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Researching farmer perspectives on the impact of a potential increase in Nitrate Vulnerable Zones in Wales 2017

Research Conducted by: Donna Udall, Alex Franklin, Francis Rayns and Ulrich Schmutz

CAWR)


Correct citation: Udall, D., Franklin, A., Rayns, F. and Schmutz, U. (2017). Researching farmer perspectives on the impact of a potential increase in Nitrate Vulnerable Zones in Wales. CAWR (Centre for Agroecology, Water and Resilience), Coventry University, UK, www.coventry.ac.uk/CAWR, 51 pages Corresponding author: Donna Udall (email: Donna.Udall@coventry.ac.uk)

Acknowledgments: The authors are grateful to all the farmers and representatives of other organisations who participated in this study. Special thanks for the advice and guidance of Chris Thomas and Shumba Makinwa. Funding was provided by Coventry University. Photo Credits: Ulrich Schmutz. Proof Reading: Joanne Noone. Layout design: Rosie Gibbard

About this report: The aim of this work was to produce data that captures farmer and regulator opinions on both the current and potential future social, environmental and economic cost and opportunity of Nitrate Vulnerable Zones (NVZs) within Wales. The research findings reported here provide an independent evidence base to support future policy development. Notably, this includes advice about the introduction of participatory, co-production based approaches, which include farmers’ and other stakeholders’ interests and knowledge from the beginning of the policy process.


Executive Summary Nitrate vulnerable zones (NVZs) are areas of land draining into receiving waters that are currently high in nitrates and are subject to regulation under the European Union’s (EU) Nitrates Directive (91/676/EEC). Around 2.4% of Wales is within an NVZ and it is possible, as a result of an ongoing review that this area will be increased. In 2016 Coventry University conducted a study to gather information from a range of stakeholders about the possible implications of this. The following key conclusions were drawn: 1. The fear of NVZ regulation is currently mixed with Brexit uncertainties and a general squeeze in farm profitability in Wales, especially when supplying conventional markets. 2. Organic farmers are comfortable with NVZ regulations as organic certification is seen to be very much in line with NVZ regulation. 3. Dairy farmers are likely to suffer a disproportional impact due to the amount of slurry produced and lack of land to spread to. For some dairy farmers the installation of new slurry stores may be required at considerable expense. 4. Owners of smaller and extensive farms (beef, sheep) are less concerned, as they know they can meet the NVZ regulations. However, the administration may still be a burden. 5. Consideration should be given to a grant scheme to cover all or some of the investment required to meet NVZ regulations, with the proviso that famers also consent to a bespoke permitting scheme. This should achieve good buy-in from farmers and help develop relationships with Natural Resources Wales (NRW) staff, which are going to be crucial going forward. 6. Farmers are, in general, not convinced that if NVZs are increased this would benefit water quality in the short or long-term. They want to see the evidence and they what to be convinced by the government that this is necessary. The government should reconsider how to connect with farmers so that this information is effectively received. 7. Farmers also want to see the role of farming considered in relation to other polluters of watercourses. Farmers point to successes like reduced artificial N fertiliser application rates over the last decades and increase of agroecological and organic farming practices and they want to be credited for those improvements by Government. They also want encouragement for the services to the environment they already provide. Government should present any measures to reduce pollution as a package, where every industry does its fair share. 8. Given the increase in the number of farms that are likely to fall within NVZs, and the reduction in NRW staff currently underway, a risk based approach to identifying high polluting farms and their proximity to sensitive watercourses is vital. This approach would include criteria such as farm type, stocking rates, proximity to watercourses, topography etc. It could be deployed throughout Wales ensuring an equitable restriction, where necessary, on all farmers. This would mean that all farmers would have to be made aware of the impact of nitrate pollution and mitigation mechanisms, and that already stretched resources could be targeted according to risk based assessment criteria. We recommend more active and collaborative engagement with farmers and a focus on farmer driven solutions. Within this the increased adoption of agroecological farming techniques can offer a long-term route to the goal of reduced nitrates in water bodies. Such techniques should include more diverse grass sward with reduced stocking rates, grass/clover leys, cover crops and leguminous cash crops. In addition, buffer strips, riparian zones, reduced tillage, key-line ploughing, conture hedges, smaller field sizes, and more agroforestry.

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Technical Glossary Anaerobic digestate

Arlagarden

CAWR Compost Dairy Assurance

DEFRA Eutrophication

FAWL

A semi-solid material produced as a result of anaerobic digestion (AD) of waste from organic material (e.g. manure or food waste) or of energy crops grown for methane production. It is high in available nitrogen. A programme administered by Arla Foods. Requirements including taking responsibility for the milk, to ensure it is produced responsibly and is of a highquality standard. Centre for Agroecology, Water and Resilience, Coventry University. A material produced as a result of aerobic decomposition of organic materials such as park and garden wastes or FYM. Generally low in available nitrogen. Red Tractor Assurance for Farms Dairy Scheme, which is a requirement of many milk and dairy processors and retailers. Department for Environment, Food and Rural Affairs in the United Kingdom. The enrichment of a body of water with nutrients, often resulting in excessive algal growth. Farm Assured Welsh Livestock administered by Welsh Lamb and Beef Producers Ltd (WLBP). WLBP is a cooperative owned by over 7200 Welsh farmers. It strives to strengthen consumer confidence by providing assurance of farm standards through the FAWL scheme. Farms are assessed by Quality Welsh Food Certification Ltd. (QWFC), a body independently accredited by the United Kingdom Accreditation Service (UKAS) to strict European standards.

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Freedom Foods

FYM Glastir

Mineral nitrogen

NRW

NVZs

Organic Farming

Red Tractor Scheme

Sewage sludge Slurry

SSAFO

Tesco Nuture

A farm animal welfare assurance scheme run by the Royal Society for the Prevention of Cruelty to Animals (RSPCA) covering the whole of the animals’ life, from health and diet to environment and care. Independent assessors carry out annual checks. Farm Yard Manure (animal manure mixed with bedding, usually straw). Glastir (meaning sward) is the sustainable land management scheme funded by the Welsh Government Rural Communities – Rural Development Programme 2014-20. It pays for the delivery of environmental goods and services aimed at: combating climate change, improving water management and maintaining and enhancing biodiversity at the farm and landscape level. Nitrogen existing in ionic form as ammonium (NH4+) or nitrate (NO3). These are both soluble and can be taken up from the soil solution by plants (so are sometimes described as readily available nitrogen in contrast to un-decomposed or stabilised nitrogen that cannot be utilised directly. Nitrate is not attracted to soil particles and so is readily lost by leaching during periods of heavy rain. Natural Resources Wales. A body formed in 2013, largely taking over the functions of the Countryside Council for Wales, Forestry Commission Wales and the Environment Agency in Wales. Nitrate Vulnerable Zones. Areas of land where there is particular risk of nitrate pollution and as a result of which certain farming practices are closely regulated. Is a certified farming system covered by detailed UK, EU and international legislation and additional private standards e.g. the Soil Association in the UK. Organic farming means working with nature. It attempts highest levels of animal welfare, no manufactured herbicides or artificial fertilisers and a sustainable management of land and the natural environment. The word ‘organic’ is also used for organic manures or organic chemistry but when trading food or farm products words like organic, ecological, biological are protected by law and require a valid organic certification. Run by the Assured Food Standards, an organisation that promotes and regulates food quality, the Red Tractor quality mark is a UK product certification programme that comprises some farm assurance schemes for food products, animal feed, and fertiliser. A semi solid material produced as a result of treatment of municipal wastewater. Animal manure (particularly cattle manure) collected separately from bedding material and often mixed with rainwater from the collecting area. These are UK regulations (Defra) for Silage, Slurry and Agricultural Fuel Oil (SSAFO). Inside an NVZ there are extra rules for storing organic manures. Nurture is an independently accredited scheme exclusive to a UK supermarket chain called Tesco, dedicated to ensuring all fruit and vegetables are grown to environmental and responsible standards.

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Contents

1. Introduction ........................................................................................................................................ 6 2. Methodology ...................................................................................................................................... 9 3. Questionnaire Results ...................................................................................................................... 11 Numbers and Location of Respondents ................................................................................................... 11 Farmers and Farm Types .......................................................................................................................... 12 Farmers Thoughts on NVZ Impact – Have they Improved Rivers and the Environment? .................. 15 Changes in Farm Management due to Potential NVZ Inclusion .......................................................... 17 4. Qualitative Research Interviews ...................................................................................................... 19 Farm No. 1 ............................................................................................................................................. 19 Farm No. 2 ............................................................................................................................................. 21 Farm No. 3 ............................................................................................................................................. 22 Farm No. 4 ............................................................................................................................................. 23 Farm No. 5 ............................................................................................................................................. 24 Farm No. 6 ............................................................................................................................................. 25 Farm No. 7 ............................................................................................................................................. 26 Farm No. 8 ............................................................................................................................................. 27 5. Regulator and Farm Industry Representative Case Studies ............................................................ 28 Environment Officer, NRW ................................................................................................................... 28 NVZ Officers, NRW ................................................................................................................................ 32 Farmer Representative Organisations ................................................................................................. 34 6. Discussion and Conclusions .............................................................................................................. 41 7. Recommendations ............................................................................................................................ 44 Farmer Driven Solutions ....................................................................................................................... 45 8. References ........................................................................................................................................ 46 Appendix A. Main requirements for farming within an NVZ. ........................................................... 47 Appendix B. The English version of the questionnaire ..................................................................... 48

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1. Introduction The Nitrate Pollution Problem Nitrogen is an element vital to life on Earth as it is a key component of all proteins and many other biomolecules. It is abundant in the atmosphere but only certain microorganisms are able to ‘fix’ it and thus make it available indirectly to other species. The most significant of these are the rhizobia bacteria that form symbiotic associations with legumes (i.e. forage crops such as clover and cash crops such as peas and beans). Industrialised agriculture relies heavily on ‘synthetic’ nitrogen fertilisers that are made under conditions of high temperature and pressure with a significant energy input. Plants are generally only able to take up nitrogen from the soil as the ‘mineral’ ions ammonium (NH4+) or nitrate (NO3-), which are produced as a result of the decomposition of organic matter. Nitrate is readily soluble in water and negatively charged and so is not held in the soil on its positively charged ‘cation exchange’ sites. As a result it is readily leached out of the soil as soon as it reaches field capacity and there is insufficient demand from growing crops – this represents both a waste of this important nutrient to the farmer and a source of pollution in the wider environment. It is a particular problem on light (sandy) soils that drain most readily.

