DG Environment) Collection and Analysis of Data for the Control of Emissions from the Spreading of Manure

European Commission (DG Environment) Collection and Analysis of Data for the Control of Emissions from the Spreading of Manure

Final Report

6 January 2014

AMEC Environment & Infrastructure UK Limited in partnership with BIO Intelligence Service

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Document Revisions

No. Details Date

1 Final Report for client comment 3 July 2013

2 Updated Final Report 26 July 2013 incorporating new cost analysis

3 Revised Final Report taking into 25 September 2013 account client comments

4 Revised Final Report taking into 15 November 2013 account client comments

5 Final Report 20 December 2013

6 Revised Final Report 6 January 2014

© AMEC Environment & Infrastructure UK Limited 6 January 2014 S:\Projects\33280 PPAQ EC Manure Spreading\C Client\Reports\Revised Final Report (issue 2)\Issued Final\33280 Revised Final Report_20131220.docx

Executive Summary

Introduction

AMEC Environment and Infrastructure UK Limited („AMEC‟) in partnership with BIO Intelligence Service („BIO‟) were contracted by the Commission to undertake the following study: “Collection and analysis of data for the control of emissions from the spreading of manure” (contract number 070307/2012/635347/ENV.C3). This final report sets out the findings from the review of literature, consultation with Member States and the analysis of possible policy options for the control of emissions from the spreading of manure.

The overall objectives of this study were to provide support to the Commission for the collection and analysis of data concerning the control of emissions from the spreading of manure. A large volume of work has already been completed in this field and the aim was to build on this; supplementing it with further data to be gathered directly from the Member States. This consultation focused on those main gaps identified through the literature review.

Data Collection (Section 2)

In addition to a review of relevant literature and available datasets, all of the Member States were consulted and asked to complete a data collection proforma focusing primarily on any policies and measures in place at a national level targeted at reducing emissions to air and water from manure spreading. The approach taken and summary of responses received are provided in Section 2 of the report.

In addition to the above, modelling outputs produced to inform the review of the Thematic Strategy for Air Pollution (TSAP) were also provided by IIASA (from their GAINS model) for the agriculture sector.

Baseline Definition (Section 3)

Section 3 of the report presents the baseline for the study setting out the current situation in terms of manure production, environmental impacts, existing legislation and the current economic status. The aim was to define the current status of the livestock sector, focussing primarily on manure management, which could then be used as a starting point for assessing the potential impacts of possible options to control emissions to air and water.

There are a number of different types of manure:

 Liquid manure (slurry): it is produced in intensive livestock rearing systems using concrete or slats instead of straw bedding. It consists of excreta produced by livestock in a yard or building mixed with rainwater and wash water and, in some cases, waste bedding and feed. Slurries can be pumped or discharged by gravity. The use of slurry separators is not uncommon and this produces a very liquid fraction, suitable for irrigation pumping onto fields via irrigation pipes and a solid fraction which is handled as solid manure.;

 Solid manure: comprises material from covered straw yards, excreta from livestock, or solids from mechanical slurry separators. Solid manures can generally be stacked; and

 Litter-based farmyard manures, which contain the material (e.g. straw, wood shavings) that have been used as bedding for animals and has absorbed the faeces and urine.

There is no official reporting of the amount of manure produced across the EU, but a recent report estimates that the entire manure production in the EU27 is about 1.4 billion tonnes1and includes a calculated estimate by Member State and livestock and manure type. The table below reproduces the data at a EU27 level (for Member State breakdown see Table 3.6).

Table 1 Estimated amount of livestock manure produced per year in EU27

Separated Pig Pig Pig Separated Cattle Cattle Cattle Poultry Poultry Total Manure Slurry Litter Manure Slurry Litter Slurry Litter

Solid Liquid Solid Liquid

1,000 tonnes 14,151 8,845 148,590 5,307 297,870 54,606 447,766 294,870 3,387 109,518 1,381,911

% of EU total 1% 1% 11% 0.4% 22% 4% 32% 21% 0.2% 8% 100%

Source: Agro Business Park, 2011

Livestock farming places significant pressures on the environment, in particular through the production of manure. Manure has the potential to generate both positive and negative impacts on the environment. A discussion of the key environmental impacts associated with manure is provided in Section 3.3 and summarised in Table 3.7 (reproduced below). All impacts depend on the sort of practices implemented and the prevailing local conditions such as topography, soil types and condition, proximity to water courses etc.

1 Agro Business Park, 2011, Manure Processing Activities in Europe

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Table 2 Overview of Environmental Impacts of Manure Spreading

Impacts of Manure Domain of Impact Description of the Impacts of Manure Spreading Spreading

Air

Climate change (-) Emissions of CO2, N2O and CH4 which all contribute to climate change

Avoided impacts due to the reuse of residues, while the use of mineral fertilisers would (+) require energy and resources to be produced

Manure spreading and storage impacts on air quality due to considerable emissions of (-) 2 Air quality pollutants, such as ammonia (NH3) and particulate matter (PM) This leads to eutrophication, acidification, and formation of secondary PM which is harmful for health.

Manure spreading creates unpleasant odours due inter alia to emissions of hydrogen Odour (-) sulphide (H2S), methane (CH4) and nitrous oxide (N2O)

Noise (-) Noise is caused by machinery (and animals).

Water

Eutrophication from emissions of N and P and NH3 deposition

Water eutrophication, Acidification from emissions of NH3 acidification and (-) Drinking water standards require N and P concentration in water to be below certain pollution thresholds Medicinal residues can be leached into water and cause negative impacts to fauna

Soil

Manure brings organic matter beneficial to soil conditions (soil structure and soil carbon, Soil structure and soil biodiversity). The microorganisms that benefit from increased soil organic matter (+) composition improve soil degradation indicators, i.e. reduce soil compaction and improve water circulation/retention.

Improved soil conditions by the beneficial impact of organic matter on soil biodiversity and Soil water retention (+) structure leads to improved water filtration from soil. On drought-prone soils, higher organic content will provide better water retention.

Manure sometimes contains heavy metals, which increase soil heavy metal concentration and catalyses uncontrollable soil chemical reactions. This may result in high soil Heavy metals (-) concentrations of Cu, Zn, Mn, Fe that are useful to plants at low concentrations but may harm plants at excess concentrations, and of Cd, and Se that are harmful.

Use of heavy machinery (often by contractors) can lead to soil compaction, especially if Soil compaction (-) spreading takes place in inappropriate conditions

2 Zhang, Air Quality and Community Health Impact of Animal Manure Management www.ncceh.ca/sites/default/files/Air_Quality_and_Animal_Manure_Sept_2011.pdf

Table 2 (continued) Overview of Environmental Impacts of Manure Spreading

Impacts of Manure Domain of Impact Description of the Impacts of Manure Spreading Spreading

Biodiversity and ecosystem services

Manure increases the organic matter content of soil and thus microbial diversity Biodiversity (+) Manure provides food to diverse organisms and increases their diversity and biomass, including e.g. beneficial insects and possibly birds

Manure contributes e.g. to increased growth of grasses and may negatively impact birds (-) that are using short grasses to nest

Ecosystem services (+) Increased productivity of land, nutrient cycling

(-) Eutrophication leads to loss of drinking water and bathing areas

Manure is a significant source of air pollutants and greenhouse gases. Ammonia is emitted due to the pH controlled equilibrium of NH4 + and NH3. Emissions of ammonia from the spreading of manure across the EU are estimated to represent around 24%3-29%4 of the total emissions of ammonia from agriculture (almost 800kt) so is a major source for this pollutant5. Other important sources include livestock housing and manure storage systems estimated to contribute around 44% of total agriculture ammonia emissions. Ammonia is also a precursor of particulate matter that may affect human health and cause odours. Methane, formed by methanogenic bacteria in the slurry during storage, and nitrous oxide, mostly formed by denitrifying bacteria in anaerobic conditions when manure interacts with soil, are both powerful greenhouse gases.

When applied to land, manure increases soil organic matter and fertility by providing elements (C, N, P and K) that are essential to plant growth and beneficial conditions for soil biodiversity by stimulating microbial activities thanks to the increase of labile carbon and nitrogen content. It improves soil structure and texture, which reduces erosion and increases soil water retention. However, manure also contains nitrates and phosphates which, in excess, can be pollutants to water. Ammonia/ ammonium, partly dissolved in water and partly emitted into air, after nitrification can contribute to acidification of soil and water. The nitrification of ammonia forms nitrate, which can lead to eutrophication of soil and water in case of an excess of nutrient in particular in nitrate vulnerable zones (e.g. NVZs). To a lesser extent, manure can also contain heavy metals and veterinary residues, which can

3 AMEC, 2013, Identification of the contribution to pollution and emissions of activities and/or pollutants not regulated under EU environmental law. Study for the European Commission, ongoing.

4 Alterra, 2010, The impact of the Nitrates Directive on gaseous N emissions Effects of measures in nitrates action programme on gaseous N emissions

5 There is no distinction made in the national reported inventories between the emissions arising from livestock housing, grazing, manure storage or manure spreading so these estimates have been derived based on available data and other assumptions.

potentially pose negative consequences to the environment and human health. All these variables degrade the environment with secondary effects on biodiversity, in particular, in eutrophied zones.

The main existing EU and international legislation that cover manure and its management are summarised in Section 3.4.1. Key legislation affecting pollutant emissions to air and/or water from manure includes the Nitrates Directive and other freshwater policies (e.g. Water Framework Directive), the Industrial Emissions Directive (IED, only for poultry and pig farms above specific thresholds), the National Emission Ceilings Directive (NECD, includes national emission ceilings for ammonia which are in effect a cap on agriculture emissions), the Gothenburg Protocol and Pillars I and II under the Common Agricultural Policy (CAP). Section 3.4.2 sets out national legislation in place relevant for manure, making clear that some Member States are taking actions over and above EU legislation in relation to manure management but there still appears to be significant potential for further action.

A review of the economic outlook of the poultry, pig, dairy and beef industries is provided in Section 3.5 focusing on key industry characteristics, trade and competitiveness. A summary of the main findings are provided below:

 For poultry, the EU is a net exporter of both poultry meat and eggs although the former is expected to decline up to 2020 as the Euro recovers and strengthens following the economic crisis. There has been a significant decrease in the number of holdings since 2005 whilst broiler or laying hen numbers have increased or remained constant, respectively, reflecting a consolidation of the industry into fewer, larger holdings;

 For pigs, two thirds of pig meat production in the EU is produced in just six countries, Germany, Spain, France; Poland, Denmark and the Netherlands. As for poultry, the EU is a net exporter of pig meat and average herd size has increased steadily since 2005. Margins in the sector are tight making farmers reluctant to invest in their farms and a significant proportion are expected to exit the business as a result of forthcoming environmental and animal welfare regulations and associated costs;

 For dairy, milk production in the EU is not competitive in comparison with other parts of the world, with the cost of production at farm level per litre of milk higher than in other areas. Liberalisation of the EU dairy market will result in greater competition within the EU market and increased international competition in milk products, which is likely to result in a lower real milk price in future years. Less competitive producers (high production costs, high critical milk price) will be forced to close or re-structure. Those EU dairy producers which remain will seek to reduce production costs, through increasing herd size and increasing milk yield per cow in order to remain competitive;

 For beef, the long-term trend in the trade balance has been negative since 2003. EU beef production is uncompetitive compared with other countries due to competitive advantages in third countries (i.e. relatively cheap inputs (feed and labour), large and reliable livestock supplies, lower levels of bio- security regulation and economies of scale). It is likely that in future, reductions in import tariffs for key beef exporting countries and further decoupling aid will result in increased competition. Those EU enterprises which continue to operate will be forced to implement measures to increase competitiveness such as reducing production costs, increased specialisation, greater productivity per head and increased herd size to gain economies of scale.

Policy Options (Section 4)

There are a number of possible options for controlling emissions to air and water from manure storage and spreading as set out in Section 4. These vary in terms of the framework/ mechanism for control (e.g. voluntary, revisions to existing legislation, new legislation), the scope of coverage in terms of thresholds and the stringency of requirements.

The different mechanisms by which specific measures could be implemented at an EU level are described in Section 4.3 and summarised in the table below. There are a number of advantages and disadvantages associated with each option. The key issues to take into consideration include the certainty of impact (i.e. voluntary versus mandatory) and potential conflicts between instruments targeted specifically at air (e.g. NECD) or water (e.g. Nitrates Directive) emissions i.e. it may not be feasible to include air specific measures in an existing instrument targeted at water quality and vice versa. Overall, it appears that, in the short term, the revision of the NEC Directive (Option 2.3) offers the most feasible route for promoting a broader uptake at EU level of measures targeted at reducing emissions to air from manure storage and spreading considering it is currently under revision and specifically targets ammonia. This could be via the inclusion of implementing measures alongside revised national emission ceilings for ammonia (which would effectively act as a ceiling for the agriculture sector considering its more than 90% contribution to total ammonia emissions). Other short term options, possibly in combination with others, may include measures under Pillar II of CAP although this requires Member States to prioritize these measures in the process of developing Rural Development Programmes for the time period 2014-2020 (Option 3.2).

A possible longer term option could be the revision of the IED or the BAT reference documents developed under it to target manure spreading more actively than at present (Option 2.1). However, the recent IED Article 73 review report concluded that the Commission does not intend to include cattle farms within the scope of the Directive or amend any other elements of the Directive in relation to intensive livestock farms as the inclusion of cattle would deliver somewhat limited environmental benefits while potentially imposing significant administrative and compliance costs to a large number of farms. The report did recognise the significance of emissions from manure spreading but indicated that the IED itself is not the most appropriate instrument. Therefore other longer term options could include the revision of the Nitrates Directive to broaden its scope to also cover air pollution and require more specific ammonia measures within NVZs (Option 2.2), new legislation targeted specifically at manure storage and spreading (Option 4.1) or the development of a new integrated nitrogen management directive (Option 4.2). The latter options may provide a good way of targeting overall nitrogen emissions to both air and water, thereby applying a more comprehensive perspective. Inclusion of the best practice manure spreading measures under the CAP Pillar I cross-compliance requirements (Option 3.1) could also be feasible in the long- term, i.e. post 2020.

Voluntary approaches (Option 1) could be a possibility and have been applied already in some Member States but these don‟t represent a level playing field for farmers across the EU, and do not offer certainty in delivering any substantial emission reductions as uptake is highly uncertain.

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Table 3 Summary of Pros and Cons of Different Instruments

Instrument Advantages Limitations

Voluntary (Option 1)  It does not require any new legislation;  The uptake of the measure is unpredictable and  Being developed in close collaboration with the could be insufficient to secure adequate farming industry, it would have a high level of environmental gains; industry „ownership‟;  The extent of the public authority control is limited  The impacts on public sector and the industry, and (i.e. during the design phase of the measure but the net costs would be low (e.g. farmers are most also for ensuring compliance and monitoring the likely to follow the measures where it is in their results) such as over compliance monitoring; and financial interests to do so); and  It is likely that the costs of compliance would be transferred to a price premium on food (as for other  There are successful examples of this approach compliance options) – in this instance, however, being in place although it is unclear what impact consumers might be willing to pay the premium on they have had from an environmental perspective. the basis that it was from an environmentally sustainable farm.

Existing instruments (Option 2):  Relies on the existing legislation, it is overall easier  It is restricted by the scope or „raison d‟être‟ of to revise an existing framework than introducing a certain instruments, for example the IED currently - Industrial Emissions Directive whole new one; only covers pig and poultry farms above a specific (Option 2.1)  It relies on a framework that farmers are already threshold; - Nitrates Directive (Option 2.2) familiar with, so it may be easier to assimilate;  Inclusion under IED would extend burdensome permitting regime to wider number of installations  It allows the use of existing monitoring - National Emission Ceilings and has already been considered by the mechanisms; and Directive (Option 2.3) Commission as not fit for purpose in recent review;  Adopting implementing measures alongside a revised ammonia emission ceiling could allow for  It may blur the objectives of the existing targeted targeted measures for certain activities whilst still legislation, for example the Nitrates Directive is leaving a certain element of flexibility for Member aimed at reducing nitrate pollution of surface and States to decide how best to meet the overall groundwater sources, not air emissions of ceiling. ammonia (although it is a side-effect); and  Existing instruments such as the IED and Nitrates Directive are unlikely to be up for renegotiation at present and widening their scope may only be feasible in the longer term.

Common Agricultural Policy  It relies on mechanisms which have already been  Monitoring compliance with some measures can (Option 3): set up and used (Option 3.1 and Option 3.2); be difficult and resource intensive (Option 3.1);  It has a strong incentive as subsidies could be  Costs of some of the measures are likely to be - Cross compliance measures reduced as a result of non-compliance (Option substantial and may be unaffordable for some under CAP Pillar I (Option 3.1); farmers (Option 3.1 and Option 3.2); and 3.1)  It would impact widely as a majority of farmers are  Some intensive livestock installations (pigs and - Support for Rural claiming subsidies (Option 3.1), and poultry units regulated under the IED) would not be affected by this, as they claim no or little in SPS Development under CAP  Implementation of measures would be eligible for payments (unless impacted indirectly where funding support via RDP (Option 3.2) pillar II (Option 3.2) manure is spread on land managed by third parties who are claiming subsidies) (Option 3.1)

New legislation (Option 4):  Allows clear objectives to be set and strived for  The process can be particularly long to introduce; focussed on reducing impacts to multiple  More legislation is unlikely to be welcomed by - Directive on manure environmental media rather than just one e.g. air; interest groups and MS governments; management (Option 4.1)  Allows for a tailored approach to be adopted  The introduction and implementation of a new - Integrated nitrogen without having to fit into an established framework; legislation is costly and in the current economic management directive and climate may not be welcomed by Member States; (Option 4.2)  An integrated approach to nitrogen bringing and together all existing legislation could potentially  New legislation may partly conflict with the existing reduce the overall administrative burdens on legislation, e.g. when introducing more stringent Member States and farmers requirements or applying existing requirements on a wider scope.

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A further issue to consider for the development of possible options is the overall scope of coverage i.e. which size and types of farms may be affected. The scope of coverage of a particular option could be defined in two main ways: geographical and/or numerical (animal places, livestock units or manure volumes). These are discussed in Section 4.4. Whilst a livestock unit (LSU) approach might be the most equitable way of defining thresholds (farms with similar environmental impacts would be captured) it is more complex than the animal places approach which is already applied within the IED (note, the IED itself focuses primarily on emissions linked with housing rather than spreading). Defining the farms captured by the policy in terms of the volume of manure being produced or the volume of manure being spread (e.g. on an annual basis) would ensure that those farms spreading large volumes of manure would be captured. However, this option could perhaps be quite challenging to regulate as it would require precise data on the volumes of manure being produced and/or spread by a particular farm which is likely to vary from year to year. The same could be said for an approach based on animal heads. Furthermore, certain measures are considerably less cost effective when applied at smaller farms and any administrative burdens are likely to affect smaller farms most (although there is potential to differentiate burden depending on size). As the analysis of numbers of farms and animals that could be affected by any new regulation presented in Section 5.3.1 shows, there are a significant number of farms in the EU with a small number of animals. Therefore any options targeted at reducing emissions from manure storage and spreading should exclude the smallest farms to reduce the overall costs of compliance with minimal impact on overall benefits.

A key issue for determining the most appropriate approach for establishing scope will be the mechanism by which an option would apply. As identified during the review of the IPPC Directive, in many cases the farms producing the manure do not necessarily have the land to be able to spread it so it is often spread off-site by a third party. This has meant that it does not have to be spread according to BAT as defined in the BREF. If the onus is to be placed on the producers of manure (requiring any manure produced to be spread according to BAT) then an animal numbers approach (heads or LSU) is fine. In order to ensure that it would still be spread according to the policy there would need to be a requirement for those farms producing the manure to subsequently require their contractors to spread the manure appropriately. This could be in the form of a manure transfer note, similar to current approaches for waste management. In particular, where manure is being spread by a third party rather than by manure producer, responsibility to ensure compliance with the best practice requirements could be placed on the manure producer. This could be achieved, for instance, by using contract arrangements based on duty of care philosophy, e.g. manure transfer notes that would make the best practice requirements also binding for the parties spreading the manure. This type of approach is already applied by some Member States in their national legislation. However, if an option is to target those spreading the manure directly then an approach based on geographical area or manure volumes would be most appropriate.

Section 4.5 lists best available practices to reduce emissions of ammonia to air and nitrates leakage to water in relation to manure storage and spreading techniques (including equipment) as well as spreading practices including spreading quantities, area and timing. These are based on a review of relevant literature and existing practices in each of the Member States. These include options for differing levels of ambition. Building on the consultation undertaken for the study, we have also attempted to summarise where some Member States are already applying

the best practices described below; this is presented in Table 4.11. Some Member States did not respond to the consultation and/or only provided limited information.

Table 4 Summary of Best Practices under Different Ambition Levels (A-C)

Element A (high) B (moderate) C (low)

Manure Sufficient storage capacity across whole Sufficient storage capacity in NVZ and Sufficient storage capacity in NVZ storages: of the country above certain threshold outside NVZ capacity (100AU)

Manure Target NH3 emission reduction of >80% Target NH3 emission reduction of >60% Target NH3 emission reduction of storages: cover >40% Techniques – tight lid Techniques – plastic sheet Techniques – floating cover

Manure Target NH3 emission reduction of >60% Target NH3 emission reduction of >30% Target NH3 emission reduction of spreading (slurry application) and >30% (solid (slurry) and >30% (solid). >30% (slurry) and >30% (solid). technique and manure application). Techniques: Techniques: incorporation Techniques: Slurry: band spreading (trailing hose or Slurry: band spreading (trailing hose Slurry: injection (grassland, arable)/ band trailing shoe) (grassland)/ with or trailing shoe) (grassland)/ dilution / spreading with incorporation within 2h incorporation within 4h (arable) management systems with (arable) Solid: direct incorporation (within 12h), incorporation within 12h Solid: direct incorporation (within 4h), where feasible (applicable on arable Solid: direct incorporation (within where feasible (applicable on arable land land only) 24h), where feasible (applicable on only) arable land only

Quantity 170kg N/ha (manure) including potential 170kg N/ha (manure) including 170kg N/ha (manure) including thresholds grassland derogation up to 250 kg/ha potential grassland derogation up to potential grassland derogation up to (absolute) where applicable 250 kg/ha where applicable 250 kg/ha where applicable Scope: whole territory Scope: NVZ +voluntary with active Scope: NVZ +voluntary support

Quantity Application based on crop nutrient needs Application based on crop nutrient Not used thresholds Scope: NVZ + voluntary with support needs (variable) Scope: NVZ + voluntary

Timing of Set closed periods Set closed periods Set closed periods application No application on water-saturated, No application on water-saturated, No application on water-saturated, flooded, frozen or snow-covered ground flooded, frozen or snow-covered flooded, frozen or snow-covered ground ground Scope: whole territory Scope: NVZ+ voluntary with active Scope: NVZ + voluntary support

Areas of No application on a steeply sloping No application on a steeply sloping No application on a steeply sloping application ground ground ground No application near water courses No application near water courses No application near water courses Scope: whole territory Scope: NVZ+ voluntary with active Scope: NVZ + voluntary support

Table 3 (continued) Summary of Best Practices under Different Ambition Levels (A-C)

Element A (high) B (moderate) C (low)

Fertiliser plans Establishment of fertilizer plans on a Establishment of fertilizer plans on a Not used farm-by-farm basis and the keeping of farm-by-farm basis and the keeping of records on fertilizer use. records on fertilizer use. Scope: NVZ+ voluntary with active Scope: NVZ +voluntary. support.

Farm Use of appropriate crop rotation systems. Use of appropriate crop rotation Not used management Set proportion of the land area devoted to systems. permanent crops relative to annual tillage Set proportion of the land area devoted crops. to permanent crops relative to annual Maintain minimum vegetation cover tillage crops. during (rainy) periods. Maintain minimum vegetation cover Scope: NVZ + voluntary with support. during (rainy) periods. Scope: NVZ + voluntary.

It is essential that overall fertilizer inputs are fine-tuned to match the amount of nitrogen saved. In this way, farmers can also save time and costs by reducing other fertilizer inputs, as reduced nitrogen losses translates to a larger fraction of nitrogen inputs being available to reach the agricultural crops.

Analysis (Section 5)

As described in Section 3.2 there are a very large number of pig, poultry and cattle holdings in the EU (over 12 million in total based on available Eurostat data). However, the majority of these are very small and including them in any new or revised legislation is likely to provide limited benefits and potentially at a high cost. Therefore, we have undertaken a review of the Eurostat data available for each animal species focussed on the numbers of holdings and animal heads broken down by farm size for the EU as a whole (Section 5.3.1). This provides a useful proxy for the volumes of manure that could be targeted in any new or revised policy. It demonstrates for all three animal types that there are a significant number of farms with a small number of animals so there is merit in setting thresholds for coverage under any new or revised legislation.

For assessing potential compliance costs for applying best practices for manure spreading (measures focused primarily on reducing emissions to water) and administrative costs we have assumed thresholds of 50 heads for cattle, 10,000 heads for poultry and 150 heads for pigs. Costs for measures targeted specifically at manure storage and spreading (measures focussed primarily on reducing emissions to air) have been modelled based on the reference and maximum applicable uptake rates assumed in the GAINS model. The GAINS modelling assumes that farms below 15 LSU would not have to apply any of the measures associated with manure storage and manure spreading techniques. When converted using Eurostat LSU conversion factors for each animal type, 15 LSU is roughly equivalent to 15-20 heads for cattle (varies between dairy and others), 30-50 heads for pigs (varies between

sows and others) or 1,000-2,000 heads for poultry (varies between broilers and laying hens). These are therefore lower than the thresholds assumed in the modelling of measures focussed primarily at reducing emissions to water.

The costs associated with best practice for manure storage and spreading primarily aimed at reducing NH3 emissions to air have been considered in two ways:

 Firstly, a comparison of the cost-effectiveness of different abatement measures targeted at the agriculture sector has been undertaken based on a range of sources. This shows how manure storage and application measures tend to be at the lower end of the cost spectrum i.e. they are relatively cost effective. Some of the application measures can even show a negative overall cost as, when applied properly, manure can reduce the need for purchasing fertilisers;

 Secondly, the reference scenario developed by IIASA for the TSAP review for the EU28 using the GAINS model was taken as a basis for the analysis of costs and emission reduction. In particular, the potential additional costs and emission reductions of applying the maximum uptake rate has been modelled separately through manipulation of the modelling of the reference scenario for two measures including covered manure storage and low ammonia application. The additional costs associated with the maximum uptake of GAINS measures for covered storage and low nitrogen application for 2025, i.e. additional to the uptake anticipated under the reference scenario, are estimated to be around €20 million to €210 million per year for covered storage (low and high efficiency, respectively, broadly correlating to our ambition levels C and A) and around €120 million and €100 million per year for low nitrogen application (low and high efficiency, respectively, broadly correlating to our ambition levels C/B and B/A). The overall cost-effectiveness (based on the modelled maximum uptake) varies from €1.2 (low efficiency – broadly correlated to our ambition level C) to €4.2 (high efficiency – ambition level A) per kg of ammonia abated for covered storage and €1.4 (low efficiency – broadly correlated to our ambition levels C/B) to €0.4 (high efficiency – B/A) per kg of ammonia abated for spreading. The high efficiency low ammonia application measures are more cost effective than the low efficiency measures as they take into account greater savings from reduced fertiliser use.

