of animals moved. The easiest way to obtain details of what is required in the movement records, is to visit the Animal Movement Licensing section of the Defra website.
Finally, an annual stock inventory should be carried out on the entire flock on the 1st December. This is also the date that a new flock or herd register should be started.
Following the recent announcement of farmers having the option to reduce their set-aside to 0% please find following the official guidance from Defra and Natural England. Please contact me for further information, advice or if you would be interested in speaking to a technical specialist.
Set-aside has delivered large scale environmental benefits.
With the removal of the requirement to manage any land as set-aside in 2008, the NFU and CLA are urging farmers to ensure those benefits are retained. This follows their assurances to the Secretary of State, Hilary Benn, that increased production will not come at a cost to the environment. Hilary Benn has said he will be looking to the farming industry to deliver on these assurances.
Uncropped land is important because it can provide valuable habitat for a range of birds of arable land such as grey partridge and skylarks, some rare arable plants and wildlife such as brown hare. It is also important for reducing the risks of nutrients (from fertilisers and manures) and pesticides leaching into water from cultivated land.
So, if you're an arable farmer, what practical ways are there to retain the most valuable benefits that set-aside provided alongside any increase in production?
Here are some ideas as to how you can do this, and on less land.
How do I identify the best uncultivated land on my farm?
Generally, the longer the land has been uncropped, the greater the environmental value. There are other factors you will also need to think about.
* Are there valuable plant species or birds present that have been identified in surveys as important species in particular areas of your farm?
* Is the land next to water – so that it can capture run-off, nutrients, or spray drift?
* Is it close to another site of high botanical or species-rich value, or is the land protecting some archaeology?
* Does the land slope and aspect make it unsuitable for cultivation?
It is important to act now to try to protect the value of the set-aside habitats you have created on your farm, especially as this change has only been confirmed for one year and may be different in future years.
Will I lose out financially if I keep some of my land uncropped?
With most marginal land previously in set-aside, there are sound financial reasons why it was uncropped. It is important that you also consider the environmental benefits when you are making decisions to bring land back into production.
How can I rise to the challenge if I want to utilise all my uncropped land?
It should be remembered that while the change applies to this cropping year only, you may be asked to manage some of your land as set-aside in future years. With this in mind, you might consider keeping some of the more valuable uncropped land on your farm. This will of course depend on whether you are cultivating land that has been uncropped for some time, or whether it is part of your normal crop rotation. Here are a few helpful suggestions that should fit in easily with your current farm practice.
* Continue to leave awkward corners uncultivated.
* If you have set aside margins, don’t remove them altogether, but leave a reasonable width behind to keep the connection you have established between farm habitats. Keeping wider strips is particularly important for resource protection where they are on steeper slopes with shallow soils.
* Locate a smaller area of rotational uncropped land that will help to support the plants and birds using your farmland.
Won’t keeping land uncropped just lead to a build up of weed problems?
Any land you voluntarily leave uncropped will need to be managed under cross compliance requirement GAEC 12, in which problem weeds can be controlled and prevented from seeding.
I am planning spring cropping – can I still deliver environmental benefits?
Yes. Any land previously managed as set-aside which has been left uncropped and unmanaged over the winter and early spring perideliver valuable benefits for birds, plants and other issues such as resource protection. Some suggestions might be to:
* Leave your cultivations until early spring, providing your soil type allows for this. Any delay following harvest is valuable as it
* provides birds with an opportunity to feed on any shed seeds before they are buried.
* Follow the stubble from a spring crop with another spring crop, as this retains the beneficial weed value from one crop to another, which becomes an important source of insect and seed food for farmland birds next season.
* Try to minimise herbicide use in some of this season’s crops to allow some beneficial weeds to survive through to next harvest (they provide habitat and seeds for birds and small mammals). Obviously, where you have difficult grass weeds in fields, you will need to control them.
* If you are not already in Environmental Stewardship, look at the options that could safeguard these areas or reduce the impact of your cropping.
Rise to the challenge by following these five simple steps-
1. Don’t plough up valuable permanent set-aside land
2. Over the winter - provide food for birds
3. Spring/summer – provide food and nesting sites
4. Protect soil and water – protect banks and margins and steep slopes.
5. Find out more about the environmental/biodiversity value of your farm
– Get advice from RSPB, FWAG, Momenta etc.
So do more for less. By following these five simple steps you can help deliver the same level of environmental benefits using a smaller area.