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Nitrate can also be lost in surface run off from farmland following excessive application of materials (especially slurry) that contain large amounts of readily available nitrogen. Such materials can also result in air pollution as a result of gaseous emissions. Point source nitrate pollution is also possible – this most commonly results from damaged or overflowing slurry stores but sometimes discharges from sewage works or domestic septic tanks can be responsible. There are two main issues with nitrate pollution (Ward et al; 2005, Pretty et al. 2012): 1) Contamination of drinking water. The ingestion of nitrate (either in drinking water or in food) can cause health issues in humans. It has been linked to stomach cancer and to ‘blue baby syndrome’, whereby red blood cells struggle to transport sufficient oxygen. Much of our drinking water comes from groundwater from deep boreholes; it can take many years for pollution from the surface to reach these depths and so any mitigation measures must be in place for a long time before their effects can be seen. 2) Eutrophication. Nutrient enrichment can result in disturbance of aquatic ecosystems, most notably the prolific growth of algae and reduction of oxygen levels. This can kill fish and reduce biodiversity with consequent impacts on the recreational value of water bodies. Elevated nitrogen concentrations on their own are often not sufficient to cause eutrophication – it usually occurs when excessive phosphorus is present; this may also originate from agriculture. Nitrate Vulnerable Zones To address these issues the Nitrates Directive (91/676/EEC) (EU 1991) was introduced by the EU in 1991. This is now incorporated into the Water Framework Directive (2000) and the Groundwater Directive (2006). As a result of these directives all 27 Member States have drawn up Action Programmes to minimise nitrate pollution. A key aim is to keep groundwater nitrate concentrations below 50mg/litre, generally accepted as a safe level for drinking water. The details of the Action Programmes vary from country to country but they include the development of voluntary codes of good practice that apply to every farmer and additional compulsory regulations for farmers in certain areas, known as Nitrate Vulnerable Zones (NVZs) that are considered to be at particular risk. The main requirements for farmers in NVZs are listed in Appendix A. Around 2.4% of Wales (and 58% of England) is currently within an NVZ but some countries (e.g. Northern Ireland and Germany) have decided to so designate their entire territories and apply the regulation to every farm. However, this does not mean they are all succeeding with preventing water pollution and e.g. the EU commission is taking legal action against the current German government for lack of progress in nitrate pollution prevention in surface waters and into the Baltic Sea (European

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commission, 2016). EU member states have agreed to review their implementation of the Nitrates Directive every four years. As a result of the review, any appropriate amendments to the Regulation or measures in the Action Programme will then be developed. NVZs in Wales were last updated in October 2013 and so must be reviewed in 2017. In 2016 a consultation was held by the Welsh Government that considered two options; an increase in the area of designated NVZs (to approximately 8% of the whole country) or designation of the Whole of Wales as an NVZ (Welsh Government 2016). The supporting documents to the consultation included reports that had been commissioned that explained the methodologies used to identify areas at particular risk of surface water pollution (WRC 2016), ground water pollution (WRCa 2016) or eutrophication (Environment Agency 2012). For example, in the case of ground water contamination, data from boreholes was combined with the results of computer modelling to identify areas at risk; land that is directly above polluted groundwater does not necessarily drain into it and so knowledge of hydrogeological features was used to define the appropriate catchments. As a result of this a list of potential new NVZs was produced by NRW (NRW 2016). Farmer Perspectives This research aimed to assess the anticipated impact of this policy change on farmers and regulators. The research team administered a questionnaire and conducted interviews in North and South Wales to assess the possible effects of the proposed review. The aim was to produce data that captures farmer and regulator opinions on both the current and potential future social, environmental and economic cost and opportunity of NVZs within Wales. The research findings reported here provide an independent evidence base to support future policy development. Notably, this includes advice about the introduction of participatory, co-production based approaches, which include farmers’ and other stakeholders’ interests and knowledge from the beginning of the policy process. The recent triggering of Article 50 (as part of the UK’s intention to leave the EU) combined with the preceding and growing pressures faced by frontline public sector staff, make the need for securing a collaborative, joined up and effective approach to environmental protection and regulation, all the more critical. The principle of co-production and the supporting legislative structure created through the Welsh Well-being for Future Generations Act (2015) (Welsh Government 2015) can create an opportunity for the post-EU management of NVZs in Wales to achieve these goals for multiple, social, economic and environmental benefits.

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2. Methodology A mixed-method data collection strategy was deployed to capture both the breadth and depth of the impact of NVZs in Wales. In close co-operation with Welsh farmers and regulators, a bilingual questionnaire (English and Welsh) was developed by researchers at the Centre for Agroecology, Water and Resilience (CAWR) at Coventry University, UK. The website Yell.com was interrogated for ‘farmers’ in target counties which gave a list of just over a thousand addresses in Pembrokeshire, Carmarthenshire, Flintshire, and Denbighshire (counties which already included some NVZs and/or were areas where NVZ expansion was possible). Hard copy questionnaires, in English and Welsh, were sent to all of these addresses (see Appendix B). All other farmers throughout Wales were encouraged to participate through emails and twitter feeds sent via the NFU and Farmers Weekly. Farmers also had the option of responding via an online survey, which exactly mirrored the hard copy versions. Farmers were encouraged to respond by the offer of entry into a draw for a full annual subscription to Farmers Weekly. The questionnaire was live for four weeks and ended on the 31st July 2016. During July, August and September 2016, key stakeholder interviews were conducted with targeted individuals of Natural Resources Wales (NRW), Farmers Union Wales (FUW) and the NFU. Also, farmers were asked to self-nominate for participation in an on-farm research interview as part of completing the

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questionnaire. 30 farmers accordingly indicated their willingness to participate. Eight farmers were then chosen to represent a wide range of farm types. For instance, a farmer each from small (<49 ha), medium (50 – 200 ha) or large farms (> 200 ha), and from different farm systems, e.g. dairy, sheep and beef. Two of the farmers were already in an NVZ, one partly in, and five were not currently in an NVZ. Each farmer selected was visited on the farm and interviewed by two members of the CAWR research team; in most cases this was followed by a farm walk. Interviews were recorded for detailed analysis and farm pictures were taken with the permission of the interviewees. The interview questions were designed to extend and deepen the information captured via the questionnaire, and to secure data on the perceptions and opinions of respondents about: •

the financial impact of NVZs at a farm and national scale

the farm management impact of NVZs

the environmental impact of NVZs at a farm and national scale

existing communication and general levels of awareness amongst the various stakeholder groups regarding NVZs

the relevance of the impending EU exit on the NVZs (on-farm interviews only).

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3. Questionnaire Results Numbers and Location of Respondents Figure 1. gives the location of all responding farmers who submitted their postcode. Overall, 98 farmers responded to the hard copy questionnaire of 1,000 issued. Of these 91 responded in English and 7 in Welsh. Eight were already in an NVZ and the rest were not. Hence the answers from those not already in an NVZ relate more to expectations and concerns for the future. Six counties were represented, in both north-east and south-west Wales. Flintshire gave the highest return rate for questionnaires at 13% of those sent out, followed by Carmarthenshire (12%) and Denbighshire and Pembrokeshire (8% each). It was interesting to note that of the 43,000 NFU Twitter followers and 61,500 Farmers Weekly Twitter followers sent links to the survey, none responded online.

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Figure 1. Location of Farmer Respondents

Farmers and Farm Types With regard to farm type, dairy farmers constituted nearly 50% of the respondents (Figure 2) but other

Percentage of Respondents

grazing livestock enterprises were also very important. 60 50 40 30 20 10 0 Dairy

Grazing Grazing Livestock Livestock (LFA) (Lowland)

Cereals

Other

Poultry

Pigs

Horticulture

Farm Types

Figure 2. Percentage of Respondents by Farm type. Please note that this illustrates the total of farming types, with some farmers having ticked several farm type options.

Farmers were asked if they thought they were already in an NVZ. 90% indicated that they were not, with the remaining respondents, nearly 10%, stating that they did not know whether they were in an NVZ.

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Of the 98 respondents, 96 indicated farm size. 67 had mid-sized farms (50 – 200 hectares), while 22 responded from small farms or holdings (< 50 hectares) and seven responded from farms in excess of 200 hectares. 2% 2% 4%

7% Arlagarden

11%

Dairy Assurance FAWL Freedom Foods Glastir 22%

None 43%

Organic Red Tractor Tesco Nurture

5%

4%

Figure 3. Participation of respondents in farm certification schemes. Respondents were asked to provide details of any schemes they were associated with (Figure 3). 43% were certified with FAWL (Farm Assured Welsh Livestock). To maintain membership of FAWL a farmer must demonstrate a commitment to high standards of animal welfare and husbandry, but not necessarily sustainable land management in the broader context. 11% of farmers were certified Organic. Organic certification is administered by a number of organisations (all regulated by DEFRA), the largest of which in Wales are the Soil Association and Organic Farmers & Growers. These organisations are required to meet the EU’s offical organic standards, but they can choose to exceed them.