A breakdown of costs disaggregated for different livestock and manure types is provided in the figure below:

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Figure 1 Maximum Additional Costs for Manure Storage and Spreading Measures (relative to GAINS reference scenario, €m per year)

The ammonia emission reductions presented are based on the TSAP revision modelling outputs provided by IIASA as described above for compliance costs using outputs from the GAINS model to assess potential maximum uptake of measures for manure storage and spreading. These are summarised in the figure below:

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Figure 2 Maximum Additional Emission Reductions for Manure Storage and Spreading Measures (Relative to Gains Reference Scenario, kt NH3 per year)

These show a potential additional reduction in ammonia emissions from livestock (over and above the reference scenario) of around 15kt and 50kt for low and high efficiency covered storage measures (broadly correlated to our ambition levels C and A), respectively, and around 80kt and 250kt for the low and high efficiency spreading measures (broadly correlated to our ambition levels C/B and B/A), respectively.

These have subsequently been monetised using the damage cost functions developed under the CAFE programme6 giving total monetised benefits of around €0.4 billion (€0.2-0.6bn range) and €1.2 billion (€0.6-1.8 bn range) for low and high efficiency covered storage measures (broadly correlated to our ambition levels C and A), respectively, and around €2 billion (€1.1-3 bn range) and €6.5 billion (€3.4-9.7 bn range) for the low and high efficiency spreading measures (broadly correlated to our ambition levels C/B and B/A), respectively. The estimated benefits

6 These include both health impacts as well as some wider impacts such as on crops.

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are substantially higher than the associated costs (even if the costs for manure spreading practices targeted at water pollution and administrative burden as described below are included).

Figure 3 Comparison of Monetised Benefits (Using Cafe Damage Cost Functions) and Costs Associated with Maximum Uptake of Each Measure (relative to GAINS reference scenario, €m per year)

The costs associated with best practice for manure spreading aiming to reduce nitrate leaching to water have been assessed separately taking into account existing uptake of best practices (based on feedback from Member States during the consultation) and existing NVZ coverage and are presented in Sections 5.2.2 (key assumptions) and 5.3.2 (results). The costs associated with ambition level A are estimated to be around €1.3 billion per year (€0.7- 1.8bn range) whereas for level B they are considerably lower at around €0.1 billion per year (€0.1-0.2bn range). These cost estimates are based on the estimated number of holdings that could be affected using the thresholds described above in Section 5.3.1. Taking a lower or higher set of thresholds would of course affect a differing number of holdings and subsequently change these costs. The cost estimates for ambition level A are considerably higher than B as in general they require application of best practice measures across the whole of a Member State‟s territory and not just in an NVZ thus capturing a much greater number of farms. No costs have been estimated for ambition level C as the majority of measures proposed can be considered BAU in most Member States e.g. they only apply within NVZs and/or are voluntary outside.

Potential administrative costs associated with any new or revised legislation targeted at controlling emissions from manure management have been estimated based on a light touch approach to regulation whereby farmers would be required to maintain records of manure production, storage, processing and application including evidence of any transfers to other farms and that it has subsequently been stored and applied in line with the best practice requirements. Regulators are assumed to undertake a small check of records each year. Total administrative costs are estimated to be €18-37 million per year for farmers and regulators. Irrespective of whether an option is targeted at either water and/or air emissions, the administrative costs are expected to be broadly the same as the types of records to be maintained and checks made will be similar.

An assessment of the wider environmental impacts (i.e. beyond impacts on emissions to air) associated with the best practices defined in this study has been undertaken and is presented in Section 5.3.6. An important consideration when assessing impacts of these practices is the need to avoid pollution swapping, i.e. the risk that reduced emissions to air increase risks of nutrient leaching. For example, the rapid soil incorporation of manure reduces N emissions to air but can increase the risk of leaching in water (ADAS, 2011). However, the risk of trade- offs can be controlled by other measures, in particular by balancing fertilisation.

An assessment of potential socio-economic impacts has also been undertaken and is presented in Section 5.3.7. The scale and nature of impacts will be influenced primarily by “operator reaction” to any options to control emissions. Operators of smaller farms in accordance with the thresholds adopted and/or those Member States not already applying more stringent measures than existing EU legislation are expected to be the most affected.

Those options which impose the greatest additional burden on farmers will result in the greatest loss of competitiveness in the short-term. However, it should be noted that this burden could be somewhat mitigated by the benefits linked to more efficient resource use arising from the options, particularly relating to more efficient and optimal use of manure/ fertiliser. Furthermore, the emerging opportunity to use RDP funding under CAP Pillar II to explicitly support measures aimed at reducing ammonia emissions could mitigate adverse impacts on competitiveness. It has not been possible to quantify the extent to which this might happen under the different ambition levels, but the use of RDP funding and additional benefits associated with the reduced use of fertilisers may fully or partially alleviate additional burdens. Furthermore, the options imposing a greater additional burden on farmers increase the driver for their pro-active response, e.g. to increase productivity, apply for RDP funding, and are likely to accelerate the uptake of measures to increase competitiveness. In those instances where available RDP funding and/or benefits associated with the reduced use of fertilisers are not sufficient to compensate any additional costs, the shock of greater additional burden may result in changes to industry structure which make the sector more competitive in the medium-term.

In the context of employment, the aggregate impact of additional costs of options is likely to be a net reduction in the number of persons employed. The magnitude of impacts for the specific options, relative to one another, are expected to be in line with the relative magnitudes of associated costs. However, the opportunity to use RDP funding under the CAP Pillar II to support measures targeting reductions of ammonia emissions may, to a certain degree, offset negative impacts and prevent job losses (if these measures are taken up by the Member States).

xvi

Uncertainties and Limitations

There are a number of uncertainties and limitations associated with the information presented in this study including current (and future) application of best practices in each Member State. Whilst we have gathered a lot of useful information via a review of literature and consultation with the Member States, there is still significant uncertainty associated with the current (and future) application of particular techniques and practices. Other uncertainties and limitations are described in Section 6.2.

xvii

Contents

1. Project Understanding 1 1.1 This Report 1 1.2 Project Context 1 1.3 Objectives 3 1.4 Structure of this Report 3

2. Data Collection 5 2.1 Overview 5 2.2 Review of Literature and Relevant Data Sources 5 2.3 Member States Consultation 5

3. Baseline Definition 7 3.1 Overview 7 3.2 Manure and Slurry Volumes 7 3.2.1 Numbers of Livestock Heads and Holdings 7 3.2.2 Projections of Livestock Numbers 12 3.2.3 Excretion Factors 15 3.2.4 Manure Volumes and Types 17 3.3 Environmental Impacts 25 3.3.1 Overview 25 3.3.2 Emissions to Air 27 3.3.3 Odour 41 3.3.4 Noise 41 3.3.5 Impacts on Soil 41 3.3.6 Impacts on Water 44 3.3.7 Impacts on Biodiversity and Related Ecosystem Services 48 3.3.8 Risks of Pollution Transfer 50 3.4 Current Regulation 51 3.4.1 European and International Legislation 51 3.4.2 National Legislation 59 3.5 Economic Outlook 63 3.5.1 Poultry Industry 63 3.5.2 Pig Industry 67

xviii

3.5.3 Dairy Industry 71 3.5.4 Beef Industry 75 3.6 Summary 77

4. Options Development 79 4.1 Overview 79 4.2 Approach to Developing Options 79 4.3 Overall Framework 80 4.3.1 Business as Usual 80 4.3.2 Voluntary Approach (Option 1) 80 4.3.3 Existing Instruments (Option 2) 84 4.3.4 Common Agricultural Policy (Option 3) 88 4.3.5 New Legislation (Option 4) 93 4.4 Scope of Coverage 96 4.4.1 Overview 96 4.4.2 Geographical 96 4.4.3 Numerical Thresholds 97 4.4.4 Summary 97 4.5 Defining Best Practice 98 4.5.1 Overview 98 4.5.2 Best Practice in Manure Storage 99 4.5.3 Best practice in manure spreading techniques 104 4.5.4 Best Practice in Manure Spreading Practices 108 4.6 Summary 116

5. Data Analysis 123 5.1 Overview 123 5.2 Approach to Assessing Impacts 123 5.2.1 Potential Numbers of Holdings/ Animals Affected 123 5.2.2 Compliance Costs 124 5.2.3 Administrative Costs 127 5.2.4 Emission Reductions 128 5.2.5 Monetised Benefits 128 5.3 Estimated Impacts 128 5.3.1 Potential Numbers of Holdings/ Animals Affected 128 5.3.2 Compliance Costs 135

xix

5.3.3 Administrative Costs 140 5.3.4 Emission Reductions 141 5.3.5 Monetised Benefits 142 5.3.6 Wider Environmental Impacts 143 5.3.7 Wider Economic and Social Impacts 147 5.4 Summary 160

6. Conclusions 164 6.1 Conclusions 164 6.2 Uncertainties and Limitations 169

7. References 172

Table 1 Estimated amount of livestock manure produced per year in EU27 ii Table 2 Overview of Environmental Impacts of Manure Spreading iii Table 3 Summary of Pros and Cons of Different Instruments vii Table 4 Summary of Best Practices under Different Ambition Levels (A-C) ix Table 3.1 Number of Livestock Heads Disaggregated by Animals in EU27, 2010 7 Table 3.3 Review of Available Excretion Factors 16 Table 3.4 Mean N Excretion Factors for Different Livestock 17 Table 3.5 Breakdown of Different Types of Manure (%) by Livestock Type 18 Table 3.6 Estimated Amount of Livestock Manure per Year in EU27 (in 1,000 tonnes) 19 Table 3.7 Overview of Environmental Impacts of Manure Spreading 26 Table 3.8 NVZ Coverage by Member State (2008) 52 Table 3.9 Livestock Numbers Thresholds for Annex IX 55 Table 3.10 Key Characteristics of EU27 Poultry Industry (2010 or most recent prior to 2010 where not available) 64 Table 3.11 Key characteristics of EU27 pig industry (2010 or most recent prior to 2010 where not available) 68 Table 4.1 Examples of Measures under the RTFADS in the UK 81 Table 4.2 Advantages and Limitations of the Voluntary Approach 83 Table 4.3 Advantages and Limitations of the Existing Legislation Approach 87 Table 4.4 Advantages and Limitations of the Cross Compliance Approach 92 Table 4.5 Advantages and Limitations of the new Legislation Approach 95 Table 4.6 Summary of ambition levels included in draft Gothenburg Protocol revision guidance document for preventing and abating ammonia emissions from manure storage 102 Table 4.7 BAT on Land-spreading Equipment 106 Table 4.8 Summary of ambition levels included in draft Gothenburg Protocol Revision guidance document for preventing and abating ammonia emissions from manure spreading 108 Table 4.9 Closed Periods in England 113 Table 4.10 Summary of Ambition Levels Associated with Best Practices 118 Table 4.11 Summary of current uptake of best practices by Member State based on consultation responses* 120 Table 5.1 Cost Implications of Best Practice on Spreading Practices 126 Table 5.2 Number of holdings (and cattle heads) covered by different thresholds (EU27) 129 Table 5.3 Number of holdings (and poultry heads) covered by different thresholds (EU27) 131 Table 5.4 Number of Holdings (and pig heads) covered by Different Thresholds (EU27) 133 Table 5.5 Summary of Measures from the draft Gothenburg Protocol Agriculture Guidance Document 136 Table 5.6 Costs from IIASA/Alterra 2012 (TSAP Report #3) 137 Table 5.7 Bonus for Conserved Nitrogen, achieved by applying Low Emission Spreading Techniques for Slurry (relative to use of a broadcast spreader) 138 Table 5.8 Estimated Costs associated with Best Practice Ambition Levels A and B for Measures Targeted Primarily at Reducing Nitrate Leaching to Water (€ million per year) 140 Table 5.9 Estimated Costs associated with Administrative Burden (€ million per year) 140 Table 5.10 Effects of the Options regarding the different Environmental Impacts 146 Table 5.11 Impact of Farmer Reaction on Competitiveness 155

Table 5.12 Broad Impacts of Option Elements on Competitiveness 156 Table 5.13 Specific Impacts of Best Practice Elements on Competitiveness 156 Table 5.14 Impact of Operator Reaction on Employment 158 Table 5.15 Impact of Options on Employment and Labour Markets 159

Figure 1 Maximum Additional Costs for Manure Storage and Spreading Measures (relative to GAINS reference scenario, €m per year) xii Figure 2 Maximum Additional Emission Reductions for Manure Storage and Spreading Measures (Relative to Gains Reference Scenario, kt NH3 per year) xiii Figure 3 Comparison of Monetised Benefits (Using Cafe Damage Cost Functions) and Costs Associated with Maximum Uptake of Each Measure (relative to GAINS reference scenario, €m per year) xiv Figure 3.1 Number of Cattle Holdings in each EU Member State (2010) 9 Figure 3.2 Number of Poultry Holdings in each EU Member State, EU 27 (2010) 10 Figure 3.3 Number of Pig Holdings in each EU Member State (2010) 11 Figure 3.4 Evolution of Cattle, Poultry and Pigs Numbers between 2007 and 2010, EU27 12 Figure 3.5 CAPRI Projection of Livestock Units in EU28 for the (a) PRIMES 2012 and (b) PRIMES 2010 Baseline Scenario (million livestock units) 13 Figure 3.6 Projected Numbers of Livestock Heads and Associated Manure Management Systems (relative to numbers in 2000)14 Figure 3.7 Production of Manure per Member State (as a % of EU27 total) 20 Figure 3.8 Estimated nitrogen Manure Production (ton N), left, and Phosphorus Manure Production (ton P), right, Distributed for Different Animal Types for EU15 countries 21 Figure 3.9 European Map of Nitrogen Manure Input per Agricultural Area in EU15, averaging on 10 km2 area 22 Figure 3.10 European Map of Phosphorus Manure Input per Agricultural Area in EU15, averaging on 10 km2 area 23 Figure 3.11 Schematic Overview of the Environmental Impacts of Manure and Related Processes 25 Figure 3.12 Ammonia Emissions for the EU27 from Cattle, Pigs and Poultry for years 1990-2010 (in Gg) 28 Figure 3.13 Ammonia Emissions from Cattle, Pigs and Poultry by Member State, 2010 (in Gg) 29 Figure 3.14 Agricultural Sources of Ammonia Emissions for EU27, 2010 30 Figure 3.15 Split of NH3 Emissions from the Spreading of Manure, EU27, 2010 31 Figure 3.16 Source of Methane Emissions in EU27, 2010 32 Figure 3.19 Source of N2O Emissions in EU27, 2010 35 Figure 3.25 Exceedance of Critical Loads for Eutrophication due to the Deposition of Nutrient N in 2000 and 2010 47 Figure 3.26 Poultry Meat Market Developments (million tonnes), 2000-2020 65 Figure 3.27 Average Numbers of Broilers per Holding (Member States with more than 1000 broilers per holding in 2010), 2005- 2010 66 Figure 3.28 Average Numbers of Laying Hens per Holding (Member States with more than 500 broilers per holding in 2010), 2005-2010 67 Figure 3.29 Pig Meat Market Developments (million tonnes), 2000-2020 68 Figure 3.30 Average Numbers of Pigs per Holding (Member States with more than 100 pigs per holding in 2010), 2005-2010 70 Figure 5.1 Percentage of total EU27 Cattle Holdings and Heads above Different Thresholds 130 Figure 5.2 Percentage of total EU27 Poultry Holdings and Heads above Different Thresholds 132 Figure 5.3 Percentage of total EU27 Pig Holdings and Heads above Different Thresholds 134 Figure 5.4 Maximum additional Costs for Manure Storage and Spreading Measures (relative to GAINS reference scenario, €m per year) 139 Figure 5.5 Maximum additional Emission Reductions for Manure Storage and Spreading Measures (relative to GAINS reference scenario, kt NH3 per year) 142 Figure 5.6 Comparison of Monetised Benefits (using CAFE damage cost functions) and Costs associated with Maximum Uptake of each Measure (relative to GAINS reference scenario, €m per year) 143 Figure 5.7 Size-dependent Investment Costs for High Efficiency Measures to abate Ammonia from Manure Storage. The inverted regression function (line) indicates high costs for small units (costs expressed in EURO of the year 2005) 149 Figure 5.8 Comparison of cost data for slurry injection (orange) and for incorporation of manure (blue) 150 Figure 5.9 NVZ Map 151 Figure 5.10 NVZ Land Area as a Percentage of 1) Whole Territory and 2) Arable Land, Land under Permanent Crops and Permanent Grassland, 2008 152 Figure 5.11 Nitrogen input per hectare of Lands Classified as Arable Land, Land under Permanent Crops and Permanent Grassland (kg/ha), 2008 153

Appendix A Literature Review Summary Appendix B Questionnaire sent to Member States Appendix C National Legislation Affecting Member States Appendix D Assessment of Wider Environmental Impacts

1. Project Understanding

1.1 This Report

This final report sets out the findings from the review of literature, consultation with Member States and the analysis of possible policy options for the control of emissions from the spreading of manure.

1.2 Project Context

The Commission published its proposal and an impact assessment for a Directive on industrial emissions (Industrial Emissions Integrated Pollution Prevention and Control, IED 7) on 21 December 2007, which consolidated seven existing Directives related to industrial emissions into a single clear and coherent legislative instrument. These existing Directives included titanium dioxide industry related directives (78/176/EEC, 82/883/EEC, 92/112/EEC), the IPPC Directive (96/61/EC), the Solvent Emission Directive (1999/13/EC), the Waste Incineration Directive (2000/76/EC) and the LCP Directive (2001/80/EC).

The Commission‟s impact assessment8 accompanying the proposal identified a number of problems related “(1) to shortcomings in the current legislation that lead to unsatisfactory implementation and difficulties in Community enforcement actions and, thereby, to loss of health and environmental benefits and (2) to the complexity and lack of coherence of parts of the current legal framework.”

The impact assessment and proposed Directive were informed by a series of studies undertaken over several years as part of the review of the IPPC Directive. Political agreement on the text was reached at the European Council on 25th June 2009 and a common position was outlined by the Commission in November 2009. Following agreement between Council and Parliament on 7 July 2010, the Directive (2010/75/EU) was formally adopted on 24 November 2010 and published in the Official Journal on 17 December 2010; coming into force on 6 January 2011.

7 “Proposal for a Directive of the European Parliament and of the Council on industrial emissions (integrated pollution prevention and control) (recast)”. European Commission, Brussels, 21st December 2007. Available from: http://eur- lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:52007PC0844:EN:NOT

8 “Commission Staff Working Document: Accompanying document to the Proposal for a Directive of the European Parliament and of the Council on industrial emissions (integrated pollution prevention and control) (recast). Impact Assessment.” European Commission, Brussels, 21st December 2007. Available from: http://ec.europa.eu/environment/air/pollutants/stationary/ippc/ippc_revision.htm

The Directive places a number of requirements on the European Commission to undertake additional actions over the coming years. Of relevance to this study are the reviews set out in Article 73(2) of the Directive:

“Article 73 Review

2. The Commission shall by 31 December 2012, review the need to control emissions from:

(a) the combustion of fuels in installations with a total rated thermal input below 50MW;

(b) the intensive rearing of cattle; and

The Commission shall report the results of that review to the European Parliament and to the Council accompanied by a legislative proposal where appropriate.”

The focus of this study is on Article 73(2)(c) as the other elements have been considered in a recent study that was undertaken by AMEC9 (“Collection and analysis of data to inform certain reviews required under Directive 2010/75/EU on industrial emissions (IED) and to inform Commission Guidance on the content of the baseline report under Article 22 of the IED”).

The Commission‟s review of the IPPC Directive identified that, under the definitions in Directive 2008/1/EC, the spreading of manure is generally not covered by the Directive as it often does not take place on the site of the main IPPC activity (intensive rearing of pigs or poultry). This is because intensive livestock installations, except for some intensive cattle-rearing enterprises, may have little land on which to spread it, and so the manure is often transferred to other farms or in anaerobic digesters and, in the case of some poultry installations, to power stations. Therefore, in these circumstances, operators are not required to carry out Best Available Techniques (BAT)-based manure spreading. To address this issue, Article 16(4) of the original IED proposal included requirements for BAT to be applied to the spreading of manure and slurry outside of an IPPC installation. The proposals also stated that “…Member States may include those requirements in measures other than a permit.”

The Commission‟s Impact Assessment (IA) for the IED – based on a number of supporting studies – found that the extension of BAT to all manure spreading would lead to significant benefits (reductions in emissions of ammonia of 50-60kt per annum for the EU27 which represent around 2% of total ammonia emissions in 2020) with average costs of around €2,400 per tonne of NH3 abated. In contrast, the IA concluded that the inclusion of cattle farms under IED would result in limited additional ammonia emission reductions (estimated at around 40kt annually) compared to the large number of additional installations included (between 9,000 and 25,000 installations depending on the scenario), with an average cost of reducing ammonia emissions at nearly €8,000 per tonne.

9 Final reports available from: http://circa.europa.eu/Public/irc/env/ied/library?l=/studies/article_reports/final_reports&vm=detailed&sb=Title

However, the proposed clauses related to manure spreading were removed during the co-decision procedure and a review clause added instead.

In addition to the IED, manure spreading is also influenced by other legislation primarily related to the protection of waters e.g. Nitrates Directive. This Directive and other relevant legislation are described in more detail in the baseline legislative review section of this report (Section 3.4.1).

1.3 Objectives

The overall objectives of this study were to provide support to the Commission for the collection and analysis of data concerning the control of emissions from the spreading of manure. A large volume of work has already been completed in this field and the aim was to build on this; supplementing it with further data to be gathered direct from the Member States. This consultation focused on those main gaps identified through the literature review.

A range of possible options for the control of emissions from manure spreading have been developed and analysed with an assessment of the main relevant environmental, economic and social impacts in line with the Commission‟s impact assessment guidelines and associated guidance and toolkits. Possible options to be considered for the control of emissions from the spreading of manure include the use of existing instruments, the introduction of a new instrument, cross compliance measures and/or voluntary measures.

As set out in the technical specification, the study should aim to consider the following aspects:

 Defining and describing the different categories of slurries and manures produced by farms in the EU;

 Providing a detailed overview of the current production, use and application of these slurries and manures in the EU, in each of the Member States and EU-wide (origins, quantities, characteristics, management) and projected evolution over the next 10-15 years;

 Providing an indication of the potential for cost-effective emission reduction for the different manure management techniques both currently available and in development; and

 Providing a holistic assessment of the potential impacts of a range of options to control emissions from manure spreading focusing on a wide range of impacts including air, water, biodiversity and climate change.

1.4 Structure of this Report

This report is structured as follows:

 Section 2 sets out the overall approach for data collection including the Member State consultation undertaken;

 Section 3 describes the baseline definition;

 Section 4 describes potential options for analysis;

 Section 5 describes the approach and results of the data analysis completed; and

 Section 6 describes the overall conclusions for the study.

2. Data Collection

2.1 Overview

Building on data already available, the aim of the data collection stage of the study was to gather the following information:

 The quantities of manure linked with the number of animals with a clear distinction between those already covered by national permitting legislation (which can be based on the concept of BAT or can fix minimum standards for the operation of such installations) for the spreading of manure and those that are not. This should also provide a clear picture of the different types of manures (cattle, pigs, poultry, etc) produced across the EU;

 Nitrogen excretion factors (kg N/animal/year) (preferably at NUTS 2 level) and volumes of manure produced;

 A description of the most common manure management systems (e.g. solid systems/liquid systems);

 A description of the environmental impacts, including impacts to water, air, climate change and biodiversity, for each manure management technique;

 A description of the current regulation of the livestock sector across the EU, including environmental regulations and those linked to the Common Agricultural Policy (CAP) as well as the CAP review;

 Level of variation in environmental performance across the EU for each manure management technique and the environmental aspects linked to the important impact of the agriculture for the maintenance of permanent pastures.

2.2 Review of Literature and Relevant Data Sources

An overview of the information sources reviewed is included in Appendix A. It should be noted that for certain elements of the study (e.g. environmental impacts) a much wider range of literature has been reviewed; specific references are provided in each section. The conclusions of the literature review are that a lot of information is already available as a lot of research has been undertaken on managing emissions from agriculture. However some gaps were also identified in relation to specific manure management techniques adopted in certain Member States at national level. A consultation was undertaken, focusing on filling these gaps.

2.3 Member States Consultation

The consultation with Member States commenced after the submission of the Intermediate Report. It focused on gathering information to fill the gaps that were identified during the literature review. These primarily relate to existing legislation in place at a national level in relation to the spreading of manure and current practices. A copy of the questionnaire is included in Appendix B.

Answers were received from 19 Member States: Austria, Belgium (both Flanders and Wallonia), Cyprus, Estonia, Finland, France, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, the Netherlands, Portugal, Slovenia, Spain, Sweden and the UK. Most Member States answered all the questions with the exception of Hungary, Spain and Greece that could only provide partial information. In some cases, Member States provided links to additional materials and reports, however much of this additional information was in the Member States‟ national languages and within the scope of this study it was not feasible to translate all of the information.

All respondents with the exception of Spain provided details of their national legislation. Spain provided examples of measures adopted in some of its Autonomous Communities. Most Member States provided information on best practices, except Hungary and Portugal. Only two Member States mentioned labelling certification schemes, one in France recognising High Nature Value Farming, and one in Lithuania on organic farming. Both the UK and Ireland have a farm modernisation scheme which provides financial support for purchasing low emission spreading technologies.

Finally, some Member States provided details of their ongoing efforts to specifically reduce emissions (to air and/or water) from the spreading of manure, including Austria, Estonia, Germany, the Flanders region of Belgium, France, Italy and the Netherlands. Various incentives are provided and more stringent thresholds are in place than those in the EU legislation.

3. Baseline Definition

3.1 Overview

This section builds on the information gathered during the review of literature and Member State consultation and presents the baseline definition setting out the current situation in terms of manure production, environmental impacts, existing legislation, BAT and the current economic status. The aim is to define the numbers of holdings, animal numbers and manure volumes and types that could be affected by possible options to control emissions. In addition, current emissions and techniques already being applied are described. This section also describes current EU and national level legislation.

3.2 Manure and Slurry Volumes

The following section describes the current number of holdings, animal numbers and manure volumes and types as well as available information on potential future evolution.

3.2.1 Numbers of Livestock Heads and Holdings

Table 3.1 provides summary data on number of livestock heads according to different animals available from Eurostat for 2010.