Post harvest management – preparation of land
With harvest now heading (hopefully!) towards completion thoughts turn to the maize and sugarbeet crop. The weather patterns in England have changed over the past few years and we now tend to see drier Septembers followed by wetter Octobers. Therefore, if fields are deemed to be at all at risk of compaction or water logging they should be targeted to be harvested as early as possible in the season.
Harvesting in this way will help protect the soil - a farmer’s most valuable resource. It will prevent damage to the soil structure through compaction and heavy rutting of fields, which in turn results in a greater risk of erosion and an accelerated chance of run-off . By following the advice below you will also help to ensure compliance with GAEC 3, which states that you must not normally carry out mechanical field operations such as harvesting, cultivations and spreading and all other vehicle activity on an area of waterlogged soil. There are exceptions to this rule and details of these may be viewed in the 2006 Cross Compliance Handbook and RPA website at www.rpa.gov.uk.
The difficulty in adopting this approach is maintaining the balance of timing -combining appropriate harvesting conditions with the ripeness of the crop.
For maize this means looking at the crop and harvesting as soon as the cob has reached maturity. Cobs can be tested for maturity by testing with a thumbnail to see if there is still juice in the kernel; when there is not, it is ready for harvest. A more scientific method is to dry the crop down using an oven, although do be sure not to burn it as the smell given off stays with you for days! The difference in weights tells you the percentage moisture. Once the crop has reached 30% moisture it should be harvested as soon as possible.
For sugar beet there is not the same method of measuring the dry matter. The crop does benefit from being left in the ground as it encourages higher root yields, at the cost of the level of sugar in the root. If the historic plan has been to harvest in October every effort should be made to try and harvest earlier. This will ensure a quick delivery, ease of land management and allow for the establishment of a high yielding cereal crop afterwards.
After the severe flooding in parts of England, DEFRA announced a cross compliance derogation allowing harvest to continue on waterlogged land, also part of GAEC 3. However, if you were unfortunate enough to have to harvest under these conditions you still need to record any soil problems resulting from this activity in your Soil Protection Review and note what you intend to do to solve these. As per the rest of your SPR, this will need to be reviewed on at least an annual basis
Soil compaction reduces the pore space between soil particles, reducing the land’s capacity to absorb water and air, and this can be intensified when the soil is wet. Maize and sugarbeet harvest can result in deterioration of the soil structure which may enhance erosion and run-off. This can cause long-term environmental damage, a general nuisance to neighbours, as well as leading to difficulty in establishing a high yielding combinable crop in the following years.
Some options to consider and to include in your SPR could be:
* As soon as harvest is complete and the soil is no longer waterlogged, rough cultivate to help dry the field out.
* Subsoil tramlines and ruts when dry enough. On the wettest fields subsoil after the field has been roughly cultivated when there is more chance that it will have dried to the correct level.
* Drill into a rough seed-bed. This allows air to keep infiltrating the soil throughout the next crop’s life.
* Avoid rolling. Test bait for slugs as soon as possible to determine the threat. If levels are low then avoid rolling as the soil is more likely to cap and less air can get in.
* Change cropping. In very waterlogged fields drying will take a long time so it would be worth seeing if the crop rotation can be changed.
Clearly there will be other options, which may be more suitable in different situations and it may be advisable to discuss with an agronomist or other qualified professional.
If you have harvested under wet conditions and to ensure you remain cross compliant, record the option you have chosen to correct the problem in the Soil Protection Review. In the ‘comments’ box on the right hand side of the crop choice pages enter the field name where the problem has occurred and what option you have chosen to help correct the problem.
In 2006 Food and Feed Law became a Cross Compliance requirement (SMR 11). The basis for this law is to prevent contamination of food and feed and to stop unsafe products from entering the food chain. This requirement is relatively simple to understand and on a practical level comes down to traceability, record keeping and hygiene. Most of this should to be linked to your existing accounting and/or farm assurance system, which should mean that there is no additional burden.
It is important to note that SMR 11 does not apply to farm gate sales, only sales to and from other businesses. Similarly, you should note that the hygiene element of this requirement means abiding by the statutory pre-movement testing of animals and TB testing
One key element of the requirements is that you need to keep records showing not only what, and how, inputs and outputs tally for every food and feed enterprise on your farm (including the name and address of supplier/ customer, the nature/quantity of product and date of transaction), but also of anything relating to the treatment of your animals/crops, including any relevant reports on checks carried out on animals or products of animal origin.