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Farmers Thoughts on NVZs – Advantages and Disadvantages Asked if they were aware of NVZ aims and rules, nearly 40% of respondents stated that they were not. Although this may be because they are not yet in a zone, it is nevertheless highlights a general awareness issue that will need to be reviewed should the zones be expanded. People are also more naturally against something they don’t understand. Respondents were also asked whether or not NVZs had their ‘good points’ (Figure 4). That 62% of respondents considered that NVZs have, or possibly have, good point’s is perhaps indicative of a general understanding of the impact of nitrates on the environment and, possibly, the farmer’s role in mitigation. 50

50

Number of Respondents

Number of Respondents

40 30 20 10 0 Yes

Possibly

No

Response

Figure 4. Respondent Answers to ‘Do you think there are any good points to NVZs?’

40 30 20 10 0 Yes

Possibly

No

Response Figure 5. Respondent Answers to ‘Do you think there are any bad points to NVZs?’

This implicit openness to understanding the effects of, and taking responsibility for, farming and the environment, bodes well for developing a more progressive attitude to nitrate management. However, in cases where respondents gave more detail, specifying why they thought NVZs had their good points, there appeared to be a financial motivation, with comments including ‘‘Reduced costs’, ‘use less fert [sic.]’ and ‘Plenty of grants for improving farming practices’. In all, 26 farmers offered more detail on their thoughts, of which only three provided comments on the effect on the environment. This included, for example: ‘Soil improvement with correct slurry handling and no pollution in watercourses.’ In accordance with the above example, the financial incentive sought may not necessarily be in the form of financial support for one-off infrastructure investment per se. There is also some evidence to suggest that farmers would be equally motivated by seeing reduced costs and improved efficiencies resulting from more sustainable farming practices for which financial assistance from the Welsh Government may be an enabler.

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In response to ‘Do you think that there are any bad points to NVZs?’ (Figure 5), 90% of respondents felt that there were, or possibly were, bad points. Accompanying comments elucidating farmers’ concerns can broadly be categorized as increased financial costs, increased bureaucracy and restrictions on management practices. By way of illustration, supporting comments included: ‘More capital investment needed;’ Reduced output because of lower stocking rate & lower fertiliser usage’; ‘More paperwork, more problems’; and, ‘I would not be able to apply manure in the winter months when ground conditions are favourable. This would mean when the spreading window opens I would possibly have to apply in poor ground conditions, thus causing damage to soil structure and organisms which in turn will reduce my soils ability to retain nutrients and cause greater diffuse pollution’. It was interesting to note that the number of comments received regarding bureaucracy and restrictions on management practice, considerably outweighed those citing more obvious financial concerns as perceived bad points of NVZs. Farmers Thoughts on NVZ Impact – Have they Improved Rivers and the Environment? Of the respondents who answered this question (91) 89% felt that NVZs had, or possibly had, improved river and water quality. However, within this group there were still doubts as to the effectiveness of NVZs. The fact that 90% of respondents were not yet in an NVZ and may not be fully familiar with their procedures and effect may again be of relevance here. Based on the comments provided, the respondents could be broadly divided into those who were convinced, unsure and unconvinced. The ‘unconvinced’ group expressed concerns regarding the impact of industry on watercourses and questioned whether there had been any improvement at all: Convinced of Benefit ‘NVZ have made farmers more aware of the value of the nutrients available in our manure on farm.’ ‘Slurry/dirty water controlled to avoid run off & contamination of rivers allowing fish/fauna to thrive.’ ‘Reduction of nitrate and phosphate in water’ Unconvinced of Benefit ‘Very little, a lot of nutrients both nitrate and phosphate are coming from sewage plants’. ‘Water improvement as local industry has been monitored by Natural ResourcesWales.’ ‘Very little as farmers still spread slurry through the closed period.’

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‘Water quality may have improved, but the improvement has little to do with nitrate regulations, pollution from other sources has been reduced - hence the improvement.’ ‘The South Pembrokeshire NVZ has had an increase in phosphate levels.’ ‘Not enough information to give a valid answer’ The item which elicited most views and detailed explanation was the question: ‘In general terms, in what way do you think farming impacts upon the environment?’: Farmers clearly hold strong views on this, with many negative comments put forward about the way that farmers and farming are perceived in terms of their impact on the environment. It was interesting to note (see below) that some within the farming community continue to see a healthy environment as one that is ‘not overgrown’, ‘clean’ and ‘not ugly’. This rather clean-aesthetic view of the environment is one which may impact upon many farming decisions. As such, it is notable should training or regulatory interventions be designed and deployed. Amongst the questionnaire respondents, however, there are also some farmers who clearly demonstrated a deeper understanding of biodiversity and the environment: Positive ‘Farmers on the whole care deeply about the environment as it directly impacts their livelihood, however, more paperwork is not what most farmers do well’. ‘Good way. Without farming the countryside would soon become overgrown creating a negative impact on tourism and money spent in rural communities. At present green fields and well-kept farms mean healthy foods and lifestyle’. ‘The environment is what farming has created.’ ‘Very positive impact. The countryside has been managed and maintained by farmers for centuries. The landscape we have today is a magnificent tribute to their work’. ‘Farming can, if managed correctly go hand in hand with the environment, many farming practices are damaging soil quality and structure leading to higher inputs needed and therefore more run-off and pollution’. Negative ‘Some of the farm’s milk to money and pollution.’ ‘Causes reduced biodiversity, water pollution, release of greenhouse gases, antibiotic resistance, big producer of CO2’. ‘Potential for leaching of nutrients and agrichemicals from conventional agriculture. Organic farming has much to offer in this area’. ‘Intensive farming damages the environment, extensive farming is more sympathetic towards the environment.’

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Changes in Farm Management due to Potential NVZ Inclusion 43 respondents stated that they were concerned about NVZ designation (Figure 6), while 31 were not.

Number of Respondents

This answer may, however, have been very much dependent upon farm type. 50 40 30 20 10 0 No

Yes Reponse

Figure 6. Respondent Answers to ‘Are you concerned about NVZ designation?’

Of the 42% who answered ‘no’, not one offered a reason. Accordingly, it is not possible to understand the thinking behind their response. In contrast, however, those who said ‘yes’ offered many comments. Comments included: Practical constraints ‘Having to store slurry for longer.’ ‘I will be unable to decide when best to apply nutrients to my farm.’ ‘Will have to transport some of my hen muck out of the zone.’ Financial ‘The farming industry cannot sustain the capital investment required. With the present returns, young people will not invest in farms’. ‘Increased cost for the farm. Restricted fertiliser/slurry will limit productivity of the grass’. ‘Considerably increased costs with capital investment with no material benefit.’ Other ‘Unsure as not aware of the rules’. ‘Gross depression.’ ‘More regulations to worry about.’ ‘Negative. But thankfully EU Brexit mean unlikely!’ Seemingly, therefore, according to the above, as much concern was demonstrated by farmers surrounding practical constraints and management practice as was for financial impediments.

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Eight respondents were already in an NVZ (this is 8% of our the sample, while NVZs in Wales currently cover only 2.4% of the whole country). Five respondents felt that designation necessitated them to make changes to the way they farm, with three reporting changes to infrastructure and two reporting the requirement to purchase new equipment. Further detailed information on this was collected during the on-farm research interviews. Communication Respondents were asked if they were satisfied with the level of communication about NVZs. Of the 78 who responded to this, 70% were not satisfied. Although this finding is likely to be affected by the fact that the majority of respondents were not currently within an NVZ, it nevertheless has clear implications for the approach taken to training and dissemination of key obligations if the NVZ is to be expanded in the future.

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4. Qualitative Research Interviews The qualitative semi-structured research interviews were conducted on-farm. The structure consisted of a set of questions designed to develop the responses received from the questionnaire. All interviews were conducted in English. Set out below, for each interviewee in turn, is a short contextual summary of the farm type together with an overview of their attitude towards NVZs in Wales, based on the responses they provided.

Farm No. 1 NVZ Status Outside

Organic Status Nonorganic

Location

Hectares

Flintshire 90

Produce

Details

180 dairy cows, plus 200 followers

Pedigree Ayrshires, some raw milk sold on farm, rest for cheese. Selling cows and bulls important. Bull as well as calf meat produced.

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Farm Background The swards include some clover but nitrogen fertilisers are used as well. The farm is reseeded in rotation, sometimes with a slot seeder so that a full cultivation is not required. Most is grazed with the more distant fields being cut for silage (or haylage, but not for hay). Some maize silage is bought in and in return, some solid farmyard manure (FYM) is given to the people that grow it (young stock are bedded on straw). Concentrates are also bought in (1.3t per cow) but the system is not intensive with an emphasis on reducing inputs and maximising cow longevity. It is reportedly not far from being organic but formal conversion would have higher input costs and better prices could not be guaranteed. Slurry from the yard area is collected but there is only a small store (over 20 years old) and in wet weather it must be emptied twice a week – fortunately the soil is quite sandy so this is not generally perceived to be a problem. The cows are fed outside (for health reasons) and so there is more slurry produced than if they were kept inside all the time (rainfall dilutes the slurry, but does not increase the N content). Attitudes to NVZ The farmer felt that the farming industry is generally overregulated creating the risk that NVZ rules will force many, particularly dairy farmers, out of business. He hoped that upon leaving the EU the regulations would be more ‘appropriate’. He was also of the opinion however, that the Welsh Government had ‘no interest in farming at all’ and generally staff from NRW was ‘ill informed’. Were this farm to be covered by NVZ regulations, the main issue would be cost of increased slurry storage for the closed period. He thought this would be unreasonable because the slurry is dilute and there are no watercourses nearby that could be polluted. A new slurry store of adequate size could cost a ‘six figure sum’ with no direct financial return. The farmer wondered if this could be subsidised by the government, but considered that their money could be better spent on something else like the NHS. He was unaware that there were any plans to increase the current NVZ area, especially as nitrate pollution from farms is, in his opinion, likely to be decreasing – water companies are much more likely to cause problems.

‘I mean there’s bad eggs in every industry but generally speaking the countryside has been well managed by farmers for generations and generations and I don’t see the need for forcing farmers down the route of vast increasing capital expenditure in most cases. Taken to its extreme it would put people out of business’.