Table 3.1 Number of Livestock Heads Disaggregated by Animals in EU27, 2010

Member State Cattle (1000 heads) Poultry (1000 heads) Pigs (1000 heads)

Dairy Cows Other Broilers Laying Other Sow Other Pig Cattle Hens Poultry

EU27 23,263 64,883 875,870 510,650 230,040 14,099 137,711

Austria 540 1,484 6,860 6,400 1,360 289 2,958

Belgium 521 2,072 21,900 11,680 790 524 5,906

Bulgaria 334 253 7,560 7,880 2,050 74 597

Cyprus 20 33 2,400 550 270 34 296

Czech Republic 381 948 15,290 8,990 1,040 190 1,718

Denmark 568 1,003 12,840 3,900 2,000 1,342 11,831

Estonia 96 145 1,040 860 40 35 353

Finland 289 636 4,620 4,680 10 150 1,216

France 3,720 15,786 143,600 78,060 74,470 1,127 12,795

Germany 4,165 8,370 67,530 35,280 26,090 2,365 25,207

Table 3.2 (continued) Number of Livestock Heads Disaggregated by Animals in EU27, 2010

Member State Cattle (1000 heads) Poultry (1000 heads) Pigs (1000 heads)

Dairy Cows Other Broilers Laying Other Sow Other Pig Cattle Hens Poultry

Greece 131 521 27,750 8,240 770 134 814

Hungary 245 462 13,920 10,300 24,480 277 2,931

Ireland 1,071 5,536 7,840 2,700 390 160 1,357

Italy 1,832 4,121 94,950 44,100 28,470 623 8,708

Latvia 166 228 1,650 3,460 50 48 335

Lithuania 353 386 5,140 3,080 380 80 780

Luxembourg 45 154 20 70 0 7 76

Malta 7 9 670 300 10 6 64

Netherlands 1,477 2,496 44,750 56,500 2,370 1,094 11,161

Poland 2,506 3,236 102,180 51,080 21,040 1,423 13,821

Portugal 278 1,152 20,250 11,980 3,120 238 1,675

Romania 1,151 838 34,260 39,070 5,860 489 4,856

Slovenia 108 364 2,800 1,500 600 36 346

Slovakia 154 311 6,570 5,850 240 62 526

Spain 910 4,930 118,850 59,480 22,580 2,635 22,077

Sweden 348 1,189 6,450 7,710 130 154 1,366

United Kingdom 1,843 8,220 104,180 46,950 11,430 500 3,943

Source: Eurostat

Figure 3.1shows the total number of cattle holdings (all categories and herd sizes) in each Member State.

Figure 3.1 Number of Cattle Holdings in each EU Member State (2010)

225,000

200,000

175,000

150,000

125,000

100,000

75,000

50,000

25,000

Italy

Spain

Malta

Latvia

France

Cyprus

Poland

Ireland

Austria

Finland

Estonia

Greece

Sweden

Belgium

Bulgaria

Slovakia

Slovenia

Hungary

Portugal

Romania

Denmark

Lithuania

Germany

Netherlands

Luxembourg CzechRepublic United Kingdom

Source: Eurostat

Note: Poland and Romania have a high number of cattle holdings which is not visible on the figure (we have reduced the scale for presentational purposes). Actual totals for Poland are 514,120 and for Romania 728,020.

Figure 3.2 shows total number of poultry holdings (all categories and flock sizes) in each Member State.

Figure 3.2 Number of Poultry Holdings in each EU Member State, EU 27 (2010)

600,000

500,000

400,000

300,000

200,000

100,000

Italy

Spain

Malta

Latvia

France

Cyprus

Poland

Ireland

Austria

Estonia

Greece

Finland

Sweden

Belgium

Bulgaria

Slovakia

Slovenia

Hungary

Portugal

Romania

Denmark

Lithuania

Germany

Netherlands

Luxembourg

CzechRepublic United Kingdom

Source: Eurostat

Note: Poland and Romania have a high number of poultry holdings which are not visible on the figure (we have reduced the scale for presentational purposes). Actual totals for Poland are 579,000 and for Romania 2,280,000.

Figure 3.3 show the number of pig holdings in each Member State.

Figure 3.3 Number of Pig Holdings in each EU Member State (2010)

200,000 180,000 160,000 140,000 120,000 100,000 80,000 60,000 40,000 20,000

Italy

Spain

Malta

Latvia

France

Cyprus

Poland

Ireland

Austria

Estonia

Greece

Finland

Sweden

Belgium

Bulgaria

Slovakia

Slovenia

Hungary

Portugal

Romania

Denmark

Lithuania

Germany

Netherlands

Luxembourg CzechRepublic United Kingdom

Source: Eurostat

Note: Poland and Romania have a high number of pig holdings which are not visible on the figure (we have reduced the scale for presentational purposes). Actual totals for Poland are 370,000 and for Romania 1,655,000.

The figure below presents the evolution of number of livestock heads per livestock category for the EU27 between 2007 and 2010 based on Eurostat data. O verall, the number of cattle has remained relatively stable with a slight decrease in the number of dairy cows (5%). The trend is similar for pigs, with a decrease of 14% of sows and overall 13% fewer reported animals in 2010 than in 2007. The reverse trend can be observed for poultry; the overall number of poultry increased with 9% more broilers and 12% more other poultry. The number of laying hens has remained stable during the period.

Figure 3.4 Evolution of Cattle, Poultry and Pigs Numbers between 2007 and 2010, EU27

15%

10%

0% Dairy Cows Other cattle Sow Other Pigs Boilers Laying Hens Other Poultry -5%

-10%

-15%

Source: Eurostat

3.2.2 Projections of Livestock Numbers

The figure below shows the projected numbers in LSU based on the CAPRI model coherent with the PRIMES 2012 baseline which is used as an input to the GAINS model and has been used for the central case modelling in IIASA (2013) TSAP #1010. They show an overall reduction in the number of LSUs by 2030, in particular for dairy cows and other cattle. Numbers of poultry and pigs remain relatively stable. Presented alongside for comparison are the projected numbers from the CAPRI model based on an older PRIMES 2010 baseline11. This has been modelled for sensitivity and comparison in the same IIASA report. This alternative set of projections predicted an increase in animal numbers up to 2030.

10 IIASA, 2013, Policy scenarios for the revision of the Thematic Strategy on Air Pollution

11 Some of the characteristics of the PRIMES 2012 and 2010 baselines are described in the TSAP #10 report with the main difference relating to assumed future economic development. The PRIMES 2010 baseline assumed much faster recovery following the economic downturn than that now assumed in the 2012 update. This is reflected by the fact that the 2012 baseline projects GDP to be 7% lower in 2030 than the earlier version. Other differences relate to assumptions around implementation and compliance with existing EU energy and climate policy.

Figure 3.5 CAPRI Projection of Livestock Units in EU28 for the (a) PRIMES 2012 and (b) PRIMES 2010 Baseline Scenario (million livestock units)

(a) PRIMES 2012 – as used for TSAP central case modelling in (b) PRIMES 2010 – presented for sensitivity and comparison IIASA (2013) against central case in IIASA (2013) Source: IIASA, 2013

This data is used as an input for the GAINS model where the data is further disaggregated by manure/slurry type/system as presented in the figure below. This shows an upward trend for pigs and cattle managed in liquid slurry systems whereas numbers in solid slurry systems are projected to decline. Poultry numbers are projected to rise.

Figure 3.6 Projected Numbers of Livestock Heads and Associated Manure Management Systems (relative to numbers in 2000)

30%

20%

10%

-10%

-20%

-30%

-40%

-50%

-60% 2000 2005 2010 2015 2020 2025 2030 Other Poultry 0% 3% 8% 12% 16% 21% 24% Laying Hens 0% 5% 16% 16% 18% 20% 22% Pig Liquid Slurry System 0% 3% 4% 7% 10% 10% 10% Other Cattle Liquid Slurry System 0% -4% 1% 5% 5% 7% 9% Dairy Cow Liquid Slurry System 0% 1% 7% 8% 8% 7% 6% Other Cattle Solid Slurry System 0% -12% -15% -7% -6% -4% -2% Pig Solid Slurry System 0% 3% -6% -12% -10% -18% -21% Dairy Cow Solid Slurry System 0% -24% -38% -44% -51% -53% -56%

Source: IIASA, GAINS Model

The agriculture model CAPRI includes projections that were used, for example, to calculate the evolution of greenhouse gases emissions from the agriculture sector in a report conducted by the JRC12. Similarly, the MITERRA Europe model included data to forecast the evolution of emissions and livestock according to different scenario.

12 JRC, 2008, Evaluation of the livestock sector's contribution to the EU greenhouse gas emissions (GGELS) http://ec.europa.eu/agriculture/analysis/external/livestock-gas/exec_sum_en.pdf

The evolution of the livestock numbers is strongly dependent on a number of key drivers such as population growth (human), land availability, evolution of the diet and external factors such as competition from other parts of the world. Additionally, the evolution of policy and legislation has a strong impact on the future trends. A report13 published in 2010 on the impact of the Nitrates Directive found that one of the possible outcomes if the derogation in the Nitrates Directive was not allowed is a reduction in the number of dairy cows. A recent report summarising the findings of a workshop focusing on „Future trends on manure processing activities‟ discussed these issues and concluded that it could be expected that larger livestock concentrations would be observed by 202014. It states that an industry structure based on small farms will not be sufficient to feed a growing population . One of the solutions identified is the concentration of farming production into „industrial‟ type units (also called „mega units‟) for which industrial solutions can be developed to deal with increased manure production whilst benefiting from economies of scale. The report mentions as a drawback the increase of transmittable diseases due to the increased concentration of animals. With the average size of farm installations growing but no „industrial solutions‟ adopted, the report concluded that larger areas of farmland would be needed to spread the manure created, which would be impossible due to the fact that no large net increase of farmland is likely. It therefore recommends the adoption of livestock manure processing technologies that avoid manure spreading.

3.2.3 Excretion Factors

Excretion factors represent the amount of nutrients excreted by the animals and are specific to each species. The excretion varies a lot according to the Member States (e.g. climate, feed) and even within the Member States. There is also a lot of variation between the stage of production when the excretion occurs (while the animal is housed or while grazing). Consequently there is a high number of excretion factors from a range of different sources, and it can be difficult to choose the most relevant one. The table below summarises the main sources of excretion factors. The uncertainty and the diversity of excretion factors listed in the current literature is one of the drivers for the current on-going study that Alterra is conducting. The objectives of the project are to bring clarity to the issue of excretion factors so that a recommendation on a single, common methodology to calculate N and P excretion coefficients can be identified. The aim is for this methodology to be flexible enough to allow local conditions to be taken into account, but without distorting the picture15. We have consulted with the team in charge of the project, but the findings of their study will not be available till later in 2013.

13 Alterra,2010, The impact of the Nitrates Directive on gaseous N emission

14 Agro Business Park, 2011, Future trends on manure processing activities

15 Personal communication with the project manager at Alterra, 24 March 2013

Table 3.3 Review of Available Excretion Factors

Source Information Available

IIASA , GAINS model The GAINS model includes very detailed excretion factors for:  Each Member State  Each type of livestock (cattle, poultry, swine, sheep, horses, buffaloes etc.), making a distinction between dairy cows and other cattle; laying hens and other poultry  Each type of manure system (e.g. solid and liquid)  Different activities / stage of excretion (e.g. housing and grazing) A range of sources seem to be used, from academic publication to Member States reporting under the UNFCCC.

Alterra, 2010, The impact of the Nitrates The report includes a detailed review of the available excretion factors. The report Directive on gaseous N emissions decided to rely on GAINS excretion factors, except for dairy cows for which it developed a method to estimate the N excretion from milk yields and the grassland yields at an EU level.

AMEC, 2012, Collection and analysis of data to The report collected data on excretion factors for poultry and cattle through a review of inform certain reviews required under Directive literature and consultation with Member States. 2010/75/EU on industrial emissions (IED): (a) Differentiated thresholds for the rearing of different poultry species

Alterra, 2007, Integrated measures in agriculture The report includes a detailed breakdown of excretion factors for different livestock to reduce ammonia emissions based on an investigation of excretion used in models and literature.

Alterra, 2011, Recommendations for establishing The report includes detailed excretion factors for: Action Programmes under Directive 91/676/EEC  Different type of livestocks (laying hens, broilers, dairy cows, calves, sow concerning the protection of waters against with piglets, fattening pigs, ewes, female goats, rabbit and horse) pollution caused by nitrates from agricultural sources  For some livestock distinction is made between the smaller breeds and the bigger ones  For dairy cattle and fattening pigs, it distinguishes between the N content of manure excreted, and the manure spread

Agro Business Park, 2011, Manure processing The report includes excretion factors for: activities  Different ages of the livestock (i.e. mother, youngster before and after weaning, breeding male, breeding female)  Different livestocks categories (i.e. cattle, poultry and pigs)

Alterra, On-going, Methodological studies in the The report will focus on bringing clarity into the issue of excretion factors. It will field of Agro-Environmental Indicators produce a recommendation on a single, common methodology to calculate N and P excretion coefficients can be identified. The ambition announced is for this methodology to be flexible enough to allow local conditions to be taken into account. The study is currently on-going, first draft of the final report is likely to be presented in late August.

The table below presents some of the available set of excretion factors for different livestock. It shows the variation between the same livestock categories and the importance to reach the most accurate estimate possible to have a clear indication of the amount of manure produced (note differences in units for certain sources).

Table 3.4 Mean N Excretion Factors for Different Livestock

Species Mean N Excretion N Excretion in Alterra 2010 Agro Business Park, 2011, GAINS Model (kg N (kg N per animal (kg N per animal per year) Manure Processing Activities per animal per year) per year) in – incomplete set (tonnes of manure per animal Alterra 2007 per year)

Fattening 11 General swine: 1.2 to 7.7 9.032 (AT) to 14.8 (DE) pigs

Sows 28 9.032 (AT) to 14.8 (DE)

Dairy 100 Replacement cattle <1 yr from General cattle: 3 to 24 55 (RO) to 126 (NL) Cows 25 to 45

Replacement cattle >1 yr from 40 to 80

Suckling cows > 2 yr from 50 to 90

Non-dairy 45 35 (PO) to 68.85 (IE) cows

Broilers 0.6 General poultry: 0.0016 to 0.28 0.40 (AT) to 1.5 (HU)

Laying 0.8 0.6 (PT) to 1.5 (HU) Hens

Ducks 1

Turkeys 2.1

3.2.4 Manure Volumes and Types

Manure Types

There are a number of different types of manure:

 Liquid manure (slurry), it is produced in intensive livestock rearing systems using concrete or slats instead of straw bedding. It consists of excreta produced by livestock in a yard or building mixed with rainwater and wash water and, in some cases, waste bedding and feed. Slurries can be pumped or discharged by gravity 16;

 Solid manure comprises material from covered straw yards, excreta from livestock, or solids from mechanical slurry separators. Solid manures can generally be stacked16; and

 Litter-based farmyard manures, which contain the material (e.g. straw, wood shavings) that have been used as bedding for animals and has absorbed the faeces and urine.

16 DEFRA, Managing livestock manures, 2001

By using separators, manure can be divided into a liquid (low dry matter slurry) and a manure (with high dry matter). Different livestock contribute to overall EU manure production in different ways.

Table 3.5 Breakdown of Different Types of Manure (%) by Livestock Type

Manure Type Cattle Poultry Pigs

Solid 27 8

Liquid 5 5

Slurry 41 3 84

Deep litter 28 97 3 Source: Agro Business Park, 2011

The production of manure depends on the following factors17:

 The number and type of animals present;

 Diet (e.g. relative proportion between concentrate and forage feed, food quality);

 The number of hours per day and days per year that the animals are indoors;

 The housing type (i.e. slurry or separated collection of urine and faeces);

 The addition of water (flush, spilling, rain);

 The addition of bedding material (litter); and

 The excretion per animal, a function of its diet and food/ water intake.

Manure volumes

There is no official reporting of the amount of manure produced across the EU, although estimates are available. A recent report estimated that the entire manure production in the EU is about 1.4 billion tonnes18. The same report includes a calculated estimate of the total amount of manure produced in the EU by livestock type. The table below reproduces the data calculated at a Member State and at EU27 level . It was indicated in a recent workshop presentation that there is no expected change in the volume of manure produced19 in the immediate future.

17 IIASA, 2012, Emissions from agriculture and their potential

18 Agro Business Park, 2011, Manure Processing Activities in Europe

19 Oene Onema, 2012, Livestock production and manure management in EU27, ReUse Waste Kick Off Meeting presentation

Table 3.6 Estimated Amount of Livestock Manure per Year in EU27 (in 1,000 tonnes)

Member Separated Pig Pig Pig Separated Cattle Cattle Poultry Poultry Total State Manure Slurry Deep Cattle Manure Slurry Deep Slurry Deep Litter Litter Litter

Solid Liquid Solid Liquid (in 1,000 % tonnes)

Austria 283 177 2,972 106 6,655 1,232 10,106 6,655 41 1,337 29,564 2

Belgium 575 359 6,039 216 8,448 1,564 12,829 8,448 83 2,679 41,241 3

Bulgaria 72 45 760 27 1,882 349 2,858 1,882 50 1,618 9,545 1

Czech 176 110 1,851 66 4,496 833 6,827 4,496 69 2,217 21,142 2 Republic

Cyprus 43 27 451 16 185 34 281 185 8 268 1,499 0

Denmark 1142 714 11,995 428 5,133 950 7,794 5,133 55 1,773 35,117 3

Estonia 34 21 354 13 793 147 1,204 793 5 162 3,524 0

Finland 128 80 1,339 48 3,060 567 4,646 3,060 14 454 13,395 1

France 1,368 855 14,362 513 61,948 11,472 94,068 61,948 502 16,230 263,264 19

Germany 2,483 1,552 26,073 931 43,134 7,988 65,500 43,134 337 10,881 202,013 15

Greece 87 54 913 33 2,066 383 3,137 2,066 91 2,932 11,762 1

Hungary 312 195 3,281 117 2,336 433 3,547 2,336 89 2,874 15,519 1

Ireland 136 85 1,424 51 22,379 4,144 33,983 22,379 No data No data 84,580 6

Italy 855 534 8,972 320 20,406 3,779 30,987 20,406 74 2,398 88,731 6

Latvia 35 22 372 13 1267 235 1,924 1,267 11 369 5,515 0

Lithuania 83 52 870 31 2,569 476 3,901 2,569 25 815 11,390 1

Luxembourg 7 5 78 3 655 121 994 655 0 9 2,527 0

Malta 6 4 64 2 59 11 90 59 1 46 343 0

Netherlands 1,118 699 11,742 419 13,315 2,466 20,219 13,315 277 8,945 72,515 5

Poland 1,319 824 13,847 495 18,993 3,517 28,841 18,993 354 11,447 98,630 7

Portugal 216 135 2,269 81 4,794 888 7,280 4,794 111 3,596 24,164 2

Romania 570 356 5,987 214 8,943 1,656 13,581 8,943 241 7,780 48,272 3

Slovakia 68 43 718 26 1,612 299 2,448 1,612 38 1,222 8,086 1

Slovenia 40 25 419 15 1,566 290 2,378 1,566 13 405 6,716 0

Spain 2,428 1,518 25,494 911 20,060 3,715 30,462 20,060 394 12,726 117,766 9

Sweden 141 88 1,482 53 5,126 949 7,784 5,126 20 660 21,430 2

United 425 266 4,462 159 32,991 6,110 50,098 32,991 485 15,676 143,663 10 Kingdom

EU27 14,151 8,845 148,590 5,307 297,870 54,606 447,766 294,870 3,387 109,518 1,381,911 100 Source: Agro Business Park, 2011

The figure below (Figure 3.7) presents the share of production of manure per Member State. It shows that France and Germany are generating together 35% of the total volume of manure calculated. The UK, Spain, Poland, the Netherlands, Italy and Ireland are each responsible for 5 to 10% of the total volume of manure produced.

Figure 3.7 Production of Manure per Member State (as a % of EU27 total)

United Kingdom Sweden Spain Slovenia Slovakia Romania Portugal Poland Netherlands Malta Luxembourg Lithuania Latvia Italy Ireland Hungary Greece Germany France Finland Estonia Denmark Cyprus Czech Republic Bulgaria Belgium Austria 0% 2% 4% 6% 8% 10% 12% 14% 16% 18% 20%

Nitrate and Phosphate Produced from Manure

The following graph illustrates the estimated N and P production from manure by different types of animals. These nutrients are responsible for most of the environmental impacts described in the section below.

Figure 3.8 Estimated nitrogen Manure Production (ton N), left, and Phosphorus Manure Production (ton P), right, Distributed for Different Animal Types for EU15 countries

Source Grizzetti et al., 200720

The input of manure per agricultural area differs across regions of the EU. The inputs of N and P are shown in Figure 3.9 and Figure 3.10, respectively.

20 Grizzetti B., Bouraoui F. Aloe A.(2007) Spatialised European Nutrient Balance. JRC-IES EUR 22692 EN

Figure 3.9 European Map of Nitrogen Manure Input per Agricultural Area in EU15, averaging on 10 km2 area

Source Grizzetti et al., 2007

Figure 3.10 European Map of Phosphorus Manure Input per Agricultural Area in EU15, averaging on 10 km2 area

Source Grizzetti et al., 2007

It is important to note that in Figure 3.9 and Figure 3.10, the white colour in Sweden and Finland indicates the absence of agricultural areas within the 10 km2 area.

Manure Treatment

A total of 45 manure processing activities have been described in a recent report21. This report suggests on the basis of compilation and analysis of data from EU Member States that manure processing currently has reached an average level of 7.8% of the livestock manure production, with a big variation from country to country. The manure processing activities can be broken down into the following categories (note in some instances these techniques are combined):

 Anaerobic treatment is the most popular manure treatment strategy. It was reported for 256 installations treating 88 million tonnes of livestock manure and other products, equal to 6.4% of the entire livestock manure production in EU. Anaerobic treatment is the most used technique in Germany;

 Separation of manure through mechanical or chemical processes. The report found that this is chosen as a manure treatment strategy in 11,130 installations treating 49 million tonnes of livestock manure and other, equal to 3.6% of the entire livestock manure production in EU. It is interesting to note that the solid component of manure once separated can be dried and used as litter or bedding for livestock although there is no data available on the up-take of this technique;

 Additives and other pre-treatment. The report found that this is chosen as a manure treatment strategy in 668 installations treating 7.5 million tonnes of livestock manure and other products, equal to 0.5% of the entire livestock manure production in EU. The technique is most used in the UK.; and

 The other techniques represent respectively 0.8% and 0.7% of the entire manure production in the EU. They are treatment technologies for the solid fraction of the manure and treatment technologies for the liquid fraction of the manure. Finally, air cleaning is applied for 0.3% of the total manure production in the EU. The most used technique is air biofiltration in manure processing plant.

Manures that are not treated are either spread on arable or grassland, used as fuel (poultry manure) or exported. Data are available on the burning of poultry manure and how this expected to evolve up to 2050, through the GAINS model, but these data show that only three Member States (i.e. Ireland, the Netherlands and the UK) incinerate poultry manure. Data for 2010 are 4% of total poultry manure incinerated in Ireland, 30% in the Netherlands and 36% in the UK.

21 Agro Business Park, 2011, Manure Processing Activities in Europe

3.3 Environmental Impacts

3.3.1 Overview

Intensive livestock farming systems can place significant pressures on the environment, in particular through the production of manure. Most of these effects are due to the nitrogen (N) and phosphorus (P) in the manure that may result in emissions as gases or soluble ions. Manure can be spread on land to increase the fertility and condition of soils, through beneficial impacts, for example on microbial activities through increasing organic matter. However, it can also result in negative impacts on climate change, water, air quality, and soils. All impacts depend on what practices are implemented and on local conditions. The figure below represents schematically the environmental impacts from manure spreading on land. The table following this presents a snapshot of environmental impacts from manure spreading and storage on air, water, soil and biodiversity and ecosystem services.

Figure 3.11 Schematic Overview of the Environmental Impacts of Manure and Related Processes

Legend: Green boxes represent impacts on air, blue boxes impacts on water and brown boxes impacts on soils. Boxes with only a delineation represent the chemical elements involved and coloured text represents processes.

Table 3.7 Overview of Environmental Impacts of Manure Spreading

Impacts of Domain of Impact Manure Description of the Impacts of Manure Spreading Spreading

Air Climate change Emissions of CO , N O and CH which all contribute to the greenhouse (-) 2 2 4 effect

Avoided impacts due to the reuse of residues, while the use of mineral (+) fertilisers would require energy and resources to be produced

Air quality Manure spreading and storage impacts on air quality due to (-) considerable emissions of pollutants, such as ammonia (NH3) and 22 particulate matter (PM) This leads to eutrophication, acidification, and formation of secondary PM which is harmful for health.

Odour Manure spreading creates unpleasant odours due inter alia to (-) emissions of hydrogen sulphide (H2S), methane (CH4) and nitrous oxide (N2O)

Noise (-) Noise is caused by machinery (and animals).

Water Water eutrophication, Eutrophication from emissions of N and P and NH3 deposition acidification and pollution Acidification from emissions of NH3 Drinking water standards require N and P concentration in water to be (-) below certain thresholds Medicinal residues can be leached into water and cause negative impacts to fauna

Soil Soil structure and Manure brings organic matter beneficial to soil conditions (soil structure composition and soil carbon, soil biodiversity). The microorganisms that benefit (+) from increased soil organic matter improve soil degradation indicators, i.e. reduce soil compaction and improve water circulation/retention.

Soil water retention Improved soil conditions by the beneficial impact of organic matter on soil biodiversity and structure leads to improved water filtration from (+) soil. On drought-prone soils, higher organic content will provide better water retention.

Heavy metals Manure sometimes contains heavy metals, which increase soil heavy metal concentration and catalyses uncontrollable soil chemical (-) reactions. This may result in high soil concentrations of Cu, Zn, Mn, Fe that are useful to plants at low concentrations but may harm plants at excess concentrations, and of Cd, and Se that are harmful.

Soil compaction Use of heavy machinery (often by contractors) can lead to soil (-) compaction, especially if spreading takes place in inappropriate conditions

Biodiversity and Biodiversity Manure increases the organic matter content of soil and thus microbial ecosystem diversity services (+) Manure provides food to diverse organisms and increases their diversity and biomass, including e.g. beneficial insects and possibly birds

Manure contributes e.g. to increased growth of grasses and may (-) negatively impact birds that are using short grasses to nest

Ecosystem services (+) Increased productivity of land, nutrient cycling

(-) Eutrophication leads to loss of drinking water and bathing areas

22 Zhang, Air Quality and Community Health Impact of Animal Manure Management www.ncceh.ca/sites/default/files/Air_Quality_and_Animal_Manure_Sept_2011.pdf

3.3.2 Emissions to Air

Ammonia and CH4 emissions originate from the slurry itself. Ammonia is emitted due to the pH controlled

equilibrium of NH4 + and NH3. Methane is formed by methanogenic bacteria in the slurry during storage. In

contrast, N2O is formed when slurry interacts with soil, when the slurry surface dries up during storage and in the presence of an energy source for the denitrifying bacteria (Wulf, Vandré, & Clemens, unknown).

Ammonia

Ammonia nitrogen usually represents 40 to 75% of the total nitrogen of slurry (INRA, 2012). At EU27 level, in 2010, the agriculture sector is responsible for 94% of ammonia emissions23. Other contributing sectors are road transport, waste treatment and some industrial processes (responsible together for around 5% of the total EU27 ammonia emissions). Mainly formed by enzymatic conversion of the urea in urine, the ammonia concentration and the pH of the slurry are important factors influencing ammonia emissions (Canh, Aarnink, Verstegen, & Schrama, 1998). Ammonia is responsible for the formation of “secondary” particulate matter (mainly nitrates and sulphate) which affects human health with effects on respiratory and cardiovascular systems and causing premature mortality. Ammonia is also harmful to ecosystems through acidification and eutrophication caused by excess nutrients leaching into freshwaters and disrupting plant communities, leading to a loss of biodiversity.