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Farm No. 2 NVZ Status Partly inside

Organic Location Status Organic, Flintshire (inconversion)

Hectares

Produce

Details

290

400 dairy cows, Holstein. 80 ha maize grown plus 300 followers for feed

Farm Background Farm 2 is ‘in conversion’ to organic production, which the farmer hoped would achieve much better milk prices. This would necessitate a lower stocking density (currently 400 cows but this may go down to 250). Some cows were in the process of being sold (the breed, Holstein, may also not be ideal for organic production). Part of the farm is in an NVZ, but as the slurry storage is outside the area the rules about storage capacity do not apply, it is just the closed periods for spreading that are an issue. Slurry is currently spread rather than injected. Injection is being considered (so as to make better use of the nitrogen it contains), but this would require investment in new machinery (perhaps £100,000) or use of contractors. Dirty water is collected separately. Quite a bit of farmyard manure is also produced from young animals bedded on straw. Attitudes to NVZ The extra record keeping associated with being in an NVZ area was felt by this respondent to be not too arduous, as it is all needed for other inspections anyway. However, with part of the farm being in Wales and part being in England (some of his fields are actually in both countries), the farmer was of the opinion that there are unnecessary differences in the rules for each. It was noted that some problems blamed on agriculture are actually the result of sewage treatment. The farmer also felt that some of those enforcing the regulations do not understand them fully. In other countries the rules are not perceived to be so strictly enforced – one example given being Northern Ireland, where slurry is spread at night so that ‘nobody can see it being done’. Even in Wales it was said to be easy to overestimate the volume of a slurry store so that it looks as though it is compliant. The farmer explained that sometimes grants towards the cost of improving infrastructure are not all that helpful because of all the extra conditions that are laid down when you accept them. Regarding the logistics of adhering to NVZ regulations should the area be extended to cover the whole farm, a perceived problem would be the short window of spreading between the end of the closed period and establishment of the maize; it takes an hour per load to transport and spread it because of the distance to the fields.

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Becoming organic means that it is more important that use is made of the manure, rather than it being a waste product; it will introduce complications, as it will no longer be possible to spread it on non-organic land.

‘Why tear your hair out objecting something you can do nothing about?’

Farm No. 3 NVZ Status

Organic Status

Location

Hectares

Produce

Inside

Nonorganic

Flintshire

101

Beef (50 suckler cows plus 50 Holstein. 80ha yearling cattle); sheep (650 maize grown for ewes plus followers) feed

Details

Farm Background Previously a dairy farm but that was not profitable so changed to beef (mixed continental breeds) and sheep fifteen years ago. This means that most of the NVZ rules do not apply, as slurry is not produced, only solid manure - which is kept in a covered slurry store. Attitudes to NVZ

‘The idea seems sensible but the regulations don’t take away the bad farmers’.

This farmer voiced a personal frustration with Welsh Water. He felt that they should be able to identify specific problems and deal with the farmer in question, rather than treating everyone as though they are guilty. For him, the record keeping is particularly arduous and disproportional for an extensive beef enterprise with only solid manure and plenty of storage. In addition, there is no feedback to say if pollution levels have dropped or increased. Moreover, he felt that the justification for imposing an NVZ in the current location (rather than on the nearby low lying wet land) has not been clearly explained. A suggestion from this farmer was: ‘Why not restrict the amount of fertiliser that can be bought’. By doing so, he reasoned, then it would not be possible to over apply it and no paperwork would be needed. It was noted that the audit trail associated with NVZ designation would be easier to accommodate on a

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large farm that can employ a secretary. Currently the same work is expected from a small part time farmer. The farmer cautioned that setting a date before which slurry cannot be spread will just result in over-application immediately afterwards.

‘It’s the bad famers that cause the trouble – the good farmers adhere to the legislation and, in my eyes have to fill in a ridiculous amount of paperwork. I didn’t become a farmer to sit in front of a computer’.

Farm No. 4 NVZ Status

Organic Location Status

Outside

Nonorganic

Hectares

Flintshire 140

Produce

Details

Dairy (300 cows plus 190 followers)

Cross-bred Jerseys. Purely dairy using the New Zealand System1 since 2001; milk is used for cheese.

1

An extensively grazed system, where the cows spend the majority of the year outdoors and are likely be out wintered in all weather conditions

Farm Background On this farm calving is in spring (February onwards) and grazing outside until November, so the herd are only totally housed in December and January. This extensive ‘New Zealand System’ has very low inputs and the cows are milked only once a day. In the winter stock are kept in open-air cubicles on this farm. This is partly for welfare reasons, but roofing them over would also be expensive, although it would reduce the amount of slurry produced. There is a small slurry pit, which reportedly fills up quite quickly with rainwater. The slurry has approximately 2% dry matter most of the time and is spread, by a contractor, with trailing shoe umbilical system. This system, it was noted, would be harder to run with higher dry matter (which would result from roofing over the cubicles), although the volume would be less. Injection has been tried but it tended to damage the grass. There is some farmyard manure produced from the young stock (heifers) bedded on straw. Male calves are sold on straight after birth (e.g. for boxed veal). Only grass is grown on the farm, fertilised with low levels of synthetic fertilisers (mainly ammonium nitrate rather than urea). Relying on clover has proved problematic for this farmer because there is not enough growth in the spring. Maize used to be grown but not anymore. The cows are milked once a day (4000 litres/year per cow but with very high solids). Very few concentrates are used (and never in the winter when the cows are dry), so the main input is fertiliser rather than feed,

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although some silage is bought in. In a dry year silage has to be fed to the cows in summer. The cows are usually kept for five lactations and then sold on for milking on other farms, usually because they have fallen out of the calving pattern. Attitudes to NVZ The farm is just outside the current NVZ boundary. A lot of the current rules are regarded by this farming family to be impractical. Contractors, for example, will have to spread all the slurry within the legal period, regardless of the suitability of the conditions. The two interviewees (male and female) also felt that farmers are unfairly blamed for problems caused by sewage works. Although the New Zealand system, which is used on this farm, is not intensive with low inputs, it is important that the grass is kept growing for as long as possible. This may be difficult with the restrictions on when fertiliser and slurry can be applied.

‘We are not causing the problem. It’s the sewage works pumping into the river. That is an argument I’ve heard from several people, not just locally but from other parts of the country.’

Farm No. 5 NVZ Status Organic Location Status Outside Non-organic, Flintshire but low input

Hectares

Produce

Details

14

7 beef cows

Hereford cross. Permanent grass, with clover, no fertiliser inputs. Wintered on silage. No concentrates.

Farm Background This farm is essentially organic, but not officially certified. Only solid manure is produced. In the winter the cows are fed on silage or haylage, baled by a contractor. No concentrates are used. Attitudes to NVZ This farmer reported that it is easy for this farm to comply with the regulations since, due to it being akin to organic; there is no slurry or use of fertilisers. The paperwork has not proved arduous, but it was noted that most farmers would not welcome the restrictions on their management decisions. However,

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environmental controls are important with modern farming practices - having so many animals in one place creates a big risk of pollution. Some farmers, we were told, are cavalier in what they do. For this farmer, information about NVZs has been adequate, with opportunities to ring up for more information if necessary.

‘In a perfect world there wouldn’t be a need to do this, but it’s not a perfect world. You have to take measures to correct the problems.’

Farm No. 6 NVZ Status

Organic Status

Location

Outside

Organic

Pembrokeshire 340

Hectares

Produce

Details

400 cows plus 235 heifers.

Hereford cross. Permanent grass, with clover, no fertiliser inputs. Wintered on silage. No concentrates.

Farm Background The farm is almost all grass (except some turnips and whole crop silage). Organic conversion began in 2006. It was noted that there are probably more organic farmers in the area than in the country as a whole. The cows mainly calve in the autumn with just a few in the spring. This suits the farm because the summers can be dry with grass in relatively short supply – which matters less if the cows are at the end of their lactations. The milk is exported and sold according to the USA organic standards, which prohibit the use of antibiotics. If antibiotics are necessary the affected cows are split into a separate small herd. The limit of 170kg organic manure N per ha is a constant consideration (both as an NVZ and an organic standard regulation). As well as on-farm manure, 1000t organic poultry manure is bought in and composted before spreading. There has been considerable investment in slurry storage (approximately £24,000), enough to go all winter without the need to spread it. Fortunately the ground where the storage area was located is impermeable, so there was no need to line the banks. Currently there is no roof over the store – it was estimated that this would have cost perhaps six times as much, with a questionable benefit. The store was installed because of the benefits it would bring to targeted fertiliser management within an organic system, rather than because of any regulations.

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Slurryis spread with a low trajectory spreader – injection was tried, but no benefit was seen in terms of crop utilisation. Anaerobic digestion of the slurry for energy generation is being considered, but there are problems with sufficient electrical connection. Attitudes to NVZ The farmer considered that if the farm were put in an NVZ then few extra changes would be needed – most of the rules and record keeping are in line with the organic regulations anyway. The farmer was unclear with regard to what the possible increase in NVZs is supposed to achieve and questioned whether it was just so that Wales does not look negligent in comparison with England. NVZs, he warned, may just displace the pollution – increasing application rates on the land just outside them, possibly in turn affecting bathing water quality, which could have an effect on tourism. The construction of new slurry stores, he noted, should not be a problem with regard to planning as a ‘toolkit’ has been developed by the Environment Agency, Pembrokeshire planners and the farming unions. Sometimes, however, being located in the National Park can be an issue. Concern was expressed that some local farms have a very small land base in comparison with their stock numbers, meaning that if NVZs were increased they would become reliant on exporting their slurry to other adjacent farms.

‘I do worry that the next generation of [Regulatory] Officers tend to be more by the book and they come at it from a very environmental perspective rather than an agricultural perspective and there will be a changing of the guard and some of that sort of good will if you like, between the farming community and the regulators may be lost.’

Farm No. 7 NVZ Status

Organic Status

Outside

Conventional Pembrokeshire 96

Location

Hectares

Produce

Details

Beef (70 suckler cows Some land rented plus 70 young stock) for potato growing

Farm Background A dairy farm until earlier this year, now converted to suckler beef production using the same cows (reduced in number from 100 to 70). The calves will be sold as yearlings for finishing. As a result much less slurry is produced, although there is still rain run-off from the yard. The slurry is spread rather than injected, because this is cheaper. It may now be possible to keep the cows grazing for a little longer but ________________________________________________________________________________________________________ CAWR, Coventry University (2017) – Researching Farmer Perspectives on NVZs in Wales Page 26


probably not very different. The farm is predominantly grassland, regularly reseeded with clover included in the mix, but nitrogen fertilisers used as well. Attitudes to NVZ This farming family (male and female interviewees) did not have a detailed knowledge of the restrictions that could be enforced if their farm were to be included in an NVZ. They felt that very little information had been provided by NRW. The farmers expressed concern that heavy rain could fall outside the closed periods, making fixed dates illogical and they also noted conflicting advice from vets – they recommended spreading slurry outside the grazing period to minimise health issues. Much of the nitrate pollution, one interviewee suggested, is likely to come from non-farm sources. ‘Within less than a mile anything off our fields is into the estuary and I can make a very good case that there’s more stuff comes upstream (when the tide comes in) than there is going down’.

‘My biggest concern would be that window of no spreading […] I think it would be counterproductive and very expensive for a lot of people.’

Farm No. 8 NVZ Status

Organic Status

Outside

Conventional Pembrokeshire 850

Location

Hectares

Produce

Details

Dairy (1600 cows plus 1300 young stock replacements, 4500 winter grazing sheep, cereals)

1600 Friesian cows, milked 3 times a day, by farm staff rather than robots. Average milk yield 11,000 litres/cow.

Farm Background The cows are inside all the time, bedded on ‘cosy mattresses’ with wood shavings or oat husks on top to absorb moisture. Hydrated lime is put down between the cubicles to reduce the risk of mastitis. Young stock are bedded on straw. Slurry is pumped around the farm and stored in two large lagoons. It is spread using a trailing shoe as injection is not regarded suitable. An anaerobic digester (AD) is currently being constructed to process the slurry plus additional crops grown specifically for it (not food waste though). This will result in a more consistent product for spreading. Clover is no longer included in the

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leys, because they have to be sprayed to control the docks. Because of the price, nitrogen fertiliser is now used much more sparingly. Attitudes to NVZs ‘Where is the evidence that NVZs are needed?’ this farmer asked – ‘fertiliser consumption on most farms has dropped dramatically so there must be less of a problem now!’ For him, farmers are being unnecessarily blamed for pollution caused by others – they are ‘easy pickings’. Expanding slurry pits has to go through planning -something, which he felt, both takes time and will be impossible for lots of farmers to do all at once in any expanded NVZ. For him, NVZs could be the ‘last straw’, which, together with other issues, will drive farms out of business. On this farm slurry storage would be sufficient to comply with the regulations as a lot of investment has already been made. Fortunately for this farmer the slurry lagoons could be dug out with earth banks – on other farms, he cautioned, they would have to be more expensive due to the need for concrete walls.

‘We are quite frightened by it to be honest with you. I will go as far as to say it will close all the dairy farms, if this is implemented it will close a lot of businesses down, without a doubt.’

5. Regulator and Farm Industry Representative Case Studies Qualitative semi-structured research interviews were conducted with regulators and other relevant farm industry representatives. The guiding questions were designed to secure an extended understanding of how NVZs are managed by such stakeholders at both an all-Wales and farm level. Drawing on their experience to date, the interviews also enabled respondents to discuss, in-depth, their views on any potential future expansion of the NVZ area in Wales – including in a post-Brexit era. All interviews were conducted in English. Set out below, for each interviewee in turn, is a short contextual summary of the interview’s role together with an overview of the responses they provided.

Environment Officer, NRW Role The officer’s role is to provide advice, guidance and regulation of farms and waste sites, waste management facilities including sheep farms, dairy farms, AD plants or biowaste sites, composting and

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MERSE (materials recycling facilities). This covers the entire southwest of Wales - a relatively large geographical area. Monitoring Incidents Although NRW have passive monitors, 99% of incidents, the environmental officer estimated, will be reported by people seeing slurry going into the river. In most instances, if an incident was notreported, it would not be discovered. Moreover, by the time an issue is picked up via such an approach, it can be difficult to trace back to source. For the future, it was suggested that passive, remote monitoring could be one of the ways to go, especially if NRW looking at staff reductions and budget restraints. Real-time monitoring on flood defence assets already exists. Communication and Relationships The Officer felt that the best form of communication is the development of direct relationships with individual farmers. This wouldn’t be an option, however, if the size of the NVZ is significantly increased, because it would not be possible to get to everyone. The proposed new NVZs could include 1,500 farms which would need more trained staff, preferably with an agricultural background. Many staff, the officer noted, come from an environmental science rather than a farming background. This officer is of the opinion that some agricultural experience would be a considerable advantage. In current NVZs, from a regulation point of view, there is very little enforcement work to be done because it is managed through face-to-face relationships which have been very successful. Bespoke Permits Large chicken farms and large pig farms have an environmental permit, very similar to the waste industry. A similar permit based system, this officer explained, has previously been considered for dairy farms. Dairy farms already operate within SSAFO regulations with regard to slurry and silage clamps ‘But there is some suggestion that maybe they should have permits from NRW’ A permit to operate would, for example, cover times and dates when you could spread, conditions for storing slurry, conditions for storing silage liquor, liquid feeds, fertilisers etc. at a farm level. Large chicken and pig farms, it was noted, operate more like a factory, with considerable investment in infrastructure and tightly regulated operations. In contrast, the dairy industry, although said to be

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improving, is nevertheless felt to be of greater risk to the rivers, and ground water etc. from the large amount of slurry that is produced. In Pembrokeshire and West Carmarthenshire, it was noted, this includes units with more than 1,000 cows. A permit system for the dairy industry would work on a penalty basis: ‘It would work by scoring the farmers if they’re found to be failing on certain things, then their subscription fee increases – it’s a penalty.’ A perceived potential risk with such an approach, however, is that farmers may then factor in how many penaltiesthey can afford: ‘[the cost] could be planned in plus the chances of an officer visiting are quite slim. One visit in, perhaps, every 5 years by which time the farmer will have made more than enough money to cover any penalty – just write it off as a tax’.

‘NRW would want the farmers to generate their options themselves, so they have ownership of it.’

Regulation Forcing Poor Practice As a consequence of there being dates when it is not legal to spread manure (due to NVZ or SSAFO), we were told that on the dates when it is possible, ‘it all goes out’. It has to be spread because storage isn’t sufficient.

‘So the first day, hell or high water, raining or whatever, it’s going out.’

Accordingly, restriction dates only protect for a set period, with the fallout occurring the following week. This calendar system also raises odour issues and other problems. As the officer explained, watercourse pollution caused by slurry is very visible: “you can see them, bang, identified, boom, green frothy rivers, and farmer spread is very easy. You can see it!” By contrast a lot of outputs from heavy industry - “chemicals, certainly aerial emissions which are perhaps more detrimental than agricultural ones to human health anyway” - cannot be seen and therefore are not reported as much by members of the public. Education Slurry is considered by this officer to be the main issue, primarily because on most farms it is still treated as a waste, with the drive being to empty the slurry store as quick as possible. By contrast, because artificial fertilisers cost money, farmers are less likely to waste them. Accordingly, the education route

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adopted by this officer and the Catchment Sensitive Farming Officers has been to encourage farmers to compare and contrast the two. That is, the fertiliser benefits from using slurry and the costs of fertilisers. However, farmers are still found to be unaware of the benefit to using slurry wisely - “rather than getting it out as soon as possible, regardless of the lands P and K loading indices”.

‘Regulation does change practice but I think the solution ultimately although it’s going to be long-term, it’s changing the attitudes of farms and that probably starts in colleges, universities.’

Also problematic, is the delay in the effect of leaching coming into the water: “It could be a month, it could be a thousand years, so the impact is difficult to measure”. This in turn makes it very hard to attribute a pollution incident to one farm. Grant Schemes One suggestion made by this officer is to introduce a grant scheme to help farmers improve slurry storage. This would essentially be a repeat of a grant scheme that was in place some 25 years ago. Indeed, this is also the reason for so many slurry stores currently reaching an end-of-life point. The previous scheme, which had been funded by the CAP, operated on a kind of like-for-like match funding basis. The concern was raised, however, that the current planning system risks working against such a scheme: “Certainly National Parks don’t want a slurry tank. So NRW has had issues, where planners have decided against the slurry tank that the farmer needs to be NVZ compliant”. Riparian Strips

‘NRW could advise farmers to plant riparian woodland on the main and smaller rivers. It improves everything; river banks are stabilised, water is cooled and slows down, it’s better for fish, it reduces soil loss and run-off from fertilisers and slurries.’

A second suggestion was to require of farms that they establish riparian strips. Glastir, it was noted, operates this already, but it would need to be spread across Wales. A notable additional benefit with this method was felt to be the parallel improvements it would bring by way of improving access, riverside walks, increased biodiversity etc.

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Glastir to Manage NVZs

‘Personally, I would combine NVZs and Glastir, it’s got to be simple.’

Currently, this officer explained, NRW spend a lot of money on regulation of both the NVZ and Glastir schemes. If, however, money was spent on infrastructural improvements, once that infrastructure is in place, it doesn’t require regulation (e.g. a new slurry store). Also, if the balance of the Glastir Scheme could be moved more towards the offering of advice and guidance, and less on regulation then this would be more manageable. By combining the Glastir and NVZ at an all-Wales scale, every farmer would then be in the same position: “not one field in and one field being out, all farmers would be the same, all of them would have to improve their slurry management, and all of them would have to give a bit more thought”.