The evolution of ammonia emissions for the EU27 1990 - 2010 is presented in Figure 3.12. It shows that the total contribution from broilers has increased by 9% over the period from 98 Gg to 106 Gg. However ,the contribution from laying hens has decreased by 21% during the same period. Ammonia emissions from dairy cattle and non- dairy cattle decreased by respectively 37% and 24%. The total contribution from pigs has overall decreased by 36%. These trends are due to a combination of factors the most significant of which are recent changes in overall livestock numbers (increases and decreases) as well as the uptake and application of more efficient feeding, housing, manure storage and application strategies and techniques.

23 EEA, Ammonia (NH3) emissions (APE 003) - Assessment published Dec 2012, accessed 24/10/2013 http://www.eea.europa.eu/data-and-maps/indicators/eea-32-ammonia-nh3-emissions-1/assessment-2

Figure 3.12 Ammonia Emissions for the EU27 from Cattle, Pigs and Poultry for years 1990-2010 (in Gg)

Broilers Cattle dairy Cattle non-dairy Laying hens Other poultry Swine 1400

1200

1000

800

600

400

200

0 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Source: CLRTAP data

The figure below presents the ammonia emissions from cattle, pigs and poultry by individual Member State for 2010.

Figure 3.13 Ammonia Emissions from Cattle, Pigs and Poultry by Member State, 2010 (in Gg)

Broilers Cattle dairy Cattle non-dairy Laying hens Other Poultry Swine

500

450

400

350

300

250

200

150

100

Source: CLRTAP data

Finally the figure below presents the contribution of the different agricultural sources of ammonia emissions in the EU27. Cattle (both dairy and non-dairy) represent the majority of the emissions reported under the CLRTAP.

Figure 3.14 Agricultural Sources of Ammonia Emissions for EU27, 2010

107 Gg, 5% 567 Gg, 24% 723Gg , 31% Broilers Cattle dairy 75 Gg, 3% Cattle non-dairy Laying hens Other Poultry Swine 149 Gg, 6%

724Gg , 31%

Source: CLRTAP data

Whilst CLRTAP presents clear emissions data for Member States, these are not disaggregated by activity. There is no distinction made in the national inventories between the emissions arising from livestock housing, grazing, manure storage or manure spreading. There has been a lot of work carried out to try to fill these gaps.

A report24 looking at the impact of the Nitrates Directive on agriculture emissions of ammonia carried out some detailed modelling to understand the sources of emissions. It found that most of the emissions of ammonia in the agricultural sector are coming from housing and storage systems (44%) followed closely by manure application (29%). AMEC in a recent report25 looked at identifying the share of emissions targeted by existing European environmental legislation and those emissions that are currently unregulated. Part of this work included splitting emissions by activities based on multiple data sources. For ammonia, it included distinguishing emissions from housing for livestock covered by the IED (based on E-PRTR data), housing for other livestock, grazing, manure application and use of other fertilisers than manure (based on data reported under CLRTAP).

The study found that emissions from the spreading of manure represented around 24% of the total emissions of ammonia in agriculture, this equates to around 790kt of emissions. Based on the data available, the study estimated

24 Alterra, 2010, The impact of the Nitrates Directive on gaseous N emissions Effects of measures in nitrates action programme on gaseous N emissions

25 AMEC, 2013, Identification of the contribution to pollution and emissions of activities and/or pollutants not regulated under EU environmental law. Study for the European Commission, ongoing.

that only 5% of ammonia emissions from agriculture came from IED regulated farms. However, this number represents only the quantity of emissions of ammonia reported by Member States under the E-PRTR in 2010 for activities 7a, 7ai, 7aii and 7aiii (intensive rearing of poultry and swine over IED threshold). This figure appears much lower than expected or estimated in previous report26, it is highly likely that it only includes housing emissions (as manure is generally spread off-site so technically not included under IED). In addition, the E-PRTR has an emissions reporting threshold (10,000 kg/year for ammonia) meaning that some sites would not have to report data, leading to an underestimate of ammonia emissions from housing. Furthermore, reporting under E-PRTR appears to be incomplete, for example, in 2010 Eurostat data indicates that there are a total of 9,000 poultry farms over the 40,000 heads IED threshold. However, only 1,499 installations have reported ammonia emissions to air in the E-PRTR under the 7ai code (intensive rearing of poultry) which represents only 30% of total IED regulated farms. Whilst it is possible that some/all of these missing farms are below the E-PRTR emissions‟ reporting threshold, it highlights that some housing emissions are not accounted for.

The figure below (Figure 3.15), taken from the AMEC (2013) study, presents the split of emissions from the spreading of manure for cattle, poultry and pigs. It shows that ammonia emissions arise primarily from the spreading of cattle manure (almost 520 kt).

Figure 3.15 Split of NH3 Emissions from the Spreading of Manure, EU27, 2010

13%

Spreading of manure - poultry

22% Spreading of manure - pigs Spreading of manure - 65% cattle

Source: AMEC, 2013

Methane

Methane emissions are not reported under the CLRTAP or the National Emissions Ceilings Directive. However, Member States report them in their annual submissions under the UN Framework Convention on Climate Change.

26 IIASA, 2007, Measures in Agriculture to reduce ammonia emissions

The figure below (Figure 3.16) presents the share of emissions of methane from agriculture sector in comparison with other agro-industrial sectors. Agriculture emissions represent almost half of the total emissions of methane; other important sources of emissions are the waste and energy sectors.

Figure 3.16 Source of Methane Emissions in EU27, 2010

Energy 19% Waste Industrial 31% Processes, less than 1%

LULUCF (land use, land use change and forestry) 1% Agriculture 49%

Source: UNFCCC, 2010

The figure below presents the emissions for both enteric fermentation (cattle, poultry and pigs) and manure management (cattle, poultry and pigs). Over the past twenty years overall emissions of methane from agriculture have been reduced by over 2,000 Gg (representing around 26% of 2010 emissions). However, it is noticeable that in the past ten years, emissions from cattle enteric fermentation and manure have remained stable.

Figure 3.17 Evolution of Methane Emissions per Livestock Category (in Gg)

14000

12000

4.B.9.Manure Poultry

10000 4.B.1. Manure Cattle

4.B.8. Manure Swine 8000 4.B. Manure Management (excluding cattle, poultry and swine) 4.A.8. Enteric Fermentation Swine 6000

4.A.9. Enteric Fermentation Poultry

4000 4.A.1. Enteric Fermentation Cattle

4.A. Enteric Fermentation (excluding cattle, poultry and swine) 2000

Source: UNFCCC, 2010

Through the same reporting source, it is possible to see the individual Member States‟ contribution to overall emissions of methane. The figures include only emissions from manure management from cattle, poultry and pigs.

Figure 3.18 Emissions of Methane from Manure Management in each Member State in 2010 (in Gg) 700 600 500 400 300 200 100

Italy

Spain

Malta

Latvia

France

Cyprus

Poland

Ireland

Austria

Estonia

Greece

Finland

Sweden

Belgium

Bulgaria

Slovakia

Slovenia

Hungary

Portugal

Romania

Denmark

Germany

Lithuania

Netherlands

Luxembourg

CzechRepublic United Kingdom

Source: UNFCCC, 2010

The high emissions from France are explained in its National Inventory Report submitted in 2010 as required under the UNFCCC. It states that the emissions of methane from agriculture are due to France‟s choice of manure management relying on „lisier‟ (liquid manure) for 100% of the young cattle herd and 85% of the swine.

Nitrous Oxides

Emissions of nitrous oxides are reported under the UN Framework Convention on Climate Change. They are reported per type of manure management system (i.e. solid system, liquid system, anaerobic lagoon and other). The figure below presents the sources of emissions of nitrous oxides in EU27. Agriculture is responsible for over 75% of the emissions. The energy sector is another important source of nitrous oxides emissions (10%).

Figure 3.19 Source of N2O Emissions in EU27, 2010

LULUCF (land use, land use change Industrial and forestry) Waste Processes 1% 4% Energy 5% 10% Solvent and Other Product Use 1%

Agriculture 77%

Source: UNFCCC, 2010

The figure below presents the emissions from manure systems reported by the EU27 during the period 1990-2010. The relevant reporting codes are referring to the type of manure management system (e.g. liquid, solid, other).

Figure 3.20 Emissions of Nitrous Oxides from Manure Systems 1990-2010 (in Gg) 140

120

100 4.B.14. Other Animal Waste 80 Manure Storage 4.B.13. Solid Storage and Dry Lot 60

4.B.12. Liquid System 40

1994 1995 1996 1997 1998 2003 2004 2005 2006 1991 1992 1993 1999 2000 2001 2002 2007 2008 2009 2010 1990

Source: UNFCCC, 2010

Figure 3.21 below is from the same source, and presents the total emissions of nitrous oxide from manure management for each Member State. Further investigations were conducted to understand why France, Poland and Italy report such high emissions of nitrous oxide from manure management. France describes in its National Inventory Report (NIR) for 2012 which reports on 2010 data to the UNFCCC, that storage of manure is the principal source of N2O emissions under the manure management reporting category. It also states that there is a

50% uncertainty relative to the emissions factors used to calculate the N2O emissions. Italy reports the same source of emissions in its 2012 NIR, 88% of its emissions of N2O are due to solid storage source. Poland states in its

2012 NIR that N2O emissions for 2010 were estimated using the recommended IPCC methodology. No further information appears to be available to explain these high numbers.

Figure 3.21 Emissions of Nitrous Oxide from Manure Management per Member State in 2010 (in Gg) 18 16 14 12 10 8 6 4 2

Italy

Spain

Malta

Latvia

France

Cyprus

Poland

Ireland

Austria

Estonia

Greece

Finland

Sweden

Belgium

Bulgaria

Slovakia

Slovenia

Hungary

Portugal

Romania

Denmark

Germany

Lithuania

Netherlands

Luxembourg CzechRepublic United Kingdom

Source: UNFCCC, 2010

There are some limitations with the UNFCCC data as these are not disaggregated by activity. However, the literature review identified additional sources of information providing further disaggregation. A modelling of emissions27 proposed a split of the sources of nitrous oxide emissions from different activities (i.e. manure, grazing, fertilizer, housing, etc.). This has been reproduced in the figure below:

27 Alterra, 2010, The impact of the Nitrates Directive on gaseous N emissions, Effects of measures in nitrates action programme on gaseous N emissions

Figure 3.22 Proportion of Emissions of Nitrous Oxides from Agriculture Activities in 2008

8% 15%

Manure 6% Grazing 29% Fertilizer Crop residues 8% Peat soils Housing Indirect 11%

23%

Source: Alterra, 2010

Particulate Matter (PM)

In 2008, agriculture contributed to around 4% of primary PM2.5 emissions and around 12% of primary PM10 emissions (EEA, 2010).

Primary particulate matter (PM) can be an issue mostly in intensive indoor breeding units such as poultry and pig housing systems. In particular, livestock farmers are exposed to particulate matter concentrations inside their animal houses that are a factor of 10 to 200 times higher than those of the outside air (Aarnink & Ellen, 2007). Source contributions in the poultry houses vary amongst poultry housing systems, but most particles originate from:

 Feathers (ranging from 4 to 43% in fine PM (PM2.5) and from 6 to 35% in coarse PM (PM between 2.5 and 10 micrometers in diameter);

 Manure (ranging from 9 to 85% in fine and from 30 to 94% in coarse PM) (Cambra-Lopez, 2010); and

 Feed, bedding, micro-organisms and fungi to a lesser extent (Aarnink & Ellen, 2007).

In pig houses, source contributions vary amongst different systems, but most particles originate from manure (ranging from 70 to 98% in fine and from 41 to 94% in coarse PM), feed, skin particles and, when used, from bedding (Cambra-Lopez, 2010) (Aarnink & Ellen, 2007). When expressed in mass, larger particles from wood shavings and especially skin increase in importance compared with the number of particles (Cambra-Lopez, 2010).

Ammonia (NH3) is also a precursor of secondary PM emissions. A 2003 article on this issue indicated that in Europe secondary particles constitutes a large part of PM10 emissions (from 50% to 90%) and around 50% or more of PM2.5 emissions28. Once emitted, ammonia can react with sulphuric and nitric acids to form ammonium sulphate and nitrate aerosols, respectively. There is not a lot of information available on the share of ammonium and nitrate contained in emissions of PM2.5 but research carried out in 2004 in the USA estimated that these substances could contribute to 13% of the PM2.5 concentration levels each (from 3 to 20% for ammonium and 4 to 37% for nitrate) (Hodan & Barnard, 2004). There are no similar data available for PM10 concentrations. Whilst ammonia is not the only precursor of secondary PM, it plays an important role in its formation, and a reduction of emissions of ammonia would lead to a reduction of secondary PM.

Depending on weather conditions such as solar insulation, temperature, humidity and presence of other constituents in the atmosphere, ammonium nitrate can contribute to high PM2.5 and PM10 concentrations (Hamaoui-Laguel, Meleux, Beekmann, Bessagnet, Génermont, & Celier, 2009), the latter being higher in case of high temperature and humidity, inducing the formation of more particles (Walker, Whitall, Robarge, & Paerl, 2004) (Hodan & Barnard, 2004) (Hodan & Barnard, 2004). A 2003 study on ammonia volatization29 has highlighted a lack of agreement about the specific influence of weather conditions on the volatilization of ammonia. It indicates that the following effects were observed:

 Temperature, relative humidity and wind speed are the main relevant factors. A high temperature of the manure increases the formation of gaseous ammonia in the manure and decreases the solubility of ammonia in water. Depending on wind conditions, the diffusion of ammonia into the air increases or decreases. High wind speeds will dry the upper layer of the soil, and create improved infiltration, resulting in decreased ammonia volatilization. In windy conditions, ammonia is removed by the wind and if the ammonia concentration in the air stays low, this will stimulate further ammonia volatilization;

 Manure may get dried to such an extent that a crust is formed at the outer layer of the manure. This crust may act as a barrier against diffusion of ammonia from the manure;

 In cases where the ammonia concentration in the air is lower than the concentration in the manure, the evaporation stimulates ammonia volatilization. The evaporation is affected by ambient temperature, air humidity and solar radiation; and

 Rainfall before manure application affects the soil moisture content; it may dilute the manure or decrease the infiltration of the manure into the soil. Rainfall directly after manure application improves the infiltration into the soil and decreased the volatilization. Rainfall is also responsible for decreasing evaporation and in that way indirectly decreases volatilization.

PM impacts on human health more than the environment. Concerning environmental impacts, deposition of acidic compounds contained in PM contributes to acidification of soil and eventually water pollution (see respective

28 Erisman J.W. and Schaap M., 2003. The need for ammonia abatement with respect to secondary PM reductions in Europe. Environmental Pollution 129, 159–163.

29 Huijsmans, J.F.M., 2003 Manure application and ammonia volatilization

sections below). PM are inhaled by farm workers and may cause the development of respiratory disease (Takai, Nekomoto, Dahl, Okamoto, Morita, & Hoshiba, 2002). Moreover, dust particles are capable of transporting different harmful chemical compounds and microorganisms. It may cause risks of airborne infections of animals, such as Salmonella. It has been also shown that viable bacteria and viruses carried into the air by dust particles may have a greater ability to survive (Takai, Pedersen, Johnsen, Metz, & Groot Koerkamp, 1998). Whilst primary PM is likely to have more localised impacts on health and the environment, the formation of secondary PM from ammonia can contribute to health and environmental impacts on a wider geographical scale due to their increased transportation over longer distances.

Trends

The data for ammonia, methane and nitrous oxide emissions all show a gradual decline in emissions over the past twenty years. However it seems that emissions have stabilised in the last decade30. The figure below presents the trends for total emissions of ammonia from 1990 to 2011 (trends in livestock emissions only are presented above in Figure 3.12).

Figure 3.23 Trends in Ammonia Emissions in EU27 1990-2011 (kt)

Source EEA Data Viewer A reduction in livestock numbers, nitrogenous fertiliser use (due to the increase in their efficiency) and an improvement in the handling and management of organic manures are thought to be the main factors to explain this

30 The JRC report on climate change emissions has modelled emissions from the livestock sector in the EU using the CAPRI model. For EU27, the CAPRI model showed lower nitrous oxide emissions following leaching of nitrogen and lower methane emissions from manure management.

trend31. The assessment conducted under the Second European Climate Change Programme by the Working Group on Agriculture and Forestry concluded that the changes in manure management systems have had a large positive impact on CH4 and N2O emissions (and likely to have impacted on NH3 as well although not the focus of the report). Concerning manure management systems, it concludes that overall the liquid systems tend to be more relied on for dairy cattle and swine, but decrease for non-dairy cattle.

Moreover, the consumption of fertilizer is decreasing at the same time that crop production is increasing. Whilst no firm quantification of the role of the CAP on this is provided, it is thought that agri-environment measures and the obligation to respect minimum environmental standards as a condition for payments have had a role in incentivising the use of organic manures. The increase in price of fertilizers is also a driver toward more use of organic manures. The reduction of the amount of fertilisers used has resulted in a reduction of N2O and NH3 emissions.

The Nitrates Directive has also had a positive impact leading to the reduction of some emissions of ammonia and nitrous oxide. A 2010 report32 looked at assessing the effects of the Nitrates Directive on emissions of ammonia. It developed two emissions scenarios for 2000 and 2008: one with the application of the provisions of the Nitrates

Directive and one without. In 2000, the total NH3 emissions resulting from the no Nitrates Directive scenario were on average around 1% higher than with the Nitrates Directive (ranging from -1.2% in Luxembourg to 5% in the

Netherlands). In 2008, these results were more significant as emissions of NH3 were over 3% higher in the scenario without the Nitrates Directives (reaching 15.8% for the Netherlands and 11.7% for Ireland). Similar results were observed for N2O with emissions over 3% higher in 2000 and 6% higher in 2008 without the Nitrates Directive.

The reduction of methane emissions is mainly thought to be due to the decrease in the number of cattle which is to a large extent a consequence from the reforms of the CAP. All Member States have reported a decrease in the number of dairy cattle from 2000 to 2010 and most Member States have reported over the same period a decrease in non-dairy cattle. The reform of the CAP has entailed a shift from the guaranteed prices system to direct aid payments in the arable, beef and veal sectors.

It is also considered that the uptake of low emissions techniques and the gradual improvement of farming techniques has led to improvements in the efficiency in the management of manure and its spreading33.

31 More details can be found in “The Second European Climate Change Programme Final Report” Working Group ECCP Review, Topic Group Agriculture and Forestry.

32 Alterra, 2010, The impact of the Nitrates Directive on gaseous N emissions, Effects of measures in nitrates action programme on gaseous N emissions

33 IIASA, 2011, Integrated ammonia abatement – Modelling of emission control potentials and costs in GAINS

3.3.3 Odour

Odours originating from the spreading of livestock manure are the result of many different compounds34. Most odours are created by the anaerobic decomposition of wet organic matter such as manure, feed or silage, enhanced by warm temperature, which are released during physical disturbance (e.g. spreading). During this process, organic gases (volatile organic compounds or VOCs) and inorganic gases (e.g., ammonia and hydrogen sulphide) are produced (Shaw, 2009). They are then transported by dust particles. PM can also generate unpleasant smells which affect downwind neighbours (Robert, 2001). Odour will dissipate on dry and windy days, but will tend to linger if the weather is humid and windless (Toombs, 2013). Frequency, duration, offensiveness and sensitivity are the main factors of odour acceptability from the farm neighbourhood (Toombs, 2013). However, perception is not always objectively linked to measured odour and some people may be more disturbed than others.

3.3.4 Noise

Noise issues can have various origins, depending on the type of livestock farmed. Agricultural workers are the group of people most exposed to noise. The main noise exposure comes from machinery and in intensive indoor breeding since it concentrates animals and machines (in particular vocalisation noise, from pigs and turkeys, and power units of high pressure cleaning sprayers in pig husbandry (Silsoe Research Institute and RMS Vibration Test Laboratory, 2004)). No specific data were found concerning noise from manure spreading machinery. Nonetheless, more generally, important improvements have been done to reduce tractor cab noise.

3.3.5 Impacts on Soil

Eutrophication

Excess N and P in soils can lead to soil eutrophication, although this is much less reported than water eutrophication (see next section). Soil eutrophication may result in35:

 Loss of biodiversity and changes to vegetation and ecosystems;

 The potential for increased microbial activity resulting in more rapid organic matter decomposition and greenhouse gas emissions; and

 The potential for an increase of nutrients in surface water and groundwater.

34 Odour is measured according to 3 parameters: quality, strength and occurrence. Odour quality is a comparison with a known odour such as rotten eggs or roses. Strength is the amount of fresh air needed to dilute odorous air to the threshold odour level where it can just be detected. Occurrence is the frequency and length of time the odour persists (Toombs, 2013).

35 SEPA (undated) Threats to soil quality, Scottish Environment Protection Agency website, available from: http://www.sepa.org.uk/land/soil/threats_to_soil_quality.aspx

Acidification

When airborne particles redeposit into the ground, in the form of acid rain, they can cause acidification by being transformed into nitric acid in the soil. In addition to ammonia that is responsible for 24% of acidification, other gases such as sulphur dioxide (SO2), nitrogen oxides (NOx), mostly produced by power plants and transport, also contribute around 44% and 32%, respectively (Sensi, 1994). This assumes that all NH4+ gets nitrified.

Even where naturally acid soils exist, such as bogs, artificial acidification can cause harmful effects on ecosystems. More precisely, acidification has an effect on the solubility of compounds in the soil, and thus on the availability of some toxic elements, especially aluminium and manganese (Slattery, Conyers, & Aitken, 1999). Aluminium toxicity is the most common plant symptom on acidic soils since aluminium is a part of most clay particles of soil (Slattery W., 2000). If the soil pH decreases under a certain limit (generally considered to be around 5 (e.g. 5.5 (according to Johnson & Zhang, 1988) and 4.8 (Slattery, Conyers, & Aitken, 1999), aluminium becomes soluble. Too high a concentration of aluminium in soil water causes crop or tree failure and yield loss by interfering with the crop capacity to absorb water and nutrients, especially phosphorus. The weakening of the crop also makes it less able to resist pests. The effect of pH is very quickly magnified: if pH decreases by 1 point, the quantity of dissolved aluminium is 1000 times greater. Availability of manganese cations are also proportional to pH but to a lesser degree than aluminium (when pH decreases by 1 point, manganese availability increases 100 fold). Manganese affects plant and tree growth, resulting in stunted, discoloured crops, reduced growth and poor yields (Johnson & Zhang, 1988).

By increasing the solubility of mineral elements in the soil, acidification also has impacts on the leaching of nitrogen, and thus on water pollution, and increased soil erosion (Slattery & Hollier, 2002). Acidification also has an impact on biodiversity, see section below.

Heavy Metals

Manures contain plant functional nutrient metals such as copper (Cu), zinc (Zn), manganese (Mn), iron (Fe), and may contain trace amounts of non-functional elements such as cadmium (Cd) and selenium (Se) (Mench & Baize, 2004). The metals contained in manure have different sources. The essential heavy metals come from feed where they are naturally present. Cu and Zn may also be added to diets in the form of mineral supplements, especially for pig rearing. Heavy metals that are not assimilated by the animals‟ bodies are excreted in manure. Thus, although manure is not the main origin of heavy metal in soil (but is a result of pollution from industries, traffic, sewage sludge, etc.) manure spreading, or manure excreted by animals on fields will contribute to heavy metal concentrations in soil. When the soil becomes saturated due to repeated addition, more of the metal remains in a soluble form and thus can leach and contaminate or pollute water (Schoenau, et al., 2004).

Concentration and availability of heavy metal in soils are influenced by several factors. Indeed, the amount of heavy metal excreted, and thus deposited on land, depends on the type of animal reared: dairy cattle seem to excrete less heavy metal than intensively reared pigs or laying hens, which is directly related to metal concentration in feed (Nicholson, et al., 1999). Soil composition and texture influence heavy metal availability. For example, grassland soils, which have mostly a pH value of 6, have a lower capacity to fix metals like copper and zinc into relatively insoluble forms compared to land with high pH, high content of calcium carbonate and high clay content.

(Schoenau, et al., 2004, McCauley, 2009). A decrease in soil pH, that can be in part driven by the nitrogen content of manure or slurry spread, can also increase heavy metal solubility and thus their mobility (Chambre régionale d'agriculture Languedoc-Roussillon, unknown).

Excess of heavy metals can have toxic effect on crops through damage to their roots and interaction with microorganisms in symbiosis with the plants. They adversely influence beneficial microorganisms (e.g. nitrogen fixing), affecting their growth, abundance, genetic diversity, nodulation ability and efficacy. Thus, a decrease of the number of Rhizobia bacteria can be observed when metal concentration increases in soils (for Cu, Zn and Pb) (Stan et al., 2011). Thus, by stopping growth and multiplication of Rhizobia, heavy metals are also responsible for the loss of Rhizobia function when they are in symbiotic association with the legume host, in particular their nitrogen-fixing ability. If metal particles enter plant tissues, they can also cause cellular injuries and interfere with metabolic activities (Ahmad et al., 2012). It will thus have an impact on growth and reproduction, and in the worst case, death (Cheng, 2003). Plants that have been contaminated with heavy metals can then be harmful to animals eating them (see biodiversity section).

Medical Residues

Pharmaceuticals residues present in manure may behave in different ways in soil. Some are degraded within a short time period and hardly have an effect on the amounts in the environment. Others, such as tetracyclines, are very stable in soils due to their high ability to form complexes with soil particles (Christian, et. al, 2003).

Pharmaceutical residues may cause microbial resistance. It can also induce health risk associated with consumption of fresh produce which contain antibiotics, in particular in case of antibiotic allergy (Mayhem, 2006).

Moreover, animal hormones are naturally excreted in manure in non-negligible quantities, in particular œstradiol E2, œstriol E3 and œstrone E1 (Hernandez-Raquet et al., 2010). Even if there is little knowledge on hormone persistence in manure, the spreading of manure may transfer these molecules into soil and water. Endocrine disruptors can then have an impact on local fauna by affecting population richness and abundance (Lee, et al., 2008).

In addition, many traces of medicinal products are found in the environment and may combine or react together. However, how they do so and what the impacts of such combinations are, known as the „cocktail effect‟, are poorly understood and are very difficult to evaluate.

Soil Quality: Texture, Structure, Organic Matter Content, Water Retention

The use of livestock manure is one of the main methods (along with crop rotation and green manure) used throughout history to maintain soil fertility. Not only does the spreading of manure bring nitrogen, phosphorus potassium and micro-nutrients that are essential for crops in a form that can be directly assimilated by the plant, but it also improves soil quality. In the case of repeated application of manure, the positive effects are the following:

 Increase of the organic matter content on soils of lower organic matter content and low fertility, (Schoenau, et al., 2004) and so improve water retention;

 Stimulation of microbial respiration and activities (McGill et al., 1986) through the increase of labile carbon and nitrogen organic content (Keyrodin & Antoun, 2009);

 Changes to the C to N ratio: manure has a relatively high C:N ratio, while slurry‟s ratio is quite low. A high ratio reduces the potential volatilisation or leaching of N (see Box 1); and

 Impacts on physical properties of soil by increasing soil porosity, density, structure and water infiltration which participate in improving soil aeration, gaseous exchange, and root development in the soil and consequently soil productivity. (Loro, Bergstrom, & Beauchamp, 2007). A study from Campbell et al. (1986) shows that soils that received repeated applications of cattle manure were more friable to the feel and less compacted under foot than those of the unmanured plots (Campbell et al. , 1986).