NVZ Officers, NRW Role Two officers were jointly interviewed. The officers advise on the Pembrokeshire NVZ, a small catchment of around 1,600 ha which includes 15 farmers. At the time of interview, the Officers had just submitted evidence to the Welsh Government to have another NVZ with 1500 farms in it which would incur ‘massive, massive change’. Future Generations Act The officers explained how the Future Generations Act (Wales) provides seven goals, which every public body must strive to meet. In it, the resilience of Wales means resilience of the eco-systems, but it also means a prosperous Wales. Hence, nothing must decline, as has also been written into the Environment Act (Wales). So, as one officer then noted, whatever happens with regulations that have their basis in Europe, ‘we’ve actually got something which says that, fundamentally, the scientific standard or the abundance of things cannot decline’. In practice this also means that NRW especially, but also all public bodies, have ‘extra duties’ of care.

‘The Future Generations Act also provides that NRW work in a particular way, that NRW must take a long-term view of things and that NRW must work in a

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collaborative, integrated way; NRW have to try and solve problems before they arise. We want a thriving agricultural industry, NRW don’t just want to regulate it. NRW want it to thrive’.

Unintended Consequences of Regulation The Officers noted that from the very first year of the Bosherston NVZ being in place, farmers had started out-wintering stock more. This was done in order to compensate for the fact that they did not have quite have enough slurry storage space: ‘Farmers are out-wintering stock on the MOD range and that change has led to an environment detriment’. As a result, conditions were felt to be getting worse in one of the streams, with the soil breaking down: “Farmers are complying with what they have to do but it’s still ending up in the stream”. Movement of Slurry and Impact on Tourism The other reported consequence of NVZs is that farmers are moving the slurry out of the controlled area – an issue which is expected only to increase should the NVZ area not be extended to all of Wales. As was noted, the danger if farmers export slurry out, is the potential for it to be above the bathing beaches where there is ‘really, really hard, very, very tight control’. As one officer went on to explain, this creates a very real risk that all the work and achievement in recent years of raising the quality of bathing beaches, to ‘excellent’, will be undone. The impact of this would not only be felt by the tourism industry, but also by public health. Risk Based Approach It was suggested by the officers that, in order to manage any future increase in the NVZ area,NRW would need to employ a risk based approach: ‘So you wouldn’t be doing the small holdings you would obviously start on your big dairies on river stretches that are not so good - high impact farms’.In accordance with this it was suggested that, NRW could develop a farm operator risk assessment - based (for example), on the number of cows, whether the current water quality of the river, and whether the farmer is a known offender etc. Currently officers within NRW are encouraging farmers to undertake water management reports and nutrient management reports capable of: “looking at the bigger picture; not, you haven’t got enough slurry storage”. They are also assessing the need for requiring farmers to have emergency plans for wetter than average winters. As an illustration, this might include requiring farmers to identify sacrificial

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fields. The ambition here is “to do something [with] a bit more initiative than a straightforward inspection report that’s helpful to the farmer”.

‘I did a quarterly management plan for one farm and found that the farmer was putting on 394 kilogrammes of nitrogen per hectare. I advised that this was where he was going wrong and he mentioned that he also bought chemical fertilisers! However, this was what his granddad had done, this is what dad had done, so he was doing it. Now he measures the grass you know.’

Farming Acceptance of the Pollution Problem The officers acknowledged the challenge for some farmers of accepting that a pollution incident may have been caused by their own practice: “I think farmers find it hard to accept that they’re the cause of the problem. They’ve certainly looked at our evidence report and what’s the role of phosphate, what’s the role of someone like DwrCymru with the sewage works and all those loadings, they really are looking at that. Our source apportionment would say it was over 98%”. However, they were also of the opinion that this was, in part at least, a generational issue:“Younger farmers are different especially if they went to Harper Adams or somewhere they’re definitely on board with the environment side of it, it is easier”.

Farmer Representative Organisations Role Interviews were undertaken with two farming industry representative organisations whose role, broadly, is to represent the interests of farmers and to offer advice on new regulations and their implementation, together with providing ongoing guidance as to what they need to do to comply with those regulations. Position on NVZs Respondents confirmed the experience of the NRW officers that, within the current NVZ area of Pembrokeshire, a lot more farmers out-winter their stock in order to try and meet the NVZ criteria. Also, because it’s such a small area, a lot of the farmers are exporting slurry to land that they hold outside of the designation. Accordingly, as was also raised by the NRW officers, the concern is that if the NVZ area is extended in Pembrokeshire exported slurry will then go to coastal areas not included within the designation.

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Planning and Practical Constraints Another issue, on which the views of the representative organisations accorded with those of the NRW officers, was planning. The interviewees acknowledged both the challenge for the planning system of potentially having to deal with multiple applications for slurry storage systems all at the same time, and linked to this, the fact that slurry systems “do tend to be a little bit controversial”. In Pembrokeshire, for example, we were told: “Incomers have this idealistic view as to how the countryside should be and not necessarily be a working countryside, which does then cause some problems. So planning authorities do find slurry systems difficult, very time consuming and complicated to deal with because there tends to be some objections to any application”. Bovine Tuberculosis (bTB) Of significance in the context of Pembrokeshire, is the presence of TB associated farm-level movement restrictions in the event of outbreaks, impacts on the amount of stock that are retained on some farms. In many cases, it results in larger herd sizes than may otherwise be optimal for the farm infrastructure to manage. Also, dairy herds are often housed for at least part of the year. This, it was noted, produces a lot of slurry from large dairy sheds, but often without there being an equivalent area of on-farm grassland for it to be spread on. In order to manage this, farmers instead look to export the slurry. However, there is an economic cost involved in doing so, whilst in the case of those farm holdings under TB restriction, tight regulations on slurry movement are maintained: “even if it’s been stored for 5 months that’s still doesn’t get around TB. There is some suggestion that it could be stored for 6 months, but that would require most farms to have two slurry pits”. Alternatives or Additions to NVZs A respondent provided details of a previous NRW project as an illustration of the possibility for designing alternatives to NVZs. The NRW project was with First Milk and focused around waste products from the factory for which there was no capacity for NRW to issue a consent for discharge into the watercourse. Instead, NRW set about advising First Milk on how to reduce their nitrate levels which would allow NRW to issue a discharge consent. A similar approach was then extended as a means of working with the local dairy farmers supplying First Milk. This included advising a local group of farmers on “simple things”,including “recalibrating fertiliser spreaders, looking at clean/dirty water separation, when to put slurry out […] soil testing and other things”, some of which, as this respondent also noted

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were at very little cost, or requiring very little involvement from others. They put a package together with each farmer, with the group in turn then agreeing on “what level of nitrates each farmer was going to take out of the watercourse”. The project was a success, resulting in NRW being able to issue a license to First Milk to be able to discharge into the watercourse. In addition, a lot of farmers also reportedly saw the financial benefit. “We’ve done some work with the local NRW Staff to actually look what lessons have been learnt that could be introduced as part of the regulations, but to actually make it a sort more of voluntary approach. Each farm could have an agreement as to what suite of measures they would do. There would still be a closed period […] between October and the end of January.” Due, however, to the way in which the current NVZ regulations are set up, such an alternative approach is not permissible. This, despite the fact, as this respondent concluded: “They can actually see that it would have a much bigger benefit than just putting the regulations in place because it would also be dealing with phosphate issues, they would be less likely to see the increase in phosphates that they are seeing.” It is also for this reason that the one of these respondents put forward, as part of the 2016 all-Wales NVZ consultation, the need for further consideration of alternative options – options which may well deliver better results environmentally, at the same time as being “more practical and cost effective for the farm as well”. The Nitrate Problem Although some is attributed to sewage outlets and industrial use on the Haven waterway, with there being no heavy industry in the area the bulk is said to come from agricultural sources. Within agriculture, the respondent explained, the source of the problem is predominantly going to be slurry produced in dairy farming: “It’s going to be due to slurry, there will be some run-off from arable practice as well, but the biggest main contributor to it generally is going to be the slurry”. In parallel to addressing the problem through research-based innovations - including, for example, current studies into the production of a crystallised form of nitrate from the slurry as a means to reducing overall nitrate levels - respondents also noted a series of farm-level actions. In particular, slurry pits were identified as a key issue, with a related problem being the need for ways of preventing clean water getting into pits.

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‘Clean/ dirty water separation can be a big issue, but it can come down to guttering. So there are some fairly low-cost solutions for some that will help enormously.’

Alongside also “scraping the yard more frequently”, it was suggested that farmers could “end up with a lower nitrate value in their slurry if they are not putting in as much as high-value feed into the animal”. The difficulty, however, with the latter is that this may in turn not produce the quality of milk needed to fulfil contracts. The respondent concluded that “realistically the vast majority of people will need a financial investment”. The Responsibility of Supermarkets A respondent explained that supermarkets do not get involved for the most part with issues of nitrate pollution. Rather, their focus and also that of the processor, is the ability of a farmer to meet their contract: “From the processors point of view they have a contract with the farmer to produce. If the farmer can’t meet the contract, the super market will look at alternatives, the problem we’ve got at the moment is that we are in the middle of a supply situation. So they do have the option to shop about a little bit. If the milk isn’t quite up to the standard that they want, they will take it but they will take at a lower price. Which then becomes less sustainable for the farmer to be able to continue”. Good points of NVZs

‘There is no data to suggest that its improved water quality, which is a big frustration. But to be honest for a lot of it’s just been a big headache, from a cost perspective, from an additional paperwork perspective.’

Respondents noted that a perceived positive impact of the NVZs is that “it has got farmers to think a little bit more about what they do, to review practices and to see if there are alternatives options”. At the same time, however, many of the affected farmers were felt to be “preparing for the worst as far as the current regulation stands”. The respondents, in accordance with the perceived wishes of the farming industry, are therefore encouraging the Welsh Government to consider alternative options. Examples were given here of successful such alternatives, including one between farmers and the Rivers Trust, undertaken to improve watercourses and water quality, for the benefit of both the livestock and the waterways.

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A respondent expressed concern that the affected farmers view the NVZ as a blanket designation, which will ‘hit them really hard’ without achieving anything: “But actually what is it going to achieve and are there better ways to actually look at this? You know whether it be working in partnership or even doing something under a regulatory basis that’s still sort of looking at an individual farm rather than just blanket across the board”. The illustration was given of the failure of the NVZ closed period dates to take into account climate differences, which result in earlier growing seasons for some: “So actually the plants could be taking in nitrogen, or we have a longer growing season so they’re still taking up the nitrates so it’s things like that so they can be quite frustrating”. An alternative approach is needed which is both more farm specific and more sensitive to individual farming practices, including where relevant, the cases in which farmers are already using precision farming techniques. Intergenerational Differences A respondent acknowledged that while the younger generation, are often “really good and really keen on new ideas”, others, including members of the older generation, “take a little bit more persuasion”: “the relationship between different generations can still be challenging”. Nevertheless, they were also of the opinion, based on their experience to date, that overall farmers remained “open to new ideas”: “if it can be shown that something works, you need a couple of people that are brave enough to maybe do it to start off with. But once they actually see that these are working, even the contractors are using them, then they may move forward”.

‘Having staff on the ground to be able to provide that advice is crucial.’

The same respondent also noted the importance of being able to provide farmers with sufficient support. This was said to be particularly relevant in the context of the planning process. Moreover, because NRW are statutory consultants in the planning process, “having them on board at the start”, as the respondent explained, “can be a lot more cost effective than bringing [them] in part way through”. To receive the necessary support, however, an additional anticipated consequence of the NVZ extension will be an increase in the number of farmers incurring further expenses through contracting of consultants.

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The Impact of Brexit The respondents were of the impression that some farmers believe that when Wales leaves the EU, they will no longer need to adhere to a nitrates directive. Whilst the representative organisations are already aware of the continuation of all EU regulations as UK legislation (with the current plan to transfer all EU law into UK law via a Great Reform Act and then change them one-by-one in parliament), there still exists the possibility for subsequently changing UK regulation through parliament if this does not affect trade agreements or international law (e.g. protecting the sea from pollution).The management of slurry was given as one such case: “I think there’s a lot of people are quite keen on looking at some of this research looking at alternative options with slurry. How to make the most of it, to potentially reduce costs and artificial fertiliser application.” However, this can be done already under current EU and UK law. Realistically, overall, even a small change to the nitrate directive is unlikely once the UK is outside of the EU.As there are common European water bodies like the Irish Sea, or the Channel, EU law will continue to define their protection from pollution.

‘With all that is happening in Europe, it is unclear what WG will do next. That’s quite frustrating for farmers because they’ve been made aware that this was likely to happen. So there this big black cloud on the horizon that will have an enormous impact on their businesses but they’ve still got no decisions on it. This is massive when planning a herd particularly with the state of milk prices and things as they are.’

The Impact of Increased NVZs on NRW Respondents expressed concern that, for practical reasons, NRW may not be able to deal with the proposed NVZ expansion. They also questioned whether the focus should be on watercourses where nitrate levels are showing increasing trends, rather than on those with reasonably healthy and constant watercourse nitrate levels. One of the perceived challenges, as a respondent noted, was the long time period for which watercourses had to be monitored in order to observe changes in levels. Rural Development Programmes Noting the experience with the first round of sustainable production grants, in which there were’some 400 applications, but only 12 farmers eventually accepted on to the scheme’ one of the respondentsnoted that, if the scheme is to be run again,“Farmers will ask is it really going to be worth our while to apply”.They also raised concern over the “whole extra layer of bureaucracy” imposed by the

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sustainable production grants with regard to documenting of slurry storage practice which may also result in farmers being put off applying. Views on NVZs

‘[We] would like to see a voluntary approach, actually working with the industry, a bespoke approach for each farm. Because every farm is different.’

Respondents from the farming representative organisations called for the need for closer working between regulators and individual farmers – “and not just tackling the easy ones but also tackling the difficult ones”. The level of investment required to achieve this, whilst acknowledged, was felt to be worthwhile given the benefits to both the environment and the industry that it would secure. One respondent also gave an illustration of how this might work in practice: “Each farm they would have a bespoke agreement that both parties would sign up to. So the farmer would sign up to it […]. It would be a binding agreement if they didn’t abide by it than they would have to look at alternative options and you know potential sort of sanctions against those individuals. But at least it would be more bespoke to that individual rather than trying to fit everybody into a small list of criteria, which inevitably is never going to work and is always going to provide issues, and not necessarily give you the benefits that you’re looking for at the end of the day”. The same respondent also noted the consistency between such an approach and the broader remit of NRW: “part of what NRW was now supposed to be is to do with natural resource management, it’s not just to do with regulations and hitting people with a stick because they have done something wrong. They are supposed to look at the wider issues of natural resources and how they are actually managed and try to get the best protection. The ethos behind NRW is that it is actually to be looking at management of natural resources not just what the regulations state and implementing those regulations”. “Wales have suffered a sustained period of low prices in dairy sector; more legislation leaves farmers feeling overwhelmed with the prospect. We’ve been working with NRW, and Welsh farmers, and the key area of concern is trying to assess impact and costs, of designation and the programme. We are really worried about the impact”. The respondents raised concern regarding a lack of commitment to riparian strips, and to the perceived failure to deploy the Wales RDP fund.

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6. Discussion and Conclusions Managing nitrogen flows into water bodies through regulation via the Nitrates Directive clearly faces many challenges. Even where farmers are fully cognisant of the legislation they doubt its effectiveness in terms of nitrates reduction in water bodies. At the same time they fear the impact of designation on their finances and resent both the intrusion on their everyday management practices and the increased bureaucracy. Reducing nitrates in water bodies cannot be achieved without farmer co-operation. Regulation may not achieve this co-operation, and the attempt could be costly and unmanageable especially as the regulator, NRW, is currently decreasing its staffing levels due to on-going budget constraints. Also, Brexit will provide an additional burden of work for Welsh Government and uncertainty regarding the unknowns of EU Exit, which may prove to be a further encumbrance during the planned NVZ rezonation. Overall the problem is one of an increased nitrogen use in Wales, especially in conventional farming systems. The stocking density of animals all over Wales has increased (as one way to remain profitable), but this increased livestock is fed from imported arable feed (with means nitrogen import) and with

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grass and fodder produced with extra artificial N fertiliser. All this extra nitrogen is building up over time, and a large proportion is evidently lost to watercourses and the Irish Sea. If the input of nitrogen could be limited across Wales (less feed and straw imports, all artificial nitrogen fertiliser being replaced by organic fertilisers and AD-digestate from Welsh production), then the overall nitrogen leaching and pollution level would slowly reduce. This would transition Welsh farming from a ‘high input-low price’ economy to a ‘low input-slightly higher’ price economy, which would ultimately be more profitable for farming and the country as a whole. Academic research has cast some questions as to how much NVZs can improve water quality. For instance, Worrall et al. (2009) in their investigations of English NVZs, found that 69% of NVZs showed no significant improvement in surface water concentrations of nitrates after 15 years. Importantly for the Welsh context, differences between NVZs could not be significantly related to the size of the NVZ, uptake of the scheme, extent of uptake, land use change or geology of the local aquifer. The effectiveness of action programmes within NVZs in other countries has also been called into question (Durkowski and Jarnuszewski; 2015). However, Macgregor and Warren (2016) found that NVZ regulations, have affected farmer attitudes and management of their farm, such that significant improvements in surface water quality were found. In either case, it is evident that many farmers appear to have real doubts and fears regarding this legislation. What is also clear is that there is an increasing awareness of the impact of farming on the environment and the validity of more sustainable techniques. With this in mind, regulators favour the development of a permit based system where farmers are encouraged to develop mitigation strategies, appropriate for their farm and for the level of risk of nitrate contamination in nearby watercourses. This inclusive approach would require a far more sensitive nitrates monitoring system, in order to identify high-risk watercourses and a focus on high-risk farming practices – such as dairy. This would allow NRW to focus its resources to limit the impact of high-risk practices and events. It would also allow NRW staff to develop the relationships with farmers that are critical to the success of any nitrate mitigation measure. In conclusion, we found the following common threads and ideas in farmers’ perspectives on NVZs: 1. The fear of NVZ regulation is currently mixed with Brexit uncertainties and a general squeeze in farm profitability in Wales, especially when supplying conventional markets. 2. Organic farmers are comfortable with NVZ regulations as organic certification is seen very much in line with NVZ regulation. They still do not like regulation, but they know the impact will be limited; if anything, grants for further investments would be positive development.

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3. Owners of smaller and extensive farms (beef, sheep) are less concerned, as they know they can meet the NVZ regulation. However, they too do not like over-regulation and paperwork. Since they are small, they have no staff to deal with administration. 4. Dairy farmers are likely to suffer a disproportional impact due to the amount of slurry produced and lack of land to spread to. Hence they will need to invest in SAFO acceptable slurry pits which, for some dairy farmers, may involve considerable expenditure for which there will be no remuneration. 5. Consideration should be given to a grant scheme to cover all or some of the investment required to meet NVZ regulation, with the proviso that famers also consent to a bespoke permitting scheme. The requirements of the permit would be developed on an individual basis, between NRW and farmers, to understand the risks and achievable mitigations for that business in that location and develop an appropriate plan. This should achieve good buy-in from farmers and help develop relationships with NRW staff, which are going to be crucial going forward. 6. Farmers are, in general, not convinced that if NVZ are increased, or 100% NVZ Wales is introduced, this would benefit water quality short and long-term. They want to see the evidence and they what to be convinced by the government this is necessary. This information and/ or trust in its accuracy is currently not present, even if the information is independently monitored and sent out in good faith. The government should reconsider how to connect with farmers so that information, messages and dialog are received not issued. 7. All farmers also want to see the role of farming considered alongside other polluters of watercourses. Farmers point to successes like reduced artificial N fertiliser application rates over the last decades and increase of agroecological and organic farming practices and they want to be credited for those improvements by government. They also want encouragement for the services to the environment they are already doing (within or outside existing environmental schemes). The Government should present any measures to reduce pollution as a package, where every industry does its fair share. 8. Given the increase in the number of farms that are likely to fall under NVZ auspices, and the reduction in NRW staff currently underway, a risk based approach to identifying high polluting farms and their proximity to sensitive watercourses is vital. This approach would include criteria such as farm type (dairy, arable etc.), stocking rates, proximity to watercourses including the sea, topography etc. It could be deployed throughout Wales ensuring an equitable restriction, where necessary, on all farmers. This would mean that all farmers would have to be made aware of the impact of nitrate pollution and mitigation mechanisms, and that already stretched resources could target worst-case events as defined by risk based assessment criteria.