The effects of manure on soils depend on soil initial properties, land-use and probably other environmental factors since some studies produce conflicting results (Keyrodin & Antoun, 2009). For example, a study found that an application of pig manure on Luvisolic soils increased the size of soil aggregates while it decreases their size for Black Chernozemic soils (Assefa, 2002).

In addition, the repeated application of manure can have deleterious effect through salt accumulation, which can damage soil structure and reduce crop growth (Schoenau, et al., 2004).

Box 1 Nutrient Ratios and their Impacts on the Environment

The C:N ration Since the carbon cycle and the nitrogen cycle are linked, the C to N ratio is used as an indicator for the transformation of organic matter in soil. The C to N ratio is about 10 for humus and 8 for microbial biomass. The C to N ratio for slurry is about 1 to 5-10, for composts 10-15 and for manure 10 to 30. In case of manure/slurry application, the higher the C to N ratio is, the more the degradation of the residues will induce a mobilisation of soil nitrogen and thus reduce potential volatilisation or leaching (INRA, 2012) The P:N ratio The P equilibrium in soils is very important as it has the potential to reduce leaching from other pollutants such as N and heavy metals (FAO, 1998). The N:P ratio in manure is in all but very exceptional cases lower than the N:P ratio in crops (FAO, 1998). Thus, when manure is applied, crops will remove more N, reducing the potential for emissions or leaching.

3.3.6 Impacts on Water

Despite the measures and improvements in the chemical status of water bodies, poor water quality is still an issue in the EU. In particular the WFD objective of reaching good chemical and ecological status of all water bodies by 2015 will not be reached (EEA, 2012). A major cause of this poor status is diffuse pollution from agriculture (EEA, 201036 and 201137). Several of the environmental impacts from agriculture are (partly) related to emissions from manure. In particular, manure is responsible for a little below half of nutrients (both nitrogen and

36 EEA (2010) The European Environment, State and outlook 2010 Freshwater quality

37 EEA (2011) Looking beneath the surface http://www.eea.europa.eu/articles/looking-beneath-the-surface-how

phosphorus) emissions (half is due to inorganic fertilisers) and also has impacts derived from pathogenic microorganisms and organic pollutants in manure.

It is also important to consider timescales when looking at impacts on water. Indeed, while many measures are available to reduce nutrient overloads are available (see section 4 for details), a significant timelag may occur before the results of such measures may be seen, especially for groundwater bodies. In 2010, it was estimated that timescales for substantial restoration of water quality ranged from 4-8 years in Germany and Hungary, to several decades for deep groundwater in the Netherlands (EEA, 201038, quoting EC, 201039).

The pollution of waters in particular may result in negative impacts to health, due to disruption of purifying processes from soils and natural elements of the landscape and directly of pollution. In particular and according to the Drinking Water Directive, if the concentration of nitrate in water bodies is higher than 50 mg/l, the water becomes unsuitable for drinking. In the EU, out of four main problems identified with drinking water (microbiology, nitrates, toxics and metals), nitrates is the issue predominant in almost all MS. In addition, pathogenic micro-organisms excreted by livestock may be washed from soils to water bodies, or directly be deposited in water bodies. This may pose a risk to public health, via freshwater and marine recreation (EEA, 2010).

Eutrophication

The overloading of sea, lakes, rivers, streams and groundwater bodies with nutrients (mainly nitrogen and phosphorus) can result in eutrophication. Eutrophication results from excessive growth of algae, due to an excess of nutrient (N and P), which can cause oxygen shortage: as dead algae decompose, the oxygen in the water is used up. Phosphorus is the limiting nutrient for eutrophication of fresh water and nitrogen is the key limiting nutrient for salt waters (EEA, 2000, EEA 201240).

Agriculture is the principal source of diffuse pollution causing eutrophication (EEA, 2012), responsible for 50 to 80 per cent of the total nitrogen load in Europe's freshwater (Bouraoui et al., 2011; Sutton et al., 2011 quoted in EEA, 2012). The major nutrient inputs to agricultural land come from inorganic mineral fertilisers and organic manure from livestock (EEA, 2010) and are generally in excess of crop needs, resulting in surpluses. N and P are applied to soils as they are necessary nutrients for crop growth. However, excess nitrogen put on land may be washed off from soils and leach into surface and groundwater. Nutrient in water can come from manure application. Indeed, ammoniacal nitrogen is the main form of nitrogen in manure, especially in slurry (INRA, 2012). Once the manure is spread on land, ammonium can be transformed in ammonia which can volatilise in the air or dissolve in water. Thus, ammonia is quickly nitrified, i.e. transformed through microbial action into nitrate

38 EEA (2010) The European Environment, State and outlook 2010 Freshwater quality

39 EC, 2010. Report from the Commission to the Council and the European Parliament on implementation of Council Directive 91/676/EEC concerning the protection of waters against pollution caused by nitrates from agricultural sources for the period 2004–2007 SEC(2010)118.

40 EEA (2012) European waters – assessment of status and pressures, EEA report No 8/2012

(NO3-). Also, nitrogen mineralised from the organic fraction of the manure, will readily be nitrified. As nitrate

(NO3-) is an anion that is soluble, it is easily leached in water run-off/percolation. The following maps show the annual diffuse agricultural emissions of nitrogen to freshwater for 2009 (Figure 3.24) and the exceedance of critical loads for eutrophication due to the deposition of nutrient N in 2000 and 2010 (Figure 3.25).

Figure 3.24 Annual Diffuse Agricultural Emissions of Nitrogen to Freshwater (kg N per ha of total land area) for the year 2009

Eurostat, 201241

41 Eurostat (2012) Annual diffuse agricultural emissions of nitrogen to freshwater (kg N per ha of total land area), (2009), available from http://epp.eurostat.ec.europa.eu/statistics_explained/index.php?title=File:Annual_diffuse_agricultural_emissions_of_nitrogen_to _freshwater_%28kg_N_per_ha_of_total_land_area%29,_%282009%29_.png&filetimestamp=20130410144617

Figure 3.25 Exceedance of Critical Loads for Eutrophication due to the Deposition of Nutrient N in 2000 and 2010

EEA,201042

The main sources of phosphorus pollution are domestic and industrial (EEA, 2000). However, phosphorus run-off from agricultural practices also adds to this pollution and contributes to eutrophication, especially in Western Europe. Phosphorus in manure is of special concern, as there is a direct relationship between the amount of extractable-P in the soil and the concentration of dissolved P in the surface run-off 43. Phosphorus excreted in manure mainly comes from animal feed, for example 60 to 70% of the phosphorus intake in poultry rearing is excreted (Fourrie, et al., 2011). Phosphorus is relatively stable in soils, but the organic fraction of P in manure can be rapidly solubilised, so the mobility of P in animal manures can approach 100%. Phosphorus is not as mobile as nitrate (NO3-) in the soil and therefore less susceptible to leaching. Nevertheless, due to its stability, phosphorus applied in excess can saturate the soil, for example after repeated manure application. Although this usually does not have a detrimental effect on crop production (Moncrief & Bloom, 1999), the soil loses part of its capacity to retain phosphorus and leaching occurs. The main consequence from N and P leaching into surface waters is eutrophication. This process leads aquatic animals (e.g. fish) to die or leave the area, causes odours and visual nuisance, and in the worst case creates deoxygenated dead zones. Increased nutrient concentration can also lead to

42 EEA (2010), Exceedances of critical loads for eutrophication due to the deposition of nutrient N in 2000 and 2010, available from: http://www.eea.europa.eu/data-and-maps/figures/exceedances-of-critical-loads-for

43 Burton C. and Martinez J. (2008) Contrasting the management of livestock manures in Europe with that practised in Asia: what lessons can be learnt? Outlook on Agriculture 37, 3 (2008) p. 195 - p. 201

changes in aquatic vegetation (EEA, 2000). Eutrophication occurs both in freshwater and in coastal/ marine waters. Indeed, discharge of polluted freshwaters into coastal waters results in pollutants potentially impacting the marine environment.

Acidification

Water can be acidified through acid rain that results from ammonia volatilisation and subsequent deposition. The effects of acidification on water are similar to those on soil: higher solubility of elements, in particular heavy metals; decrease of plants‟ capacity to absorb essential nutrients and water, specifically phosphorus; and decrease of biodiversity. In oceans, acidification also causes the dissolution of carbonate (HCO3-), which is transformed into carbon dioxide (CO2) and thus contributes to global climate change (DEFRA, 2013).

Medical Residues

Antibiotic residues can occur in small streams and large rivers, as well as in ground water. It is difficult to identify whether antibiotics come from sewage or agriculture (and leaching) and whether it has a medicinal or veterinarian origin. A study from Christian et al. (2003) showed that the behaviour of antibiotics is different depending on the substances. Some of the substances were found in nearly every sample (erythromycin and sulfamethoxazole) and sometimes in concentrations of a few hundred ng/l, while others could only be found in concentrations near the limit of detection. Antibiotics with single use in veterinary medicine could be found just few times and mostly close to the limit of detection, which leads to the suggestion that most of the substances possibly originate from discharge of sewage into rivers and that agriculture has a comparatively low influence on the input of antibiotics into the aquatic environment.

3.3.7 Impacts on Biodiversity and Related Ecosystem Services

The impacts from manure spreading on biodiversity and ecosystem services are indirect, through the positive or negative impacts that are described above. The main impacts are on soil biodiversity directly, but some impacts can be seen on other species and habitats. In addition, this section shows how the above-mentioned impacts influence ecosystem services that are provided by nature to humans. It is important to underline that the impacts outlined below are often due to a combination of factors and manure cannot be made responsible of the total impact, but it contributes to them.

Soil Biodiversity

Farmyard manure promotes the abundance of biological regulators (for example bacterivorous nematodes) and ecosystem engineers (earthworms) in the soil and generalist predators above ground (Birkhofer et al. 2008). Organic manure promotes soil microbial biomass, but slows down microbial activity. Indeed, microbes need microhabitats with the right set of conditions, which can be provided by accumulated organic matter or animal manures (BIO Intelligence Service, 2010). The moderate application of manure can benefit earthworms and other decomposers (Vickery et al, 2001). Some earthworms feed on manure, and have beneficial effects for soil organic

matter composition and structure. More generally, the positive impact that manure has on soil organic matter is beneficial for soil biodiversity.

However, the negative impacts of manure on soils also harm biodiversity. For example, in the case of heavy metals accumulation in soils that can to a small extent be due to manure spreading, soil life such as earthwork and microbes can be negatively affected. High nitrogen levels from excessive use of fertiliser and manure lead to increasing mineralisation of organic carbon in the soil, which destroys organic matter and reduces soil biodiversity.

Aquatic Biodiversity

Free ammonia (rather than the ammonium ion) is the more impacting substance as it is toxic to many fish even at very low concentrations (Burton and Martinez, 2008). In addition, organic pollution through the direct discharge of manure into surface water results in reduced oxygen dissolved in water, as the decomposition process uses oxygen. Such process may kill water fauna and flora44,45.

The reduction of oxygen available through decomposition of organic matter and eutrophication will result in damaging changes to fish and other animal and plant species in aquatic ecosystems. This may lead to deoxygenated dead zones in which only a few bacterial species may survive (EEA, 2012).

Terrestrial Biodiversity

The EEA reports negative impacts from excessive reactive nitrogen in terrestrial ecosystems, including loss of sensitive species, and favouring of few tolerant species45.

Other Species and Habitats

Similar to soil biodiversity, plants generally benefit from additional organic matter being put on soils. Both crops and wild plants around the fields will thus benefit from manure application.

However, these not all species necessarily benefit. For example, the use of manure can create dense fast growing homogeneous grassland swards and crops, which are too tall and dense for birds to nest and feed in, e.g. Skylark (Aluda arvensis) and Lapwing (Vanellus vanellus) (Donald et al, 2002; Wilson et al, 2009). High nutrient levels will tend to encourage aggressive plant species (e.g. Italian ryegrass) to outcompete other species which thrive in nutrient poor conditions.

44 FAO, World Bank, LEAD Initiative (1996) Environmental Impact of Animal Manure Management, available from http://www.fao.org/WAIRDOCS/LEAD/X6113E/x6113e05.htm#b4- 2.4%20Effects%20on%20ground%20water%20and%20surface%20water%20quality

45 EEA (2012) Environmental indicator report. URL: http://www.eea.europa.eu/publications/environmental-indicator-report- 2012/download

Other negative impacts may occur to animals feeding on plants, when plants absorb the heavy metals contained in soils (a capacity which is used in phytoremediation) (e.g. poisoning of sheep, Henken 1975). However there is no agreement on the extent of this impact.

The impacts can also result from longer chains of actions, as emissions of reactive nitrogen (primarily from ammonia from manure) are among the top causes of terrestrial ecosystem eutrophication, which leads to significant biodiversity loss (Dise, 2011). Similarly, water eutrophication, due to the emission of N and P into water, partly from manure, reduces aquatic biodiversity, as the lack of oxygen kills animals and plants, or results in animals leaving the area (see above).

Ecosystem Services

Ecosystem services are the outputs from natural processes that benefit humans. The Millennium Ecosystem Assessment46 classified them into four categories: provisioning, such as the production of food and water; regulating, such as the control of climate and disease; supporting, such as nutrient cycles and crop pollination; and cultural, such as spiritual and recreational benefits.

The environmental impacts from manure spreading also may have impacts on ecosystem services. For example, if the amounts of nitrate (NO3-) applied exceed the capacity of ecosystems to support the nutrient cycles, eutrophication occurs, as explained above, leading to reduced possibilities of using water for drinking (a provisioning service) or bathing (a cultural/recreational service) purposes. In addition, in case of acidification of soils, Rhizobia‟s survival and persistence are affected, leading to reduced nodule formation and fixation of nitrogen by plants.

3.3.8 Risks of Pollution Transfer

The prediction of the fate of applied N that is not volatilised or added to the soil N, or recovered by the crop is difficult as it can leach as NO3 or evaporate as N2/N2O (FAO, 1996), with possible pollution swapping. To ensure that individual ammonia measures also reduce N2O and nitrate (NO3-) losses, it is essential that overall fertilizer inputs are fine-tuned to match the amount of nitrogen saved. In this way, farmers can also save time and costs by reducing other fertilizer inputs, as reduced nitrogen losses translates to a larger fraction of nitrogen inputs being available to reach the agricultural crops. If ammonia emissions abatement measures are not combined with reduced overall fertilization input, it may increase the emissions of other pollutants.

While techniques are available to reduce emissions respectively in the air and in water (see BAT section below), an integrated systems approach is therefore needed to reducing global pollution and avoid that the reduction of a certain impact may lead to increased impacts of another type. Indeed, pollution swapping between air and water is possible (Alterra 2007). For example, replacing mineral fertilizers with manure, rapid soil incorporation of manure, or deep injection of slurry will for example add more total nitrogen to the soil thereby reducing

46 Available from http://www.unep.org/maweb/documents/document.356.aspx.pdf

N emissions to air but may cause an increase in N2O emissions and nitrate (NO3-) leaching unless overall nitrogen

input is reduced elsewhere (ADAS, 2011). Similarly, several techniques that reduce the amounts of CH4 or N emissions to air, for example methanisation, result in outputs (the digestate) that have a higher N content than the original manure. The level of emissions will depend on both the choice of measures and on a range of external factors (climate, temperature, soil composition, technique used etc) which all influence volatility and leakage of the different pollutants. Without careful consideration of such changes, excess nutrients may be spread on land. The option to process the digestate to reduce the amounts of P and N is also possible, especially for P, but are often more costly or technical.

3.4 Current Regulation

3.4.1 European and International Legislation

The main existing EU and international legislation that cover manure and its management are synthesised in the sections below.

Industrial Emissions Directive

The Industrial Emissions Directive (IED) and associated Best Available Technology Reference Document (BREF) for intensive livestock rearing sets requirements for the application of Best Available Techniques (BAT) for manure spreading for poultry and pig farms above the relevant thresholds in Annex I of the Directive. However, as described in Section 1.2 many of these farms do not have the land available to spread manure on site so it is often spread by third parties on other sites thus falling outside of the scope of the Directive. The requirements in the BREF for manure storage and spreading are summarised in the sections on possible BAT below.

Freshwater Policies and the Nitrates Directive

The Nitrates Directive (91/676/EEC) is the main Directive that relates to manure and requires the implementation of an action plan that implement actions targeting inter alia manure.

It was adopted in 1991 and aims to protect water quality across Europe by preventing nitrates from agricultural sources polluting ground and surface waters and by promoting the use of good farming practices.

The Directive requires Member States to identify waters that are, or could be, affected by pollution from nitrates and to designate the known areas of land which drain into polluted waters or waters at risk of pollution and which contribute to nitrate pollution as „Nitrates Vulnerable Zones‟(NVZ). Member States have to adopt Action Programmes relating to vulnerable zones that include special measures farmers must implement. Some Member States (AT, DK, FI, DE, IE, LT, LU, MT, NL and SI) have chosen the available option of designating their whole

territory as a NVZ47. The status of NVZ coverage for each MS based on 2008 data from Eurostat is summarised in the table below for both absolute area (km2*1000) and as a percentage of total country area.

Table 3.8 NVZ Coverage by Member State (2008)

Member State Area (km2*1,000) % of Total Area

Austria 83.9 100

Belgium 20.7 67.8

Bulgaria 59 53.1

Cyprus 0.6 6.8

Czech Republic 31.4 39.8

Denmark 43.1 100

Estonia 3.4 7.5

Finland 338.4 100

France 250.1 45.6

Germany 357.1 100

Greece 32 24.2

Hungary 42.6 45.8

Ireland 70.3 100

Italy 38.1 12.6

Latvia 8.2 12.7

Lithuania 65.3 100

Luxembourg 2.6 100

Malta 0.3 100

Netherlands 37.4 100

Poland 4.6 1.5

Portugal 3.4 3.7

Romania 16 6.7

Slovakia 16.4 33.5

Slovenia 20.3 100

Spain 63.7 12.6

Sweden 67.5 15

UK 94.4 38.7 Source: Eurostat

47 http://ec.europa.eu/environment/pubs/pdf/factsheets/nitrates.pdf

Member States are also required to establish „Codes of Good Agricultural Practice‟ to be implemented by farmers. These measures are included in Action Programmes and are mandatory for farmers within an NVZ, though optional for farmers outside these zones.

Annex III of the Directive sets out other measures that must be included in the Action Programmes.

Annex III

1. The measures shall include rules relating to:

1. periods when the land application of certain types of fertiliser48 is prohibited;

2. the capacity of storage vessels for livestock manure [...];

3. limitation of the land application of fertilisers, consistent with good agricultural practice and taking into account the characteristics of the vulnerable zone concerned [...].

2. These measures will ensure that, for each farm or livestock unit, the amount of livestock manure applied to the land each year, including by the animals themselves, shall not exceed a specified amount per hectare.

The specified amount per hectare be the amount of manure containing 170 kg N. However:

(b) during and after the first four-year action programme, Member States may fix different amounts from those referred to above. These amounts must be fixed so as not to prejudice the achievement of the objectives specified in Article 1 and must be justified on the basis of objectives criteria, for example:

- long growing seasons,

- crops with high nitrogen uptake,

- high net precipitation in the vulnerable zone,

- soils with exceptionally high denitrification capacity.

If a Member State allows a different amount under subparagraph (b), it shall inform the Commission which will examine the justification in accordance with the procedure laid down in Article 9.

3. Member States may calculate the amounts referred to in paragraph 2 on the basis of animal numbers.

The objectives of the Nitrates Directive are also taken into account in several other Directives linked to water, such as the Water Framework Directive (2000/60/EC), the Groundwater Directive (2006/118/EC) and the Drinking Water Directive (98/83/EC as amended). The Water Framework Directive (WFD) has as its overarching objective

48 The directive defines “fertiliser” as “...any substance containing a nitrogen compound or nitrogen compounds utilised on land to enhance growth of vegetation; it may include livestock manure, the residues from fish farms and sewage sludge”.

the achievement of good status for all waters by 2015. It is now clear that this objective will not be achieved (EEA

2012). In its annexes, the WFD requires the monitoring of groundwater chemical status, including nitrate (NO3-) and ammonium, and requires that the Programmes of Measures required under the WFD include information on measures taken according to the Nitrates Directive. The Groundwater Directive also includes in its annex that good chemical status for water quality standard is considered to be below 50 mg/l. Nitrate (NO3-) is also a parameter used as one of the potability criteria in the Drinking Water Directive.

National Emission Ceilings Directive and the Gothenburg Protocol

Introduction The 1999 Gothenburg Protocol to Abate Acidification, Eutrophication and Ground-level Ozone sets emission ceilings for four pollutants: sulphur, NOx, VOCs and ammonia. The ceilings are included in the NationalEmission Ceilings Directive (2001/81), which is due to be revised as part of the on-going EU air quality review in 2013. Each individual Member State has to decide which measures should be adopted in order to comply with the Directive. Since agriculture contributes to the majority of ammonia emissions, Member States are likely to have to target the sector in order to comply with the ammonia ceiling.

In order to help MS to be below these ceilings, the Annex IX of the Gothenburg Protocol deals specifically with pollution from agriculture with measures including:

 Defining good agricultural practice;

 Livestock feeding strategies;

 Low-emission animal housing systems;

 Nitrogen budgeting (using input-output balances);

 Urea and ammonium carbonate fertilisers;

 Manure application;

 Manure storage; and

 Animal housing.

On 3 May 2012, the Protocol was amended, including new emission ceilings for 2020 and new ceilings for PM 2.549. A revision of Annex IX was also foreseen on the basis of a proposal from a Task Force on Reactive Nitrogen (TFRN), but was eventually deferred (see Paragraph K (3) concerning Article 10). The comments below are based on the TFRN current proposals for revisions.

49 At the time of writing this document had not been formally published.

Accompanying the proposal to revise Annex IX is a Guidance Document which contains detailed descriptions of measures that could be applied, together with indications of costs (where available), which was adopted independently of the review of the Protocol by the Parties in the Long-range Transboundary Air Pollution (LRTAP) Executive in December 2012. There is partial overlap between BAT and the Gothenburg Protocol guidance document, since BAT has only been defined for the pig and poultry sectors, whilst the Gothenburg document has a wider scope. This section reviews the draft TFRN proposal for a revised Annex IX and the adopted Guidance Document in order to identify measures that could be relevant to target emissions from manure spreading.

Scope Some of the measures within Annex IX would apply across the whole of the country‟s territory and to all farms, whereas some would only apply to livestock farms above a specified threshold of stock numbers.

Targets and thresholds are set for a number of areas. The current proposals for Annex IX are to provide three different levels of aspiration. With respect to livestock numbers the thresholds are:

Table 3.9 Livestock Numbers Thresholds for Annex IX

Aspiration level Pigs Poultry Cattle

Existing Annex IX

2,000 fatteners or 750 sows 40,000 Nil

Proposed Annex IX

A 5 Livestock Units (LSU)

B 200 LSU 40,000 50 LSU

C 2,000 fatteners or 750 sows 40,000 50 LSU

Confidence in the Efficacy of Measures

In the Guidance Document, strategies and techniques for the abatement of NH3 emissions and N losses are grouped into three categories:

 Category 1: Well researched, considered to be practical or potentially practical, and there are quantitative data on their abatement efficiency, at least on the experimental scale ;

 Category 2: These are promising, but research on them is at present inadequate, or it will always be difficult to quantify their abatement efficiency. This does not mean that they cannot be used as part of an NH3 abatement strategy, depending on local circumstances ; and

 Category 3: These have been shown to be ineffective or are likely to be excluded on practical grounds.

The Guidance Document which contains detailed descriptions of measures that could be applied to control emissions of ammonia from agricultural sources informed the development of Section 4.5 of this report concerned

with defining best practice. In particular, measures associated with emission reduction from manure storage and manure spreading have been considered while developing the options associated with low, moderate and high ambition levels.

Common Agricultural Policy (CAP)

Introduction The Common Agricultural Policy (CAP) is an instrument aiming at ensuring food security at the EU level whilst supporting farmers‟ agricultural activities. Established in 1962, the CAP has undergone numerous changes over the decades.

Since 1999, the CAP is based on two pillars. The first pillar is dedicated to income support by providing payments to farmers, formerly related to their production. It is entirely financed by the European Agricultural Guarantee Fund (EAGF). The second pillar is dedicated to rural development. It provides subsidies for actions such as sustainable agricultural practices (agri-environmental measures or AEM), investment or support` of young farmers. It is financed partly by the European Agricultural Fund for Rural Development (EAFRD) and partly at national level50.

Scope The CAP reform in 2003 has reflected growing concerns about food safety, environmental preservation, farm income and sustainable development in the ever-larger EU and the ever-demanding international trade setting 51. It has brought change in the manner to calculate the income support. Initially based on the production and yields, the reform has established the Single Payment Scheme (SPS) and the transitional Simplified Area Payment schemes for MS who joined the EU in 2004 and 200752. This is a “decoupled” system of annual aid paid to producers regardless of their yields. Some production-linked payments have been maintained where necessary to avoid production abandonment. National ceilings determine the maximum amount of direct aid payments that each Member State can apply 53. The reform has also introduced mandatory cross-compliance obligations (Statutory Management Requirements) ensuring that other EU Regulations are complied with and requirements that aim at maintaining and encouraging good agricultural and environmental conditions (GAEC), as well as animal health and welfare standards 54. The principle is that farmers must comply with the requirements of good agricultural and

50http://www.pouruneautrepac.eu/pac-2013/pac-definition/piliers-et-budget/

51 http://www.cattlenetwork.net/docs/eu/EU_Beef_sum_web.pdf

52 http://ec.europa.eu/agriculture/direct-support/pdf/factsheet-single-area-payment-scheme_en.pdf

53 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2003:270:0001:0069:EN:PDF

54 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2003:270:0070:0077:EN:PDF

environmental agricultural practices, which standards are defined at national level, and other cross-compliance requirements regarding EU and national Regulations55. Failure to respect these conditions can result in deductions in the total amount of direct payments or, in certain cases, their complete cancellation. Cross-compliance requirements include compliance with the standards of the Nitrates Directive56,57. Since 2008, the GAEC also includes mandatory standards in relation to minimum soil cover (against soil erosion), arable stubble management (to maintain soil organic matter) or establishment of buffer strips (for water protection and management). Standards specific to livestock are optional and only apply for a minimum livestock stocking rates and/or appropriate regime. There is a specific requirement on the application of sewage sludge58 (Directive 86/278/EEC) but nothing regarding manure application that is not already considered in the Nitrates Directives. The farmers can also implement AEM, which go beyond the GAEC, but that is not part of the cross-compliance requirements59.

At the end of 2008, EU agriculture Ministers reached a political agreement on the Health Check of the CAP. It has introduced limited environmentally related changes to the CAP. Among them, the agreement abolishes arable set- aside, increases milk quotas to eventually lead to their abolition in 2015 and converts intervention into a market protection. It has also introduced new challenges for agriculture: tackling climate change, promoting the use of renewable energy, addressing the challenge presented by water management, halting the decline in biodiversity loss, restructuring the dairy sector and investing in Broadband infrastructure60,61.

CAP 2014-2020 The CAP has recently been reformed. Negotiations aimed at „greening‟ the instrument and ensuring that funds are more equitably distributed, while adapting to competitiveness and innovation and tackling climate change and broader environmental issues62. However, the final agreement does not seem to have gone very far in this direction as it leaves a lot of discrepancy for Member States. The new CAP regime is officially due to be approved by the

55 http://bookshop.europa.eu/en/the-2003-cap-reform-pbKF6004733/downloads/KF-60-04-733-EN- C/KF6004733ENC_002.pdf?FileName=KF6004733ENC_002.pdf&SKU=KF6004733ENC_PDF&CatalogueNumber=KF-60-04- 733-EN-C

56 http://ec.europa.eu/agriculture/envir/nitrates/index_en.htm

57 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:030:0016:0099:EN:PDF

58 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:030:0016:0099:EN:PDF

59 http://ec.europa.eu/agriculture/publi/reports/agrienv/rep_en.pdf

60 http://bookshop.europa.eu/en/overview-of-the-cap-heatlh-check-and-the-european-economic-recovery-plan- pbK33010504/downloads/K3-30-10-504-EN- C/K33010504ENC_002.pdf?FileName=K33010504ENC_002.pdf&SKU=K33010504ENC_PDF&CatalogueNumber=K3-30-10- 504-EN-C

61 http://ec.europa.eu/agriculture/healthcheck/index_en.htm

62 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2010:0672:FIN:en:PDF

end of 2013 and to apply from 1st January 201463. Most direct payment (Pillar 1) reforms will come into play in January 2015 with 2014 acting as a transitional year64. However, due to delays it seems that an interim regime will be agreed for the year 2014 and the new CAP will enter into force from 1 January 2015.

According to the agreements reached in July and September 2013, some of the changes concern the following:

 The system of direct payment for farmers: the Commission proposes to replace the existing direct payments systems by a more differentiated system. A Basic Payment Scheme will be maintained for all EU farmers, replacing the current Single Payment and Simplified Area Payment schemes. The conditionality is maintained but the share has increased: 30% of the direct payments will be conditional on three measures, with penalties after three years: crop diversification, the devotion of at least 5% of land to an ecological focus and the maintenance of permanent pasture, with a potential rise to 7% in 2017 (subject to a legislative proposal). It will be completed by payment encouraging environmental practices and young farmer‟s entrants. The Member States may maintain voluntarily couple payments and add payments to assist farmers in areas with specific natural constraints. The budget will be distributed to each Member State in order to attain a uniform payment per hectare at the regional level by 2019. At national level, Member States are allowed to take up to 30% of the national envelope to redistribute it to farmers on their first 30 hectares (“Redistributive Payment”). Moreover, up to 15% of the funds can be transferred between the 1st and the 2nd Pillar, or up to 25% for those Member States that get less than 90% of the EU average for direct payments. This will potentially permit Member States to increase the support regarding agri-environmental measures, should they choose to do so. Between Member States, the envelope will be adjusted for those countries where the average payment is below 90% of the EU average, other Member State envelopes being adjusted accordingly. The cap of the aid becomes voluntary. However, the amount received by an individual farm holding will be reduced by 5% for the amounts above 150 000€, salary cost deducted, up to 100%, except for Member States that apply the “redistributive payment”. The funds saved will have to be used in the Member State/region concerned;

 The market management: the Commission proposes minor adjustments regarding market management. Supply controls on milk, sugar and the planting of vines will be eliminated. The possibility to use crisis interventions in the event of market disturbances is generalised across commodities. Measures to strengthen the bargaining power of producers in the food chain will be introduced;

 The rural development policies: the policies will be more flexible and better coordinated with the territorial interventions of other EU funds. New institutional mechanisms for innovation are proposed, backed up with a larger budget for agricultural and food research, to help improve the competitiveness of EU agriculture and to address environmental and climate policy challenges. The co-funding rates will be up to 53% to 85% in less developed regions but can be higher for areas such as knowledge transfer, young farmers or measures tackling climate change, at least 30% of Pillar 2 envelopes would be devoted to climate change mitigation and adaptation, biodiversity, resource efficiency and soil, water and land management65. In particular, ammonia has been added in the Rural Development Indicators in addition to greenhouse gases. This means that Member States will have the possibility

63 http://ec.europa.eu/agriculture/cap-post-2013/index_en.htm

64 http://www.parliament.uk/Templates/BriefingPapers/Pages/BPPdfDownload.aspx?bp-id=SN06693

65 http://capreform.eu/habemus-consilium-rusticarum/

to support measures that more specifically target manure to reduce ammonia emissions. An optional co-financed risk management toolkit will also be proposed to Member States.

The greening of the payments has been controversial, receiving comments and opposition from a large number of stakeholders amongst Member States, NGOs and farmers‟ organization. The current comments are focused on the decoupling of public support for farming to the delivery of public goods (“public money for public goods”). Farmers‟ organisations highlight the risk that the system would result in a negative productivity shock, questioning food security and the environmental benefits. NGOs estimate that the greening provisions only constitute a justification to maintain direct payments that are harmful to the environment. Finally, the negotiations also focussed on the cap of aids that will be voluntary. On one hand this decision challenges the equity principles between each Member State. On the other hand, it could be considered as disincentive for farm modernisation.

3.4.2 National Legislation

In its 2010 report on implementation of the Nitrates Directive in the MS, based on MS reports for the period 2004- 2007 (SEC(2011) 909), the Commission reports that trends for both surface water and groundwater are generally stable or decreasing, but with very different situations amongst the MSs. The report covers the implementation of the Action programmes required to be implemented in the Directive. Main insufficiencies outlined relate to storage provisions (e.g. no mandatory minimum, insufficient capacity), balanced fertilisation (both manure and chemical fertilisers) and establishment of periods during which fertilisation is banned. Manure storage capacity has increased, but is still insufficient, due apparently to lack of financial resources among farmers. Low awareness is also underlined. The Commission notes an increased interest in manure processing techniques, in particular in regions with intensive livestock production and high nutrient surpluses. A wide range of techniques are used, from simple to more complicated techniques, sometimes establishing cooperatives.

The transposition of the Nitrates Directive at national scale, focussing on requirements for manure, is detailed in the table in Appendix C. A synthesis of the main findings is described below.

Period during which Fertilisation is Banned

As required in the Directive, each country has established periods of ban in NVZ. Spreading is mostly banned in non cultivated or “non-managed” areas. For other lands, the period of ban usually lasts 3 or 4 months, from November to February, mostly depending on land use, i.e. if the land concerned is grassland or crop land, and secondarily on the type of manure.

Some countries have establishes longer periods, up to 8 months. The periods can depend on a large range of factors, and sometimes on the type of manure:

 Regions, such as in Spain, Belgium or United Kingdom where the periods are defined by each state/autonomous community;

 Type of crops. In Hungary, spreading can be advanced by 15 days for winter cereals. Romania distinguishes fall crops and spring crops. In Slovenia, there is no ban for crops in greenhouses. Spain has implemented a specific calendar of the period of ban per type of crops;

 Previous agricultural practices. In Slovenia, application is possible if the soil and climatic conditions allows winter tillage and if manure is incorporated within 3 days. In Lithuania, the period of ban can vary by 15 days between a covered soil and a non-covered soil;

 Soil, geographical (slope) and climate condition. In Ireland, 3 regions were defined, depending to the length of the growing season, weather, soil types, etc. In Estonia, the period of ban is extended for 1 month in area where the slope is 5–10%. In the Netherland, the period is determined considering the type of soil (sandy, loess, clay and peat soil);

 Other specific condition: Luxembourg has added a specific requirements regarding protected area for drinking water. In these areas, manure spreading is forbidden during 7 months and the application of other fertilisers is forbidden during 8 months.

Some Member States have implemented a ban for areas that are not considered as NVZ.

Environmental Conditions for Application

For all Members States, the application is banned for waterlogged or water-saturated, flooded, frozen soil and for soil covered with snow. The Member States mention specific recommendations or requirements regarding the spreading on land with slopes. While some Member States are vague, by mentioning that the risk of run-off should be taken into account, others mention specific thresholds. In that case, the Member States mostly recommend measures for areas with slopes between two inclinations and forbid the application above a certain threshold. Thresholds are from 8% (in Luxembourg, for non-covered land) to 20% (for the UK, 18% for the Netherland and 17% for Hungary). Most of them have decided a ban above a 10% slope, such as Estonia, Finland, Germany, Latvia, Malta, Poland, Slovakia and Sweden. These thresholds can depend on the type of manure and practice. For example in Hungary, liquid manure cannot be applied over a 6% slope, except in the case of the use of specific spreading method.

The application distance to water bodies mostly depends on the type of water body and the type of fertiliser applied. It varies from 1m to 100m, the latter mostly concerning abstraction point for drinking water and coast. The distance from surface water is between 2m (England, for mineral fertilizers) and 50m (Latvia).

Procedure for Application

The Code of Good Agricultural Practices provides requirements, or at least advice, regarding the application techniques. The recommendations concern the dose, the timing and the application techniques. Many Member States provide a table with the requirements for each crop and a method to calculate the amount that have to be applied. The techniques for each type of manure can also be mentioned. Best case examples include:

 Flanders, where application techniques are specified in the regulation per type of land-use66;

66 Livestock manure and other organic fertilizers have to be applied with low emission techniques: on grassland through shallow injection, trailing hose technique, slit coulter; on uncultivated arable land through manure injection, spreading and incorporating of the manure maximum 2 hours after spreading; and on cultivated arable land through manure injection, trailing hose technique

 The Netherlands, where strict general binding rules on the way the manure has to be applied are in place, depending on the soil type with defined strips width and distance within strips;

 In some counties of Sweden, that request incorporation into the ground for growing crops;

 In Germany, old manure spreading technologies are progressively phased out.

Guidance is also provided on techniques, for example in Italy good practices are suggested such as fast incorporation of the surface spread manure, band spreading, application of slurry diluted with irrigation water (e.g. with low pressure sprinklers or drip lines), trailing hoses, shallow and deep injection, etc. Italy reported that due to its relative costs, fast incorporation is the most practised technique. In Ireland, trailing shoe technology is encouraged and is supported in agri-environment schemes (current uptake 3%, target of 50%). In Estonia, France and Finland, guidance documents are available on best practices including for spreading techniques. Barriers to uptake mentioned include often costs, but sometimes also specific farming conditions in the country (hilly areas, small farms, etc.)

The incorporation timing is an item tackled by more than half of the Members states in order to prevent/ reduce ammonia emissions. Most Members States require incorporation within 24 hours. This duration can be reduced depending on the MS (Austria, Portugal, Sweden, UK, and Lithuania) and the type of manure. Advice regarding the incorporation of crop residues can also be mentioned, in particular in the case of slurry application. S ome Member States such as Belgium, Germany, Ireland and the Netherland have also included recommendations or requirements regarding phosphorus spreading which may reveal a specific concern of the overall impacts of fertilizers application.

Amount of Livestock Manure Applied

Member States all impose a limit for the amount of manure applied of 170 kg N/ha, with derogation during the first four years. It is interesting to note that the amount allowed the first four years varies from 210 to 250 kg N/ha according to the MS. The Member States can also propose thresholds per type of manure, per application and per period. This is the case for Finland which imposes amounts of manure applied in autumn per type of animal manure. A threshold for the amount of a single dose of organic fertilizer is proposed by Germany and Slovenia (both apply a threshold of 80 kg N / ha, after the harvest for DE) and Northern Ireland (50 kgN/ha). In Denmark, up to 70-75% slurry can be used.

Few Member States require amounts lower than the amount required in the Nitrates Directive. It is the case for Denmark that requires a maximum of 140 kg N/ha from animal manure and 170 kg N/ha for cattle manure; Wallonia that requires 115 kg N/ha for crops; and Luxembourg that requires 85 kg N/ha for protein crops and leguminous and in protected area for drinking water, and 130 kg/ha for crops and zero for protein and leguminous crops.

As for inorganic fertilisers, some MS (BE, DE and NL) provide requirements regarding the amount of organic phosphorus fertiliser that can be applied.

Finally, although the implementation of nitrogen fertilisers‟ thresholds is only voluntary outside of NVZ, it can be noted that some MS limit the amount applied outside of these zones (sometimes with relatively high thresholds compared to the 170 kg/ha within NVZ). This is the case for Italy where the amount of organic fertiliser allowed is 340 kg N/ha.

Manure Storage

Member States require that the risks of losses and leaching during storage is minimised. They generally require a storage capacity of 6 months. The capacity can vary according the type of organic fertilisers (liquid/ solid and the origin) and the geographical context (in NVZ or not). In general, organic fertilisers that present high risks (slurry and pigs and poultry manure) require a longer storage capacity. Few Member States go beyond the Directive by imposing a capacity of 7 to 12 months, but this is the case for the Netherlands, Latvia, Lithuania, Denmark, Estonia, Finland and Sweden (in increasing order of duration).

Storage in field in mostly allowed. Nonetheless, it requires specific storage conditions, in particular regarding the storage duration and the distance from water bodies and urban areas.

The Box below (Box 2) summarises the measures implemented in Member States that differ from those required in the Nitrates Directive.

Box 2 Measures Implemented in Member States that are Different to those Required by the Nitrates Directive

Application techniques: Some Member States require specific application techniques depending on the type of fertilisers used. In Denmark, only band spreading and injection of slurry is allowed (no overall spreading) and it is mandatory to inject slurry used in grass and on “bare soil”. In Germany, fertiliser spreaders must conform to acknowledged rules of technology and from 1 January 2010 certain machinery will no longer be permitted. In the Netherlands, very precise indications, in terms of techniques but also of depth of injection for example are required. Slovenia provides a list of allowed techniques, depending on the type of manure. Finland, Poland, Portugal, UK and Italy provide advice regarding the techniques to be used for manure application. Incorporation timing: Most Member States (16 out of the 27) require that the manure is incorporated within a specified timeline, mostly within 24 hours. Some MS require incorporation more quickly, e.g. 4 hours for Austria and Sweden and 6 hours for Denmark, Lithuania and the UK. Phosphorus thresholds: Some Member States such as Belgium, Germany, Ireland and the Netherlands have also included recommendations or requirements regarding phosphorus spreading. In Flanders, phosphorus from mineral fertiliser is forbidden and the amount from organic fertiliser is limited to 100 kg/ha on grass, and 85 kg/ha on maize. In the Netherlands, limits set differ according to phosphate level in the soil and in 2013 vary from 85 to 100 kg for grassland and from 55 to 85 kg for arable land. In Germany, the excess of phosphorus must not exceed 20 kg N/ha. Nitrogen threshold per crop and per application: Some Member States such as Flanders, Finland or France require thresholds regarding nitrogen fertilisers for each crops. A threshold for the amount of a single dose of organic fertiliser is proposed by Germany and Slovenia (both 80 kg N / ha, after the harvest for DE) and Northern Ireland (50 kg N/ha). Requirements and thresholds outside the NVZ: Some Member States have implemented requirements and thresholds outside the NVZ. For example, in Wallonia, the nitrogen thresholds are primilarly for the whole territory and are lower for vulnerable zones. In Estonia, the 170 kg N org/ha is a threshold for the whole territory. In vulnerable areas, the nitrogen amount accounts for organic and mineral fertilisers combined. Financial incentives: Some Member States provide financial support to compensate for the additional operating costs of manure application requirements. In Austria, the subsidy amounts to 1€/m3 (limited to 30 m3/ha). In 2011, 2 300 k€ were spent for a reduction of almost 1,5% of all agricultural ammonia emissions. In Northern Ireland, the NI Department of Agriculture and Rural Development (DARD) has run 2 tranches of a capital grant scheme to encourage farm businesses to invest in advanced slurry spreading equipment (eg trailing shoe systems) with increased nutrient efficiency, lower greenhouse gas emissions and reduced risk of phosphorus run-off. Over 230 systems have been funded so far.

3.5 Economic Outlook

3.5.1 Poultry Industry

Key Characteristics

The poultry industry has two distinct sub-sectors, namely: poultry rearing for meat production (“broilers”) and for egg production (“layers”).

The EU produces around 11 million tonnes of poultry meat annually67 and well over 35 billion eggs (Eurostat – figure is a minimum value as it excludes countries expected to be important producers, such as Italy and the UK). In value terms, poultry meat represents 13% of livestock production value, and eggs 4%67. Poultry meat is the second most popular meat in the EU, representing 25% of EU meat consumption overall67. Poultry meat

67 JRC (2010) Evaluation of the livestock sector's contribution to the EU greenhouse gas emissions (GGELS), Final report.

consumption in the EU was about 23 kg per capita in 200968, and that for eggs is about 12 kg per capita per annum69. Key sector characteristics are presented in Table 3.10.

Table 3.10 Key Characteristics of EU27 Poultry Industry (2010 or most recent prior to 2010 where not available)

Broilers Laying hens Total

Number of holdings (1000s) 2,200 4,100 4,800(1)

Number of hens (1000s) 876,000 510,000 1,620,000(2)

Production (1000s tonnes of meat/eggs) >> 6,100(3) >> 3,600(4) n/a ~ 11,000 (5) ~ 6,900(6)

Production (1000s heads/eggs) >> 4,360,000(3) >> 35,000,000(4) n/a

Production value of meat/eggs (€ million) 17,000 7,700 14,700

Regular labour force (specialist poultry)(6) n/a n/a 1,000,000 Source: Eurostat, except where specified in the notes

Notes: (1) The total number of holdings is lower than the sum of its components as many holdings have both broilers and laying hens. (2) The total number of hens is higher than the sum of broilers and laying hens as there are also poultry classified as “other”. (3) Meat production given as minimum values as Eurostat only has such data for 10-12 Members States. (4) Eggs production given as minimum values as Eurostat data excludes countries expected to be important producers, such as Italy and the UK. (5) JRC (2010) estimate. (6) http://www.compassionlebensmittelwirtschaft.de/wp- content/uploads/2012/05/Info-1-Egg-production-in-the-EU.pdf.pdf (7) It is likely that the actual labour force will be higher than this, as non-specialists are likely to be employed in poultry rearing, slaughter etc.

In terms of trends, recent analysis by the European Commission68 expects both consumption and production of poultry meat in the EU to remain broadly level up to 2020, albeit slightly increasing, as depicted in Figure 3.26. It is thought that this increase is in part driven by the increasing consumer sensitivity to poultry‟s image as a “good value and healthy meat”.

68 European Commission, Directorate-General for Agriculture and Rural Development, Prospects for agricultural markets and income in the EU 2011–2020, December 2011

69 http://www.compassionlebensmittelwirtschaft.de/wp-content/uploads/2012/05/Info-1-Egg-production-in-the-EU.pdf.pdf

Figure 3.26 Poultry Meat Market Developments (million tonnes), 2000-2020

Source: European Commission, Directorate-General for Agriculture and Rural Development, Prospects for agricultural markets and income in the EU 2011–2020, December 2011

Trade

As presented in Figure 3.26, the EU is a net exporter of poultry meat, with over a quarter of production exported67. EU exports increased significantly in the period 2008-2011. It is thought this is due to continuing increases in demand from Asia, Africa and the Middle-East, combined with a relatively weak Euro over the period. After this initial surge in exports, they are expected to gradually decrease leading up to 2020, as the Euro strengthens.

The EU‟s main exports markets for poultry meat are in Asia, Africa and the Middle-East, while the main source of imports is Brazil, with Thailand being an increasingly important source of imports68.

Regarding eggs, the EU is also a net exporter, with 188,000 tonnes of egg/ egg products exported and 35,000 tonnes imported in 200970. It is worth noting that EU imports of eggs are limited by EU Salmonella legislation, meaning that eggs can only be imported from Switzerland, Norway and Croatia71.

Competitiveness

Poultry production is a highly integrated industry, with most chickens reared intensively in large purpose-built facilities. These tend to be operated by large companies that control all stages of production, including the supply

70 http://www.compassionlebensmittelwirtschaft.de/wp-content/uploads/2012/05/Info-1-Egg-production-in-the-EU.pdf.pdf

71 http://ec.europa.eu/food/animal/welfare/farm/docs/19012011_4%20Industry's%20perspective%20-%20Williams.pdf

of chick breeding and hatching, feedstuff manufacture, and delivery of meat to the retailers. Overall, it is estimated that 60% of broilers are supplied by farms owned directly by processors, with the rest produced by independent farmers, generally under contract to a processor67.

Trends in average number of broilers per holding by Member State are illustrated in Figure 3.27 and show large differences between Member States. Three Member States (Netherlands, UK and Czech Republic) have over 50,000 broilers per holding on average; four have between 20,000 and 50,000; ten have between 1,000 and 20,000, with the rest having fewer than 1,000. The overall trend indicates an increase in number of broilers per holding in the period 2005-2010. This reflects an overall 49% decrease in the number of holdings in Member States that have more than 1,000 broilers per holding on average, combined with an 8% increase in the number of broilers over the same period. These trends can be interpreted as reflecting a consolidation of the broiler industry into fewer, larger holdings.

Figure 3.27 Average Numbers of Broilers per Holding (Member States with more than 1000 broilers per holding in 2010), 2005-2010

Source: Eurostat database query on dataset ef_lslayhenaa.

The situation for laying hens is similar, with 59% of the laying hen population reared in farms with > 40,000 heads, despite such farms making up only 0.1% of all farms67. Again, in Member states with more than 500 laying hens per holding (on average), a consolidation of the industry is evident, with the number of holdings decreasing by almost 50% between 2005 and 2010, while the number of laying hens remained the same.

Figure 3.28 Average Numbers of Laying Hens per Holding (Member States with more than 500 broilers per holding in 2010), 2005-2010

Source: Eurostat database query on dataset ef_lslayhenaa.

3.5.2 Pig Industry

Key Characteristics

The EU produces around 22 million tonnes of pork meat annually, making it the world‟s second largest producer after China. In value terms, pig meat represents 21% of livestock production value67. In several EU member states pig meat sector is the largest meat production sector. In particular, two thirds of pig meat production in EU is produced in just six countries, Germany, Spain, France; Poland, Denmark and the Netherlands. The following countries are also rather large producers; Belgium, United Kingdom, Romania, Hungary, Austria, Portugal, Czech Republic and Sweden (Pyykkönen et al, 2012).

Pig meat is the most popular meat in the EU, representing 45% of EU meat consumption overall67. Pig meat consumption in the EU was about 41 kg per capita in 201068 . Key sector characteristics are presented in the table below.

Table 3.11 Key characteristics of EU27 pig industry (2010 or most recent prior to 2010 where not available)

Pigs

Number of holdings (1000s) 2,750

Number of pigs (1000s) 152,000

Production (1000s tonnes of meat) 12,000

Production (1000s heads) 164,000

Production value of meat (€ million) 31,000

Regular labour force (specialist poultry) 641,000 Source: Eurostat

In terms of trends, recent analysis by the European Commission68 expects both consumption and production of pig meat in the EU to remain broadly level up to 2020, albeit slightly increasing, as depicted in Figure 3.29.

Figure 3.29 Pig Meat Market Developments (million tonnes), 2000-2020

Source: European Commission, Directorate-General for Agriculture and Rural Development, Prospects for agricultural markets and income in the EU 2011–2020, December 2011

Pig meat is expected to remain the most popular meat in the EU at 41.6 kg/capita in 202068.

Trade

As presented in Figure 3.26, the EU is a net exporter of pig meat67; the production of pig meat in EU is larger than the consumption of pig meat and the excess compared to domestic consumption is approximately 10% (Pyykkönen et al, 2012).

The largest export countries are Germany, Denmark, the Netherlands and Belgium. The main export market is in Asia where the European production competes with US, Canadian and Brazilian production. US, Canada and Brazil have in general lower production costs than Europe. Due to the export orientation of the sector the exchange rate of the Euro has also had an important role affecting the competitiveness of the European pig meat sector (Pyykkönen et al, 2012).

Global pig meat consumption is projected to increase by 9% during the next decade with pigmeat exports in 2020 to be about 5% above the 2010 level. However, after reaching a peak in 2013, they are expected to follow a downward trend for the rest of the projection period, due to assumed strengthening of the Euro and resulting impact on export competitiveness, particularly to the Far East, increasing competition from other exporters such as Brazil and policies adopted in some importing countries (e.g., China, Russia) aimed at increasing self sufficiency68.

Competitiveness

Pig rearing is generally an intensive, indoor, large scale business with a weak dependence on the local resource base and bio-physical conditions resulting in a relatively low level of variability in production systems. Both pig and poultry play an important role in mixed livestock small holdings throughout the EU, particularly in the CEE MS, but this system represents little in terms of overall herd size and still much less in terms of contribution to overall production67. Pigs are raised to produce piglets or to produce meat. Sows raised for breeding are housed in different systems from pigs raised for meat - fattening pigs. The average EU litter size is roughly 11. In most EU countries slaughter takes place at 5.5 to 6.5 months of age and the live weight at slaughter is between 105 and 115kg (Reuters 2007) 67.

The pursuit for economies of scale in the primary production and the processing industry resulted in increasing the size of farms and in many countries the pig meat farms are among the largest husbandry farms, although there are large differences in average numbers of pigs per holding between the different Member States. Figure 3.30 shows the average number of pigs per holding in Member States with more than 100 on average. The figure illustrates the increasing average herd size over the 2005-2010 period in these Member States. This illustrates the increasing economies of scale that are achieved in the sector overall. It also highlights that further economies of scale remain achievable in many Member States where the industry remains relatively unconsolidated; especially in those Member States not featured in the chart (these have fewer than 100 pigs per holding on average).

Figure 3.30 Average Numbers of Pigs per Holding (Member States with more than 100 pigs per holding in 2010), 2005-2010

3,000

2,500

2,000

1,500

1,000

500

0 EE ES IT UK DE CZ CY MT FR LU FI SE BE IE NL DK 2005 75 197 85 424 303 207 706 523 353 429 455 649 818 1,977 1,167 1,500 2007 128 217 90 493 341 252 619 566 405 463 513 732 895 2,007 1,342 1,903 2010 251 354 356 445 459 477 524 543 569 598 657 894 1,092 1,253 1,743 2,598

2005 2007 2010

Source: Eurostat database query on dataset ef_lspigaa.

In the processing industry there seems to be an ongoing consolidation process with several large acquisitions during the last decade (Pyykkönen et al, 2012).

In primary production the increasing size of the units has, however, a drawback in increasing economic and environmental risks as well as increasing risks in infections and diseases. Environmental risks are associated with the large amount of manure that is handled; while the larger farms might have better access to latest technology the distances that the manure needs to be transported increases by the size of the operation and the availability of land (Pyykkönen et al, 2012).

The profitability of the pig meat production is directly related to changes in the ratio between the input prices (mainly feed) and the output prices of meat. The pig meat sector is thus very sensitive to price changes (Pyykkönen et al, 2012). For instance, a surge in feed prices coupled with low pig meat prices in 2010/2011 severely affected profitability of pig meat producers68.

Under the Common Agricultural Policy there are no quotas for pig meat sector and while such opportunities exist, public intervention has not been used for over twenty years. Thus, the EU pork meat regime has traditionally been seen as a „light regime‟, in comparison with other EU livestock regimes such as sheep, dairy and beef (Pyykkönen et al, 2012).

Overall, while there are large investment demands at the same time the sector experiences rather low profitability (Pyykkönen et al, 2012). As margins have been tight since 2007, farmers are reluctant to invest in their farms and a significant proportion are expected to exit the business as a result of forthcoming environmental and animal welfare regulations and associated costs. For instance, from January 1 2013, the EU swine sector had to comply with

Council Directive 2001/88/EC requirements. This Directive imposes specific requirements for the housing of pigs related to animal welfare such as introduction of group housing for sows, and the expansion of the living area for weaned piglets and fattening pigs. A large percentage of pig farms do not yet comply with the EU environmental (from the IED) and animal welfare requirements that will enter into force in 2013 (GAINS, 2011).