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7. Recommendations What we are advocating, as a result of the analysis and conclusions drawn from this study, is active and collaborative engagement with farmers by regulatory bodies. This requires the initiation of a cooperative process between all stakeholders, of solution development to prevent nitrate mismanagement in response to a far more robust and sensitive river monitoring system. We would also recommend further research in to the take up of an All Wales NVZ, as a simpler and more equitable approach. The current regulatory system and ‘Action Plan’ approach suffers from severe drawbacks. Much of this could potentially be addressed through a more bespoke and flexible permitting system. Such a system would afford farmers the opportunity to develop their own mitigation strategies - which, with increased buy-in, should both reduce nitrate emissions and reduce work for NRW staff, including by way of a reduced legal case load. However, in the absence of a more innovative and collaborative approach being pursued by the Welsh Government and NRW, overall we anticipate that major changes to the Nitrate Directive will be unlikely once the UK is outside of the EU. The Irish Sea and the English Channel are common European water bodies, and their protection from pollution, will still be defined by EU and international eniviromental law.

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The increased adoption of agroecological farming techniques (those which combine both agricultural and ecological parameters and drivers) can offer a long term route to the goal of reduced nitrates in water bodies (Wibbelmann et al., 2013). Such techniques could include becoming part of a bespoke permitting system and encompass: Farmer Driven Solutions 1. Grass/clover leys/cover crops and leguminous cash crops instead of commercial fertilisers. Buffer strips, riparian zones, reduced tillage, key-lineploughing, conture hedges, smaller field sizes, and more agroforesty to reduce surface errosion and run-off (See Udall, Rayns and Mansfield, 2014, for more information). 2. More diverse grass sward with reduced stocking rates (but less requirement for chemical inputs – both to animals as well as soils), which improves soils, reduces run-off and supplies own nitrogen. 3. Mixed farming – farms which combine both stock and arable creating a cycle to use the ‘waste’ of dairy/beef as a manure for arable/vegetable crops. 4. Covered stock sheds so that any slurry pits capture only slurry and not rainwater. Grants to put solar power on such shed roofs and grants for biowaste systems to use the slurry. 5. Canvas consumers and certification bodies (e.g. FAWL, SA), to make nitrogen friendly farming a requirement and something for which they are financially rewarded. 6. Seek assistance of well-established routes such as Farmers Weekly, Farmers Guardian, NFU Cymru, Farming Connect etc. to generate better communication strategies for the transition to agroecological farming techniques. 7. Use existing farmer advisory networks such as Glastir and Farming Connect, to develop and provide a free and independent service providing advice on sustainable farming techniques, including nitrates management. A highly farmer centric service, website and help line, with a hub of full time staff, but also a wider peripheral team working on a part time basis, who were e.g. farmers and farm secretaries, from different farm types and locations – such that highly pertinent and up-to-date advice can be offered, including support with completion of compulsory forms and developing bespoke permits. It is clear that future research, including further investigation of the implications of regulatory and governance frameworks on farmers and the farming industry and their perceived implications, is required.

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8. References Durkowski, T. and Jarnuszewski, G. (2015) ‘Changes in Quality of Surface and Ground Waters during Implementation of Nitrates Directive in Selected Agricultural River Basin of Western Pomerania’. InżynieriaEkologiczna 43, 122-130 Environment Agency (2012) Method Statement for Nitrate Vulnerable Zone Review – Eutrophic. Bristol: Environment Agency EU (1991) Council Directive 91/676/EEC Concerning the Protection of Waters Against Pollution Caused by Nitrates from Agricultural Sources [Act of Parliament]: EU European Commission (2016) Press release: Commission refers Germany to the Court of Justice of the EU over water pollution caused by nitrates. Brussels, 28 April 2016, http://europa.eu/rapid/pressrelease_IP-16-1453_en.htm Macgregor, C. J. and Warren, C. R. (2016) ‘Evaluating the Impacts of Nitrate Vulnerable Zones on the Environment and Farmers’ Practices: A Scottish Case Study’. Scottish Geographical Journal 132 (1), 1-20 NRW (2016) Recommendation for Nitrate Vulnerable Zone Designations: Consultation Document. Cardiff: Natural Resources Wales Pretty, J. N., Mason, C. F., Nedwell, D. B., Hine, R. E., Leaf, S., and Dils, R. (2003) ‘Environmental Costs of Freshwater Eutrophication in England and Wales’. Environmental Science & Technology 37 (2), 201208 Udall, D., Rayns, F., and Mansfield, T. (2014) LIVING SOILS: A Call to Action. https://curve.coventry.ac.uk/open/items/5330b382-b61e-4ca6-9cef-a20c0b1cd63d/1/edn: Soil Association and the Centre for Agroecology, Water and Resilience (CAWR) at Coventry University Ward, M. H., deKok, T. M., Levallois, P., Brender, J., Gulis, G., Nolan, B. T., and Van Derslice, J. (2005) Workgroup Report: Drinking-Water Nitrate and Health—Recent Findings and Research Needs [online] available from <https://www.ncbi.nlm.nih.gov/pmc/articles/PMC1310926/> [7/3/2017 2017] Welsh Government (2015) Well-being of Future Generations (Wales) Act [Act of Parliament] Cardiff: Wales Welsh Government (2016) Review of the Designated Areas and Action Programme to Tackle Nitrate Pollution in Wales. Consultation Document Number: WG27622. Cardiff: Welsh Government Wibbelmann, M., Schmutz, U., Wright, J., Udall, D., Rayns, F., Kneafsey, M., Trenchard, L., Bennett, J. and Lennartsson, M. (2013) Mainstreaming Agroecology: Implications for Global Food and Farming Systems. Centre for Agroecology and Food Security Discussion Paper. Coventry: Centre for Agroecology and Food Security. ISBN: 978-1-84600-0454 Worrall, F., Spencer, E., and Burt, T. P. (2009) The Effectiveness of Nitrate Vulnerable Zones for Limiting Surface Water Nitrate Concentrations [online]. Available from <http://www.sciencedirect.com/science/article/pii/S0022169409001152> WRC (2016) Ground Water Method Statement for Wales Nitrate Vulnerable Zone Review 2017: Report Reference: UC11236.04. Wiltshire: Natural Resources Wales WRCa (2016) Surface Water Method Statement for Wales Nitrate Vulnerable Zone Review 2017. Wiltshire: NRW

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Appendix A. Main requirements for farming within an NVZ. Livestock manure farm limit of 170kg total N per ha per calendar year. This includes all field depositions and applications (but is not concerned with the use of sludges, composts or industrial wastes. Calculations must follow a standard procedure related to the stocking density of various types of animals. Derogations to exceed this limit on grassland farms but this places additional restrictions on land use and requires extra record keeping. Crop nitrogen requirement limit. For each field records must show that the fertiliser and organic manure applications have been calculated according to crop demand (including assessments of the soil nitrogen supply), using standard procedures. Across the whole farm there are ‘N max’ limits for average fertiliser and organic manure nitrogen applications for certain crops (e.g. 220kg N/ha for winter wheat, 150kg N/ha for spring barley). For some crops N max can depend on the soil type and can sometimes be increased if high yields can be demonstrated historically. An important part of the calculations is determining the likely availability of N from manures (standard tables assume 40% availability from cattle slurry but only 10% availability from cattle FYM). Field-level limit for organic manure nitrogen. No more than 250kg total N/ha can be applied to any field in any rolling year. Higher application rates are permitted of compost with low N availability in certain situations (e.g. 1000kg N/ha can be applied as a surface mulch in orchards but only once every four years). Closed periods for spreading organic manures. Manures with a high N availability (e.g. slurry) cannot be spread during the winter. The exact dates depending on the soil type (sandy/shallow or other) and cropping (grassland or tillage), e.g. no spreading between 15th October and 31st January on all soils that are not sandy or shallow. Even after the end of the closed period application of slurry is limited to 30m3 at any one time every three weeks between the end of the closed period and the end of February. Closed periods for spreading fertiliser nitrogen. This is not permitted between 15th September and 15th January on grassland and 1st September to 15th January on arable crops (with certain exceptions when a need can be demonstrated e.g. for oil seed rape). Limits to where and how nitrogen is applied. For organic manures there must be a written risk assessment and risk map to show the areas suitable for spreading (i.e. not to steeply sloping land, not within 50m of a borehole and not within 10m of surface water). Fertiliser nitrogen should not be spread on steeply sloping land or within 2m of surface water. All spreading should be done as accurately as possible and not land that is waterlogged, flooded, frozen or snow covered. Poultry manure and slurry should be incorporated within 24 hours if applied to bare soil or stubble. Limits to storage of organic manures. Temporary field storage is permitted for materials that are solid enough to be stacked without giving rise to free drainage. This should not be near surface water or land drain or in a single position for more than 12 months. Manures with a high available nitrogen content must have specific storage capacities (6 months for pig slurry and poultry manure and 5 months for other livestock slurry). Record keeping. All records of manure applications etc. must be kept for five years, together with any written advice that guided management decisions (e.g. from a Fertiliser Advisors Certification Scheme member).

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Appendix B. The English version of the questionnaire sent out by Coventry University to Welsh farmers

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