3.5.3 Dairy Industry

International Competitiveness & Trade Policies

In 2011, dairy farms in the EU2772 produced 150.8 million tonnes of milk, 91% of which was delivered to dairies, rather than consumed on farm or delivered direct. In terms of products derived from milk, in 2011 the EU27 produced72:

 8,794 thousand tonnes of cheese, of which 695 thousand tonnes were exported;

 2,103 thousand tonnes of butter, of which 144 thousand tonnes were exported;

 983 thousand tonnes of Skimmed Milk Powder (SMP), of which 486 thousand tonnes were exported; and

 756 thousand tonnes of Whole Milk Powder (WMP), of which 420 thousand tonnes were exported.

Milk production in the EU is not competitive in comparison with other parts of the world, with the cost of production at farm level per litre of milk higher than in other areas73. This is primarily due to the cost of milk quotas (see below), animal welfare regulations and the relatively high costs of land, buildings and labour. However, fresh milk products (milk, yoghurt, cream) are mainly produced and consumed locally due to their short shelf-life; therefore these products are not highly exposed to extra-EU trade. The main impact of the higher price of milk (relative to other parts of the world) is therefore upon milk derived products; butter, cheese and milk powders. Of these, cheese produces better end prices, whereas butter and SMP/WMP can be stored for longer and so tend to be „sink‟ products, produced when supply exceeds demand.

The Commission‟s „Prospects for Agricultural Markets and Income in the EU 2011-2020‟ projects changes in the production and export of milk and milk products from 2009 - 2020, assuming that there are no developments in trade agreements or in the Common Agricultural Policy (CAP) following the recent Health-Check decisions (see below for further details). These projections are:

 That EU milk production will increase by 7% for the period 2009 to 2020;

72 European Commission, DG Agriculture and Rural Development, (December 2011), „Prospects for Agricultural Markets and Income in the EU 2011-2020‟. Available for download on the 20th March 2012 from: http://ec.europa.eu/agriculture/publi/caprep/prospects2011/fullrep_en.pdf

73 LEI Wageningen UR, (March 2009), 'Competitiveness of the EU dairy industry'. Available on the 17th March 2012 from: http://www.lei.dlo.nl/publicaties/PDF/2009/2009-011.pdf

 Production of fresh dairy products (drinking milk, cream, yoghurts etc.) are projected to increase by 6%; international trade is limited (see above);

 Production of cheese is projected to increase by almost 10%, with a gradual increase in exports to 727 thousand tonnes, while imports remain stable;

 Production of butter is projected to remain stable, with exports gradually declining and imports increasing slightly; the price of butter is projected to remain stable;

 Production of SMP is projected to increase by around 10% in 2012 and then remain stable at around 1 million tonnes to 2020, with little change in the level of imports and exports;

 Production of WMP is projected to increase by around 4% to 2020, with the additional production going to export due to increased world demand.

It should be stressed that these projections are based on the assumption that there are no further major developments in international trade policy, which is by no means certain. If the July 2008 WTO agriculture package were to be agreed, the import tariffs on butter and SMP could be reduced by 70%, while the tariff on WMP and cheese could be reduced by 54%74. Alternatively, an EU/ MERCOSUR free trade agreement may be agreed, which would result in some form of reduction in import tariffs for products from the MERCOSUR trade block75. If either deal were to be agreed, the reduction in import tariffs would result in imports entering at a lower price. The impact of lower import prices on internal EU product prices and the trade balance is dependent on world market price levels74; if world market prices are below EU prices, this would result in deterioration of the trade balance and internal prices for these products. To estimate the impact of a WTO agreement on milk producers, LEI Wageningenur (2010)73 modelled the impact on the Dutch dairy farms sector and found that:

 Gross margin decreases on smaller farms by 35%, but increases by 8% on larger farms;

 Although prices reduce for both small and large farms, the negative impact of reduced price is offset by increased production at large farms, but not at small farms;

 Increasing milk production and gross margins for larger herds, but reducing milk production and gross margins firms for smaller herds are existing trends in the dairy industry; the WTO agreement reinforces and exaggerates these underlying trends.

The University of Manchester (2009)75 estimated the impact of potential EU/MERCOSUR trade agreements on the dairy sector and although it was found that MERCOSUR countries have a comparative advantage in dairy products and that any agreement would result in a deterioration of the bilateral trade balance, the effect would not be as pronounced as in other sectors, such as beef (see below).

74 LEI Wageningenur, (March 2010), 'European dairy policy in the years to come: Quota abolition and competitiveness'. Available for download on the 17th March 2012 from: http://www.lei.dlo.nl/publicaties/PDF/2010/2010-017.pdf

75 University of Manchester on behalf of the European Commission, (March 2009), 'Trade sustainability Impact Assessment (SIA) of the Association agreement under negotiation between the European Community and MERCOSUR'. Available for download on the 18th March 2012 from: http://trade.ec.europa.eu/doclib/cfm/doclib_section.cfm?sec=168&langId=en

Changes in State Aid

Historically EU dairy producers have been protected from international competition and to a degree from internal competition, through several measures contained with the CAP: quotas for milk production (internal competition), milk premiums, export support, import tariffs and a system for internal price intervention74. However, major changes to this system have been agreed in the 2003 Luxembourg agreement (Fischler reform) and the 2008 CAP Health Check:

 A gradual increase in milk quotas until 2015, when quotas will cease to exist76;

 Stepwise reductions in the intervention prices for butter and SMP74;

 A decoupling of the milk premiums; farms continue to receive decoupled aid through the Single Payment Scheme (SPS); and

 A commitment to cease the use of export subsidies by 201377.

The purpose of these reforms is to liberalise the EU dairy market, driving greater competition within the EU market and increase international competitiveness by opening up the EU market to international competition.

The gradual removal of milk quotas will remove a barrier to internal EU competition, as farms seeking to increase production will no longer have to purchase additional quotas from less productive farms or run the risk of having to pay the surplus levy. A report by the European Commission76 examined the impact of the gradual removal of milk quotas across MSs, from which some conclusions can be reached on the competitiveness of dairy farms across the EU:

 MSs whose milk quotas are well below quota ceilings - In these MSs, the quota price is low or equal to zero and is likely to remain at this level as quotas are increased to 2015. A low quota price demonstrates that there is less internal competition within these MSs, with fewer farms seeking to increase production. However, a low quota price indicates that the removal of quotas will not result in a shock to dairy farms in these MSs; a „soft landing‟. MSs in this category include the UK, France, Germany and Denmark76;

 MSs whose milk deliveries are close to the quota ceilings - In these MSs quota prices fluctuate with expectations of the surplus levy; future milk quota prices are expected to decline towards zero up to 2015. As for the category above, a low quota price indicates that there is less internal competition, but the industry is likely to experience a „soft landing‟ when quotas are removed. The majority of MSs fall within this category76;

76 European Commission, (8th December 2010), 'Evolution of the market situation and the consequent conditions for smoothly phasing out the milk quota system'. Available for download on the 17th March 2012 from: http://ec.europa.eu/agriculture/milk/quota-report/com-2010-727_en.pdf

77 Agriculture and Food Development Agency, (September 2009), 'Dairy Markets Review: An Assessment of the Short to Medium Term Outlook for Global Dairy Markets'. Available for download on the 17th March 2012 from: http://www.thedairysite.com/articles/2151/dairy-markets-review

 MSs whose milk deliveries exceed quota - In these MSs quota prices remain relatively high. This indicates that producers in these MSs remain sufficiently competitive or are obliged to fully use their capacity to continue producing and pay a surplus levy. A „soft landing‟ from quota removal is not guaranteed for all farms; specifically farms with higher production costs which currently sell/lease some or all or their quota. MSs in this category include Cyprus and the Netherlands76.

Another indicator of the relative competitiveness of the dairy industry across MSs is the „critical milk price‟, which LEI Wageningenur (2010)74 define as, „the milk price a farmer needs to cover his costs (including depreciation), cover the actual costs of living and ensure continuity of farming. The measure is corrected for the revenues obtained from other outputs (e.g. beef payments etc.)‟. The study74 found that:

 The average critical milk price in the EU was €34.08/100Kg;

 Luxembourg, France and Germany have relatively high critical milk prices;

 The UK, Italy, Belgium, the Netherlands and Ireland have relatively low critical milk prices;

 Larger farms, have on average a critical milk price 10-20% lower than smaller farms due to economies of scale (lower per unit production cost) and proportionately less money is required to cover the farmer‟s consumption level.

The future profitability, competitiveness and production of EU dairy farms will depend upon the milk price paid to farmers and the critical milk price. The weighted average EU milk price in September 2011 was €34.80/100Kg72 (which is just 2% above the average critical milk price) although this is expected to fall in the short-term72. OECD/FAO forecasts74 that the milk price will be €29.32/100Kg in 2018, although if a WTO agreement is reached, this would be expected to decrease by 5-10%. Comparing this estimate of future milk prices with estimates of the critical milk price (above), it can be seen that producers with average, or above average, production costs will be forced to close, or alter their operations to reduce production costs. LEI Wageningenur (2010)74 modelled milk production in the EU following the withdrawal of quotas and using the OECD/FAO price projections and concluded that:

 The total number of all farms reduced in all MSs considered; farms with higher production costs are forced to close;

 There were significant increases in the scale of dairy operations; those farms which continue to operate seek to gain economies of scale in order to reduce production costs;

 Small farms contributed a declining proportion of the total milk production; smaller farms have on average higher production costs and higher critical milk price and will be forced to close, or increase scale.

A report for DG Agriculture and Rural Development (2011)72 predicts that farms will also reduce production costs by continuing to increase the average yield per dairy cow; a cumulative increase of 18% productivity gain by 2020

is estimated. The report72 predicts that the combined effect of these factors will be for the EU dairy herd to contract by 7% by 2020, but for EU production to increase by 9% due to increased productivity78.

Dairy Sector Summary

The following conclusions may be reached for the EU dairy sector under the baseline scenario:

 Liberalisation of the EU dairy market will result in greater competition within the EU market and increased international competition in milk products, which is likely to result in a lower real milk price in future years;

 Less competitive producers (high production costs, high critical milk price) will be forced to close or re-structure;

 Those EU dairy producers which remain will seek to reduce production costs, through increasing herd size and increasing milk yield per cow in order to remain competitive;

 The two points above will be greatest for small herds in MSs where quota prices are currently high (The Netherlands, Cyprus) and in MSs with higher critical milk prices (Luxembourg, France and Germany);

 The EU dairy herd is estimated to decrease by 7% by 202072.

Any form of additional international trade agreement (WTO / MERCOSUR) will increase these impacts.

The implications of this for any options to control their emissions are:

 As dairy herds increase in size, more may approach any thresholds that could be established under a particular policy option (depending on the level at which they may be set), which may create a barrier to expansion;

 On farms that are scaling up to capture economies of scale, capital may be at a premium;

 Erection of new buildings is a good opportunity to introduce some measures which mitigate emission of pollutants to air.

3.5.4 Beef Industry

European beef is produced in two distinct types of operation: specialised farms with suckler cows or young bovine cattle and dairy farms where beef sales supplement income from dairy products. In the EU, two thirds of the cattle

78 These estimates are based on the following assumptions; CAP is assumed to follow the Health-Check decisions, global trade policy is assumed to respect the Uruguay round on agriculture and growth in the EU is assumed to increase by 2% p.a. from 2012 onwards. It should be noted that there are a number of uncertainties which would strongly influence estimates of productivity and production, the most important being; changes in agricultural and trade policies, macroeconomic assumptions on growth, changes in SPS payments, proposals for CAP reform to include requirements on minimum „green‟ areas on farms and changes in feedstock prices due to climate change and macroeconomic factors.

herd are housed in dairy farms79 and two thirds of the beef produced is directly or indirectly derived from dairy herds. In Northern and new MSs, up to 80% of the herd are in dairy farms, while conversely in some Southern MSs specialised beef farms are more prevalent79.

In 2011, the total indigenous production of beef in the EU-27 was 8,371 thousand tonnes, of which 350 thousand tonnes was exported80. The production of beef in the EU has been steadily declining and although the trade balance strengthened in 2010 and 2011, largely due to the weakening of the Euro relative to other beef producing nations, the long-term trend in the trade balance has been negative since 200381. This reduction in beef production is due to:

 EU beef production is uncompetitive compared with other countries81 due to competitive advantages in third countries (primarily the MERCOSUR group): relatively cheap inputs (feed and labour), large and reliable livestock supplies, lower levels of bio-security regulation and economies of scale82;

 The level of production subsidy and import tariffs EU beef producers had historically enjoyed has been reduced since 2003. In 2003 the CAP was reformed to promote decoupled aid (SPS), where the payment received is not linked to production83, although some transitional coupled aids have been retained is some MS, such as suckler cows in France79. Current import duties remain substantial at 12.8% of the value and €3/Kg for boned, chilled and frozen meat82.

In future, the competitive disadvantage of beef producers in the EU relative to developing nations (e.g. MERCOSUR) is likely to continue, due to the reasons outlined above. However, their advantage of low labour rates may reduce due to currency appreciation and faster wage growth. In addition, EU producers with capacity to do so may seek to increase herd sizes, to gain economies of scale, potentially those with small herds or those following intensive systems (i.e. where cattle are housed for all/most of the time).

EU producers are also likely to face increased competition in the internal market in future as import tariffs are gradually reduced. Although no agreement has yet been reached, it has provisionally been agreed at the Doha round of WTO talks that future reductions in customs duties on agricultural products will be applied using a tiered formula; import tariffs on beef will be reduced by 70% relative to their previous levels. In addition, the EU and MERCOSUR trade blocks are currently negotiating a free trade agreement, which will see import tariffs reduce and

79 Hocquette, J-F. & Chatellier, V., (2011), 'Prospects for the European beef sector over the next 30 years'. Available for download on the 18th March 2012 from: http://animalfrontiers.fass.org/content/1/2/20.full.pdf+html

80 European Commission, DG Agriculture and Rural Development, (December 2011), „Prospects for Agricultural Markets and Income in the EU 2011-2020‟. Available for download on the 20th March 2012 from: http://ec.europa.eu/agriculture/publi/caprep/prospects2011/fullrep_en.pdf

81 European Commission, DG Agriculture and rural development. Webpage: Beef and Veal. http://ec.europa.eu/agriculture/markets/beef/index_en.htm

82 European Commission, (2007), DG Enterprise and Industry, 'Competitiveness of the European Food Industry: An Economic and Legal Assessment'. Available for download on the 18th March 2012 from: http://ec.europa.eu/enterprise/sectors/food/files/competitiveness_study_en.pdf

83 European Association for Animal Production, 'Beef Production in the European Union and the CAP reform: An overview of situation and trends'. Available for download on the 18th March 2012 from: http://www.cattlenetwork.net/docs/eu/EU_Beef_sum_web.pdf

potentially disappear. The Sustainability Impact Assessment (SIA) for the EU/MERCOSUR Free Trade Agreement75 estimated that beef imports from MERCOSUR would be higher under all scenarios: 5,000 tonnes (no Doha agreement, EU offer), 288,000 tonnes (Doha only) up to 524,000 tonnes (Doha and MERCOSUR request). In the final scenario (Doha and MERCOSUR request), EU production of beef is estimated to decrease by around 280,000 tonnes with a loss in value of €4.6bn. Even without any change in trade policy, the European Commission84 estimate that beef/veal production could drop by 1.3% and the trade balance would return to a deficit.

In summary, it is likely that in future, reductions in import tariffs for key beef exporting countries (e.g. MERCOSUR) and further decoupling aid will result in: an increase of beef imports to the EU, a reduction in the EU/Rest of the World (RoW) beef price differential (reduction in EU internal beef price), a reduction in the operating margin of EU beef producers, a reduction of the quantity of beef produced in the EU and that those EU enterprises which continue to operate will be forced to implement measures to increase competitiveness (reductions in production costs, increased specialisation, greater productivity per head (e.g. through increased selective breeding), increased herd size to gain economies of scale).

Like the dairy industry, the beef industry is likely to face greater international competition in the future, but perhaps to a greater degree. There may be more options for beef producers (e.g. increasing production - see above) to respond than increasing numbers towards any threshold, although intensive producers (e.g. operators of feed-lot type production systems) may favour this option.

3.6 Summary

The environmental impacts associated with manure depend on which sort of practices are implemented and on the prevailing local conditions. Methane, formed by methanogenic bacteria in the slurry during storage, and nitrous oxide, mostly formed by denitrifying bacteria in anaerobic conditions when manure interacts with soil, impact climate change. Ammonia, partly dissolved in water and partly emitted into air, causes acidification of soil and water. The nitrification of ammonia forms nitrate (NO3-), which can lead to eutrophication of soil and water in case of an excess of nutrient in particular in vulnerable zones (e.g. NVZs). Ammonia is also a precursor of particulate matter that may affect human health and cause odours. Heavy metals originate from feed and then are excreted through manure, because animals do not assimilate them. These heavy metals can have toxic effects by interfering

84 European Commission, DG Agriculture and Rural Development, (December 2011), „Prospects for Agricultural Markets and Income in the EU 2011-2020‟. Available for download on the 20th March 2012 from: http://ec.europa.eu/agriculture/publi/caprep/prospects2011/fullrep_en.pdf

85 Agro Business Park, 2011, Manure Processing Activities in Europe

with metabolic activities of crops. Medical residues may induce health risks and microbial resistance. All these variables degrade the environment with secondary effects on biodiversity, in particular, in eutrophied zones. Emissions of ammonia to air from the spreading of manure across the EU are estimated to represent around 24% of the total emissions of ammonia from agriculture (almost 800kt) so is a major source for this pollutant.

Key legislation affecting manure management includes the Nitrates Directive and other freshwater policies (e.g. Water Framework Directive), the Industrial Emissions Directive (only for poultry and pig farms above specific thresholds), the National Emission Ceilings Directive soon to be revised (includes an emissions ceiling for ammonia which is in effect a cap on agriculture emissions), revised Gothenburg Protocol and the Common Agricultural Policy (also under reform). Whilst it is clear that some Member States are taking actions over and above EU legislation but there still appears to be significant potential for more.

4. Options Development

4.1 Overview

The development of possible options for controlling emissions from manure spreading has been carried out in accordance with the following criteria:

i. Co-beneficial effects for water, air, biodiversity, climate change and soil protection or beneficial to one or more of those media and neutral / minimal negative impacts to the others;

ii. Feasibility notably from an administrative and enforceability point of view;

iii. Potential economic benefit for the farmers e.g. due to more efficient resource use;

iv. Potential acceptability by farmers notably concerning costs and additional efforts at farm level (should not damage farm viability);

v. Compatibility with the need for improved animal welfare, including possible trade-offs;

vi. Large application potential, i.e. measures that under normal conditions are applicable in most Member States and regions.

In particular, the options developed have focussed primarily on those that reduce emissions to air and water recognising the significant impacts that manure can have on these media.

4.2 Approach to Developing Options

There are three main elements that need to be considered when developing possible options. They are:

i. The overall framework for control i.e. how any requirements would be placed on the sector;

ii. The scope of coverage i.e. which sizes and types of holdings could be affected including different species (cattle, pigs and/or poultry); and

iii. Best practices i.e. what measures would be required.

We have presented our proposals for sub-options against each of these main elements below, which can then be packaged together in different ways.

4.3 Overall Framework

Article 73(2)(c) does not limit the scope of the review to any specific mechanism so any of a number of ways in which emissions from manure spreading could be managed may be considered. We describe below the various approaches available for the development of policy options and identify the particular advantages and disadvantages presented with regard to managing emissions from manure spreading.

4.3.1 Business as Usual

Under this option, there would be no changes to existing regulations and farm businesses would carry on as usual. This is the „do nothing‟ option and forms the basis for comparison against the impacts of each alternative option.

4.3.2 Voluntary Approach (Option 1)

Under this option there would be no regulation to enforce BAT. Instead, individual Member States and the Commission would work with farming representatives to develop or build on existing voluntary schemes for encouraging the uptake of measures designed to limit air emissions (and other pollutants) from agriculture.

Description of the Voluntary Approach

The nature of the option (i.e. voluntary) means that there would need to be close involvement with the farming industry in developing the approach and framework. This could involve, for example:

 Gaining industry-wide sign up to the development of a code of good practice (e.g. equivalent to a BREF/BAT or developing existing codes established in response to the Nitrates Directive and Gothenburg Protocols). This could build on existing codes of good practice for the protection of air, soil and water; and

 Developing either a bespoke Quality Assurance Scheme (QAS) for managing emissions or extending existing ones where needed to cover emissions. New or existing mechanisms can be used for checking compliance. Branding/ labelling would be useful to create an expectation amongst producers and consumers of the rationale behind the QAS. It could then be left to market forces to promote uptake.

An example of an existing QAS which imposes environmental standards relevant to the current study can be seen in the Red Tractor Farm Assurance Dairy Scheme (RTFADS) which operates in the UK. Table 4.1 below presents an extract from the Dairy Standards manual86. Additionally, the appendices linked to these standards provide a good level of detailed and practical guidance on how these standards should be achieved, which is likely to constitute Best Practice.

86 RTFADS (2011). Dairy Standards. Version 2.0. See: http://www.assuredfood.co.uk/resources/000/618/004/Dairy_standard.pdf (Visited 21-02-13)

Table 4.1 Examples of Measures under the RTFADS in the UK

Standard Standard Explanation ref no

EC.10 K Fertilisers and soil conditioners Fertiliser applications (including those to grazing or forage conservation land) must Revised (including manures and composts) must follow current legislation and Defra‟s „Protecting our Water, Soil & Air – A Code of be suitable and applied to land in ways Good Agricultural Practice for farmers, growers and land managers‟ or equivalent which prevent pollution, contamination regional publications. and spread of disease. (DR.EC.10) Application of manures, sludges, anaerobic digestates, composts and other materials provides a valuable source of nutrients or soil conditioning but they might also cause pollution of the local environment, or contamination of crops or livestock. Producers should consider soil type, crop requirements, slope, field conditions, weather conditions, grazing or planting intervals and the position of surface waters, water supplies and water abstraction points even on neighbouring land. Regulations apply and, in designated areas, NVZ regulations impose additional restrictions. (See also standard EC.12) Any material that originates outside the holding that is applied to land must have an agricultural benefit and must be properly permitted by the Environment Agency, SEPA or NIEA. The application of waste animal by-products (for example waste abattoir material but not lairage manure) that have not been treated in any way is not permitted on any agricultural land including grassland and forage crops. For further information check with the Environment Agency, SEPA or NIEA. Further advice on the requirements of this standard may be found in the relevant appendix. Fertiliser applications (including those to grazing or forage conservation land) must follow current legislation and Defra‟s „Protecting our Water, Soil & Air – A Code of Good Agricultural Practice for farmers, growers and land managers‟ or equivalent regional publications. Application of manures, sludges, anaerobic digestates, composts and other materials provides a valuable source of nutrients or soil conditioning but they might also cause pollution of the local environment, or contamination of crops or livestock. Producers should consider soil type, crop requirements, slope, field conditions, weather conditions, grazing or planting intervals and the position of surface waters, water supplies and water abstraction points even on neighbouring land. Regulations apply and, in designated areas, NVZ regulations impose additional restrictions. (See also standard EC.12) Any material that originates outside the holding that is applied to land must have an agricultural benefit and must be properly permitted by the Environment Agency, SEPA or NIEA. The application of waste animal by-products (for example waste abattoir material but not lairage manure) that have not been treated in any way is not permitted on any agricultural land including grassland and forage crops. For further information check with the Environment Agency, SEPA or NIEA. Further advice on the requirements of this standard may be found in the relevant appendix.

EC.12 All farms using organic waste and Farm manures in this context are those which can be applied to land and include manures must have and implement a slurry, solid manure, poultry litter, silage effluent, dirty water and other organic written Manure Management Plan to wastes. The NVZ legislation will have an important impact on manure management. prevent pollution, contamination and Guidance on producing a Manure Management Plan is provided in Defra's spread of disease. (DR.EC.12) "Protecting our Water Soil & Air A Code of Good Agricultural Practice for farmers, growers and land managers" or equivalent regional documentation. For producers who solely graze and have no farm manure to dispose of, this standard is not applicable.

Source: RFADS

Another example of a voluntary measure is provided by the „Agri-Mieux‟ in France.

Box 3 Agri-Mieux in France

The “Agri-mieux” programme (previously known as “Ferti-mieux”) co-operative agreements in France aim to improve and protect water quality without generating income loss for the farmers. It mostly relies on providing communication and technical assistance to the farmers. By adopting the „Agri-Mieux‟ label, farmers commit to change their use of fertilisers. Some of the measures included in the programme are concerned with spreading of manure. For example, wide manure spreading and the composting of manure are measures that are recommended, and they were found to be successfully implemented by farmers part of the scheme.

Monitoring under the Voluntary Approach

The monitoring requirements under a voluntary approach rely on the willingness of the industry and the individual farmer that is adopting the voluntary measure. In practice, it can often be observed that an auditing system is established, in charge of monitoring the application of the measure. As the examples below show for the UK and Ireland, the certification and compliance monitoring under the voluntary approach are out-sourced (i.e. external auditing).

Box 4 Certification under the RTFADS

Specialist Certification Bodies independently verify that producers are adhering to the published standards. The Red Tractor Farm Assurance Dairy standards are licensed to Certification Bodies accredited to EN45011. Participating producers are then assessed and certified against the standards. NSF-CMi Certification, PAI Ltd and SAI Global operate the certification system for the Red Tractor Farm Assurance Dairy standards on behalf of the Scheme throughout the UK. In addition, in the devolved regions, the Scheme is also operated by SFQC (Scotland), QWFC (Wales) and NIFCC (N Ireland). The Scheme does not carry out any routine assessment or certification activities of its own. Through the Certification Bodies all members are subject to routine surveillance assessments and random audits. Red Tractor Assurance regularly reviews the performance of all Certification Bodies to ensure they are operating in accordance with the scheme procedures correctly and consistently. In addition the scheme operates a programme of independent random audits as a check that producers are maintaining standards between routine surveillance assessments and that the assessors are consistent.”

Source: http://assurance.redtractor.org.uk/rtassurance/farm/dairy/dr_about/Cert.eb (Visited 21-02-13)

Box 5 Monitoring Procedure for Pigs Producers under Ireland’s Bord Bia’s QAS

Monitoring of Producer compliance with the requirements of the standard will be carried out by Bord Bia or its nominated agents through audit. Each Producer will be independently audited at determined intervals. The maximum interval between successive audits will be 18 months. Independent Auditors with relevant sectoral experience will carry out these audits and a full report will be issued directly to the Producer. Bord Bia reserves the right to carry out audits or spot checks on an unannounced basis for the purpose of verifying compliance with the requirements of the standard or to determine that corrective/ preventive actions specified during audit are in place. Auditors are entitled to seek access to relevant regulatory reports. The full onus of responsibility for compliance with the requirements of this Producer Standard is on Producers participating in the Scheme and not on Bord Bia or its agents or any other third party.

Source: http://www.bordbia.ie/industryservices/quality/Documents/Pig%20Producer%20Standard.pdf (Visited 21-02-13)

Under Bia‟s approach non-compliance is categorised and actions are taken according to the severity of the non- compliance:

 Critical non-compliance will result in the expulsion of the producer from the scheme (re-entry may be allowed after an inspection shows the non-compliance has been addressed); and

 For other non-compliance (either category 1 or 2), procedures are in place to allow the producer time to rectify problems in order to avoid withdrawal of the certification.

Assessment and Conclusion

The table below summarises the main advantages and limitations that have been identified with the voluntary approach.

Table 4.2 Advantages and Limitations of the Voluntary Approach

Advantages Limitations

 It does not require any new legislation;  The uptake of the measure is unpredictable and could be  Being developed in close collaboration with the farming insufficient to secure adequate environmental gains; industry, it would have a high level of industry „ownership;‟  The extent of the public authority control is limited (i.e. during  The impacts on public sector and the industry, and the costs the design phase of the measure but also for ensuring generated would be low (e.g. farmers are most likely to follow compliance and monitoring the results) such as over the measures where it is in their financial interests to do so); compliance monitoring; and and  It is likely that the costs of compliance would be transferred to a price premium on food (as for other compliance options) – in  There are successful examples of this approach being in place this instance, however, consumers might be willing to pay the although it is unclear what impact they have had from an premium on the basis that it was from an environmentally environmental perspective. sustainable farm.

The overall conclusion of the assessment is that adopting a voluntary approach would entail substantial stakeholder involvement, dedicated efforts to develop a suitable framework (e.g. Quality Assurance Scheme (QAS) for managing emissions, a code of good practice etc.) and willingness of the individual farmer to engage in monitoring, reporting and verification activities. While a voluntary approach would not require introduction of any new

legislation and would likely benefit from industry support, the uptake rate of voluntary measures and subsequent environmental gains are highly uncertain and could be low.

4.3.3 Existing Instruments (Option 2)

The aim of this option is to identify opportunities within existing legislation to extend or modify their scope to include best practice-type measures relating to the spreading of manure.

Description

There are several existing instruments that could be amended or extended to include best practice measures for the spreading of manure. The main possibilities are presented below:

Industrial Emissions Directive (Option 2.1) There are two main options available under this Directive:

 Extending the scope of the existing BREF on Intensive Rearing of Poultry and Pigs and to include a wider range of measures and associated details related to manure spreading. The current draft of the revised BREF (August 2013) does include more detail on low-emission spreading techniques, measures related to timing and location of spreading, management practices (e.g. balancing the spreading of manure with the available land and soil/ crop requirements etc.) However these practices would only affect intensive pig and poultry installations above the thresholds in Annex I;

 An alternative approach could be for the spreading of manure to be included in the IED as a separate chapter with specific requirements set out in the Directive rather than relying on a BREF or included as a separate activity in Annex I. This option could be implemented via a permitting regime or a non- permitting regime e.g. based on general binding rules without permits.

The recent review of Article 73 of the IED87 concluded that the Commission does not intend to include cattle farms within the scope of the Directive nor change any of the other provisions of the Directive related to agriculture (these related to thresholds for different poultry species and farms with mixed activities). The inclusion of cattle would deliver somewhat limited environmental benefits while potentially imposing significant costs in respect of administration and compliance to a large number of farms. Overall the review concluded that the IED and its associated permiting regime was not the most appropriate mechanism for targeting wider agricultural activities beyond those intensive pig and poultry farms already captured. It did, however, recognise the significance of manure spreading for ammonia emissions and indicated that the revision of the NECD, in particular, potentially offered a more appropriate mechanism for targeting this activity.

87 European Commission (2013). Report from the Commission on the reviews undertaken under Article 30(9) and Article 73 of Directive 2010/75/EU on industrial emissions addressing emissions from intensive livestock rearing and combustion plants. COM(2013) 286 Final. Report from the Commission to the European Parliament and the Council. May 2013

Nitrates Directive (Option 2.2) The Nitrates Directive has led to the creation of codes of good practice which influence manure spreading practices within Nitrate Vulnerable Zones (NVZs). However, these measures are designed to ensure that leaching into water is reduced and not specifically for the control of air emission. Notwithstanding, the existing codes of good practice could be revised to include measures that more directly seek to reduce emissions to air, such as:

 Improved animal nutrition, designed to reduce nitrogen content of faeces;

 Manure spreading techniques that minimise air emissions; and

 Requirements to ensure prompt incorporation.

However, there are some difficulties with using the Nitrates Directive:

 The Directive is aimed at reducing nitrate (NO3-) pollution to water and its objectives may need re- casting to embrace wider objectives such as reducing emissions to air (e.g. of ammonia); and

 The Action Programmes produced under the Directive only apply within designated NVZs. Whilst some MSs have designated the whole of their territory as NVZ (e.g. Germany, Denmark, Ireland), others have not (e.g. UK, Spain, Italy). The efficiency of the measures would then be very variable across Member States. One potential revision, could therefore, include an extension of the geographical scope to the whole territory of Member States.

Overall, this option may constitute a longer term possibility, as the Nitrates Directive is unlikely to be open for revisions in the near future. Considering the focus of the Directive it is only considered feasible for it to be adapted for further targeting emissions to water from manure spreading rather than expanding to also address atmospheric emissions (although there may be synergies/co-benefits with some of the requirements for water).

National Emission Ceilings Directive (Option 2.3) The NEC Directive set upper limits („ceilings‟) for total emissions in 2010 of the four pollutants responsible for acidification, eutrophication and ground-level ozone pollution (i.e. sulphur dioxide, nitrogen oxides, volatile organic compounds and ammonia). Whilst the Directive sets ceilings which leave it up to the individual MS to decide which measures should be adopted in order to comply (i.e. the Directive is sectoral neutral in that it sets a ceiling on total emissions), agriculture contributes the majority of ammonia emissions meaning that Member States are likely to have to target the sector in order to meet the ceiling. Proposals for a revised NEC Directive with ceilings for future years (2025 and/or 2030) will be adopted later in 2013 and could act as a mechanism for targeting agriculture emissions overall including those from manure spreading. It is worth noting that the majority of the Member States met their 2010 targets comfortably and limited additional measures appear to have been proposed for agriculture leaving potential scope for setting more stringent targets.

Furthermore, there is scope for supplementing a revised Directive with new ceilings with implementing measures setting out more specific requirements for the agriculture sector e.g. requirements for farms to use low-emission spreading techniques and fast incorporation.

Monitoring

One of the main advantages of choosing to introduce new measures into an existing instrument is that the monitoring mechanisms have already been designed and implemented to a certain extent.

Under the IED, Member States are required to set up a system of environmental inspections of the installations concerned. All installations have to be covered by an environmental inspection plan as part of their permit. The plan must be regularly reviewed and updated. Based on the inspection plans, the competent authority will regularly draw up programmes for routine environmental inspections, including the frequency of site visits for different types of installations. The period between two site visits will be based on a systematic appraisal of the environmental risks of the installations concerned. It shall not exceed one year for installations posing the highest risks and three years for installations posing the lowest risks. Furthermore, operators will have certain obligations in terms of reporting on implementation of best available techniques and compliance with their permit.

The Nitrates Directive requires the following:

“Member States shall draw up and implement suitable monitoring programmes to assess the effectiveness of action programmes established pursuant to this Article. Member States which apply Article 5 throughout their national territory shall monitor the nitrate content of waters (surface waters and groundwater) at selected measuring points which make it possible to establish the extent of nitrate pollution in the waters from agricultural sources.”

Finally, under the NEC Directive, Member States have to report their emission inventories to the European Environment Agency (EEA) and the European Commission which in turn monitor the progress and verify overall compliance. Under the existing NECD they also have to submit national implementation reports documenting the policies and measures being taken to achieve their ceilings. It is likely that this requirement would also be included in a revised Directive. If implementing measures were to be introduced then further monitoring and reporting requirements may need to be introduced although it is likely they could be dealt with via the national implementation reports.

For these three instruments, monitoring is a compulsory requirement. In all of the three instruments, it seems that it could be extended to include any extension/ modification of the scope of the legislation. However, as highlighted above, opening and revising either the Nitrates Directive or IED is unlikely to constitute a feasible policy option in the short-term unlike the NEC Directive which is currently undergoing revision.

Assessment and Conclusion

The modification of existing instruments to include measures addressing the spreading of manure presents some advantages and limitations. The table below presents a summary of these.

Table 4.3 Advantages and Limitations of the Existing Legislation Approach

Advantages Limitations

 Relies on the existing legislation, it is overall easier to revise an  It is restricted by the scope or „raison d‟etre‟ of certain existing framework than introducing a whole new one. instruments, for example the IED currently only covers pig and  It relies on a framework that farmers are already familiar with, poultry farms above a specific threshold. so it may be easier to assimilate.  It may blur the objectives of the existing targeted legislation, for  It allows the use of existing monitoring mechanisms. example the Nitrates Directive is aimed at reducing nitrate pollution of surface and groundwater sources, not air emissions  Adopting implementing measures alongside a revised ammonia of ammonia (although it is a side-effect). emission ceiling in the NEC Directive could allow for targeted  Existing instruments such as the IED and Nitrates Directive are measures for certain activities whilst still leaving a certain unlikely to be up for renegotiation at present and are therefore element of flexibility for Member States to decide how best to only potentially relevant in the longer term. meet the overall ceiling.  Inclusion of cattle under the scope of IED would extend burdensome permitting regime to wider number of installations and has already been considered by the Commission as not fit for purpose in recent review

The overall conclusion of the assessment is that in spite of a range of advantages associated with the IED (Option 2.1) and the Nitrates Directive (Option 2.2.) including use of existing monitoring mechanisms and familiarity of the affected parties with the legislation, the Directives are restricted by their scope and original objectives. Considering the focus of the Nitrates Directive, for instance, it is only considered feasible for it to be adapted for further targeting emissions to water from manure spreading rather than expanding to also address atmospheric emissions. Furthermore, the IED and the Nitrates Directive are unlikely to be up for renegotiation in the short-term so would constitute longer term options only. The recent review of Article 73 of the IED concluded that the Commission does not intend to include cattle farms within the scope of the Directive nor change any of the other provisions of the Directive related to agriculture as the inclusion of cattle would deliver somewhat limited environmental benefits while potentially imposing significant costs in respect of administration and compliance to a large number of farms. Overall the review report concluded that the IED and its associated permiting regime was not the most appropriate mechanism for targeting wider agricultural activities beyond those intensive pig and poultry farms already captured.

On the other hand, the ongoing revision of the NEC Directive and its specific focus on reduction of air emissions

(including NH3) constitutes one of the most feasible and attractive options (Option 2.3) in a short-term, particularly as the use of implementing measures provides some flexibility for the types of measures to be prescribed. Considering the focus on the Directive, it is only considered feasible for it to be adapted for further targeting emissions to air from manure spreading rather than expanding to also address water emissions (although there may be synergies/ co-benefits with some of the requirements for air).

4.3.4 Common Agricultural Policy (Option 3)

Description

Pillar I under the CAP could be extended to include best practice measures for the spreading of manure, while Pillar II could be amended to explicitly cover manure spreading measures. The main possibilities are presented below:

Cross-compliance Measures under CAP Pillar I (Option 3.1) Under this option, anyone in receipt of subsidies paid under Pillar I of the CAP would be required to adhere to certain farm management practices in order to continue to be eligible for payment. Failure to adhere to the prescribed measures would result in a reduction in the subsidy payment and, the greater the transgression is, the greater the reduction will be. The prescribed measures would be best practice.

At present, cross-compliance is a requirement for anyone claiming subsidies under the Single Payment Scheme and has two elements:

 Good Agricultural and Environmental Condition (GAEC): it requires claimants to adhere to certain forms of good practice. Mostly, these are minor management measures with little or no capital cost implications. For example, a good practice measure is to not spray or use fertiliser near watercourses, or keeping rights of way clear. Member States are allowed to define their own list of measures in line with four broad categories (i.e. soil erosion, soil organic matter, soil structure and minimum level of maintenance);

 Statutory Management Requirements (SMR): it requires applicants to operate within a suite of environmental regulations. Non-compliance means that they can lose some of their payments if they break the law.

According to the agreements reached in July and September 2013, the current Single Payment and Simplified Area Payment schemes (relevant to the Member States who joined the EU in 2004 and 2007) will be replaced by a Basic Payment Scheme, payments to encourage environmental practices and young farmer‟s entrants and “redistributive payments”.

The introduction of measures to control spreading of manure through cross-compliance could take two forms:

 The extended existing legislation or the new legislation could be added to the list of SMRs; and/ or

 GAEC could be re-defined to cover selected manure spreading measures, for instance the requirement to use low-emission spreading techniques.

Whilst a lot of variations have been observed at EU level of the implementation of GAEC in Member States, the requirement to prepare soil management plans (in some Member States such as the UK) would have parallels with a requirement to prepare, for example, cattle feeding strategies and/or nitrate budgets.

GAEC has long been concerned with the state of the land and its uses. It is therefore appropriate that cross- compliance be extended to include best practice measures designed to reduce/minimise pollution (of whichever receptors) from manure spreading. Examples of suitable measures would be:

 Timing specific (short-term restrictions such as not applying to frozen, snow-covered or waterlogged ground);

 Maximum permissible timings for incorporation of manures/slurries within the soil (e.g. 6, 12 or 24 hours, depending on manure type);

 Location specific (spreading not to occur within a specified distance from boreholes, streams, waterbodies etc.);

 Spreading methods (e.g. no rain guns to be used); and

 Overarching condition that application of nutrients (whether organic or manufactured) should be balanced with the needs of the crop and available nutrients in the soil. However it would be difficult to enforce in practice.

To some extent, these measures are already in force in some MSs. The box below (Box 6) presents the measures available in the UK.

Box 6 ‘No spread zones’ under UK GAEC

The aim of these rules is to protect water against pollution and run-off from agricultural sources. A. You must not 1. Apply manufactured nitrogen (inorganic) fertiliser within 2 metres of surface water1; 2. Apply organic manure2 within 10 metres of surface water, except on land managed for breeding wader birds or as species-rich semi-natural grassland and under certain other restrictions3. 3. Apply organic manure within 50 metres of a spring, well or borehole. If you apply organic manure: B. You must 1. Produce and keep a map4 of your holding showing: • All surface waters on your holding and land within 10 metres of them; • All springs, wells and boreholes on your holding, and within 50 metres of the boundary of your holding, and land within 50 metres of them; 2. Update the map with any changes within 3 months from the date of the change. If you have land under Nitrate Vulnerable Zones (SMR 4) and follow those requirements, you will also meet the rules under this standard in respect of that land. To protect water quality Defra is strongly encouraging farmers to consider placing 6-metre buffer strips next to vulnerable watercourses. Buffer strips can contribute to the reduction of pollution from farming activities. Details of the use of these can be found at section 6 of the Cross Compliance Guidance for Soil Management 2010 edition. ______1. „Surface waters‟ include lakes, rivers, streams and ditches which contain free water and also temporarily dry ditches and blind ditches. 2. „Organic manure‟ means any nitrogen fertiliser or phosphate fertiliser derived from animal, plant or human sources and includes livestock manure. 3. The restrictions are: the land must be in an agri-environment scheme or an SSSI and livestock manure only (other than slurry and poultry manure) is spread between 1 June and 31 October inclusive, it is not spread directly on to surface water and the total amount does not exceed 12.5 tonnes per hectare. This may be the risk map produced for regulation 18 of the Nitrate Pollution Prevention Regulations 2008, that is, your NVZ map. Source: RPA Website

A further example of such measures is included in the Danish Action Plan for Reducing Ammonia Volatilization from Agriculture. The plan includes the following elements:

 Only band spreading and injection of slurry is permitted;

 A time limit for incorporating slurry in the soil (6 hours); and

 Compulsory cover of manure stores.

The CAP is currently being reformed and is due to be approved by the end of 2013 and effective from 1 January 2015. The new cross-compliance standards will maintain the inclusion of the Nitrates Directive, while the GAEC will include the maintenance of the requirements on buffer strips and minimum soil cover. In practice, using CAP Pillar I as an overall framework to reduce emissions to air and water is unlikely to constitute a feasible option in the short-term; it may be considered more relevant, however, post 2020.

Support for Rural Development under CAP pillar II (Option 3.2) The second pillar (Pillar II under the CAP) is dedicated to rural development and provides subsidies for actions such as sustainable agricultural practices (agri-environmental measures or AEM) among other types of support. It is financed partly by the European Agricultural Fund for Rural Development (EAFRD) and partly at national level.

According to the agreement reached in September 2013, the rural development policies will become more flexible and better coordinated with the territorial interventions of other EU funds. New institutional mechanisms for innovation are proposed, backed up with a larger budget for research to address environmental and climate policy challenges. The agreement reached has also resulted in amendments to the priority area number 5 to include NH3. In particular, ammonia has been added in the Rural Development Indicators in addition to greenhouse gases. This amendment has made ammonia abatement measures directly eligible for funding. This means that Member States will have the possibility to support measures that more specifically target manure.

The Danish Rural Development Plan (as required under the CAP Regulation), for instance, already contains measures directed at reducing emissions from ammonia and methane. For example, Measure 121 aims at reducing localised ammonia and methane emissions through the improvement of storage conditions and the spreading techniques for manure and slurry88.

The impact of the CAP reform agreement on reduction of ammonia emissions is unknown at the present and will depend on the individual Member States choice on provision of support. Ammonia abatement measures that will be included in the RDP following the agreement are effectively part of the baseline.

However, to maximise the impacts this option could involve clarifying the scope of CAP Pillar 2 by including best practice measures on manure management and spreading and explicitly promoting their uptake and inclusion in the RDP by different Member States.

Monitoring

In the context of the Pillar I option (Option 3.1), EU legislation requires at least 1% of claimants subject to cross- compliance requirements to be inspected each year. Several organisations, known as Competent Control Authorities (CCAs), are responsible for inspecting different cross compliance requirements. Each CCA will select and carry out inspections on the farm businesses that need to comply with the SMRs and/or GAECs for which the CCA holds responsibility. The results of all inspections are passed to the relevant „paying agency‟, which will take them into account in determining whether payments are to be reduced and, if that is the case, by how much they will be reduced. As a requirement of claiming, the relevant subsidy farmers must cooperate with the inspector and provide facilities and labour to allow the necessary checks to be made. Failure to allow inspection, or give reasonable help or obstructing an inspector may result in the loss of the qualifying payments.

88 AEA, 2012, Next phase of the European Climate Change Programme: Analysis of Member States actions to implement the Effort Sharing Decision and options for further community-wide measures

A common monitoring and evaluation framework exists with the aim of measuring the performance of the common agricultural policy, including of the rural development measures (Option 3.2). The impact of the CAP measures is assessed in relation to a number of objectives, including for instance, viability of food production. Sustainable management of natural resources and climate action, with a focus on greenhouse gas emissions, biodiversity, soil and water is another objective that is being monitored and evaluated. Evaluation is carried out based on the set of indicators specific to the objectives. In accordance with the agreed CAP reform, an ammonia indicator is now being developed under the RDP and will be adopted though comitology system.

Assessment

The use of cross-compliance measures addressing the spreading of manure (Option 3.1) or specifying the scope of CAP Pillar 2 and promoting the inclusion of ammonia abatement measures in the RDP by different Member States (Option 3.2) present some advantages and limitations. The table below presents a summary of these.

Table 4.4 Advantages and Limitations of the Cross Compliance Approach

Advantages Limitations

 It relies on mechanisms which have already been set up and  Monitoring compliance with some measures can be difficult and used (Option 3.1 and Option 3.2) resource intensive (Option 3.1)  It has a strong incentive as subsidies could be reduced as a  Costs of some of the measures are likely to be substantial and result of non-compliance (Option 3.1) may be unaffordable for some farmers (Option 3.1 and Option  It would impact widely as a majority of farmers are claiming 3.2) subsidies(Option 3.1)  Some intensive livestock installations (pigs and poultry units regulated under the IED) would not be affected by this, as they  Implementation of measures would be eligible for funding claim no or little in SPS payments (unless impacted indirectly support via RDP (Option 3.2) where manure is spread on land managed by third parties who are claiming subsidies) (Option 3.1)

Overall, the Option 3.1 would be reliant on the extension of the existing legislation or introduction of new legislation that could subsequently be added to the list of SMRs. Alternatively, the Option would require re- definition of GAEC to cover selected manure spreading measures. In practice, using CAP Pillar I as an overall framework to reduce ammonia emissions to air and water is unlikely to constitute a feasible option in the short- term; it may be considered more relevant, however, post 2020.

Inclusion of ammonia alongside GHG within the Priority Area number 5 under the RDP (Option 3.2) constitutes a promising option in the short-term. In practice, however, the impact on reduction of ammonia emissions is unknown at the present and will depend on the individual Member States choice regarding the provision of support. This in turn will depend on the priority given to ammonia emissions by individual Member States. It should be noted that the impact of the CAP reform agreement on reductions of ammonia emissions using RDP will effectively become part of the baseline. Additional emissions reduction could be achieved by clarification of best practice ammonia abatement measures from manure spreading and by explicit promotion of their inclusion in the RDP by different Member States.

4.3.5 New Legislation (Option 4)

Description

There are several options to develop new legislation that would require best practice measures for the spreading of manure and possibly include a wider scope to address nitrogen pollution more holistically. The main possibilities are presented below.

New Directive on Manure Management (Option 4.1) A new piece of legislation aimed specially at the reduction of emissions to air and/or water (depending on Commission priorities) from the spreading of manure could be developed. The scope of new legislation would need to be extended to all major agricultural activities that pose a risk of emitting pollutants to air and water from manure, including intensive pig, poultry and cattle rearing enterprises. Furthermore, the new legislation could also capture manure spreading activities carried out by arable farmers and contractors in situations when manure is spread by a third party rather than by manure producers themselves.

It should also define and include in the legislation a threshold below which the requirements would not apply. The legislation could for example, follow the same approach adopted in the IED that is using numbers of animal places as the determining criterion. Possible options for setting thresholds are discussed in more detail in Section 4.4 and an analysis of different thresholds is described in Section 5.3.1. The requirements set out in the legislation would also apply to contractors and arable farmers spreading the manure produced at the intensive rearing farms falling within the scope of the legislation adopted. The legislation would then set out what is considered to be best practice, and installations above the threshold as well as their contractors would be required to adopt it, e.g. general binding rules. Alternatively, any new legislation could be targeted directly at those farms spreading the manure (rather than via those producing it initially) in which case any thresholds would have to be linked to volumes of manure being spread rather than animal numbers.

The new legislation could possibly involve the competent authority issuing a permit and ensuring that permits would be reviewed at suitable intervals. The permits could be issued on receipt of an acceptable management plan showing how manure spreading carried out by the producer or their contractors would comply with the defined best practice requirements.

Another option for a new piece of legislation would be to make it a legal obligation to be part of a QAS which must have standards covering manure spreading (see Section 4.3.2).

Integrated Nitrogen Management Directive (Option 4.2) A new Integrated Directive could be developed bringing together all relevant existing nitrogen legislation with an extended scope to ensure manure spreading is suitably targeted. The scope of the new Directive would be much broader than manure management and could cover all major agricultural activities that pose a risk of emitting pollutants to air, including intensive pig, poultry and cattle rearing enterprises including their contractors. The Directive would consider and replace all existing nitrogen related legislation, including relevant IED provisions for intensive livestock farms and the Nitrates Directive‟s requirements. It could also cover fertiliser use, animal

housing and feeding measures, manure storage, treatment and use in addition to manure spreading. The Directive could also extend to agricultural use of non-agricultural organic matter such as paper waste, sewage sludge/ biosolids and digestate from anaerobic digesters.

Depending on the form and scope of a new directive, it should also define and include a threshold below which the new legislation would not apply, following for example the same approach adopted in the IED that is using numbers of places as the determining criterion. A separate document could be produced setting out what is considered to be best practice, and installations above the threshold would be required to adopt it. New legislation could:

 Apply to farms captured by the scope of the legislation (using numbers of head, livestock units or volumes of manure being spread as the measure);

 Require a guidance document/code of practice to be produced which would explain to farmers what would constitute best practice;

 Require the managers of these farms to submit a management plan showing how their operations would comply with the code of practice;

 Possibly involve the competent authority issuing a permit when in receipt of an acceptable management plan and ensure that permits would be reviewed at intervals (if the permits option is opted for); and

 Put in place a compliance monitoring regime.

Introduction of a new integrated Directive would potentially streamline existing requirements reducing existing overlaps between current legislation. The option, however, could only be feasible in the long-term as is the case with Option 4.1.

Monitoring

At the Member State level, suitable monitoring programmes would need to be established to monitor the progress and effectiveness of the best practice measures in terms of reduction of ammonia emissions. Under these options (Option 4.1 and Option 4.2), monitoring would be defined during the design of the legislation and could be adapted to the particular needs of regulating manure management or, in the case of Option 4.2, to cover all activities covered by the integrated directive.

Option 4.1 would require specific monitoring for manure management, while Option 4.2 would need to integrate requirements from all relevant nitrogen legislation as well as cover new requirements targeting manure management.

Both options (Option 4.1 and Option 4.2) could possibly involve a competent authority issuing a permit and setting out an appropriate compliance monitoring regime. Such a monitoring regime, could potentially build on the existing IED monitoring system for poultry and pig rearing enterprises while being extended to capture intensive cattle rearing enterprises and manure spreading contractors. In particular, Member States could be required to set up a system of environmental inspections of the installations concerned. In the case of intensive pig and poultry

rearing enterprise, these would already be captured under the IED monitoring arrangements. Intensive cattle rearing enterprises would also need to be covered by an environmental permit and associated inspection plan. The plan would need to be regularly reviewed and updated. Based on the inspection plans, the competent authority would regularly draw up programmes for routine environmental inspections, including the frequency of site visits for different types of installations. The period between two site visits would be based on a systematic appraisal of the environmental risks of the installations concerned. For instance, according to the IED, it should not exceed one year for installations posing the highest risks and three years for installations posing the lowest risks.

In instances, where manure is being spread by a third party rather than by manure producer itself, compliance with the best practice requirements set in the new legislation could be ensured by the manure producer using, for instance, contract arrangements based on duty of care philosophy, e.g. manure transfer notes. In particular, a third party spreading the manure could be contractually bound to follow the best practice set out in the new legislation (Options 4.1 and 4.2) and to provide evidence to the producer for reporting to competent authority.

The permitting approach, however, would be quite onerous on competent authorities and operators. A lighter touch non-permit approach could also be taken whereby farms spreading manure would be required to maintain manure management records documenting volumes being spread and techniques being used. A proportion of farms would be subject to inspections each year to verify these records building potentially on the existing monitoring system under Pillar I of the CAP (that already includes Nitrates Directive among SMRs).

Assessment and Conclusion

The introduction of a new piece of legislation targeted solely at manure management(Option 4.1) or a wider integrated nitrogen directive (Option 4.2) that would include measures addressing the spreading of manure (as well as other areas for Option 4.2) presents some advantages and limitations. The table below presents a summary of these.

Table 4.5 Advantages and Limitations of the new Legislation Approach

Advantages Limitations

 Allows clear objectives to be set and strived for focussed on  The process can be particularly long to introduce reducing impacts to multiple environmental media rather than  More legislation is unlikely to be welcomed by interest groups just one e.g. air. and MS governments  Allows for a tailored approach to be adopted without having to  The introduction and implementation of new legislation is costly fit in an established framework. and in the current economic climate may not be welcomed by  An integrated approach to nitrogen bringing together all existing Member States legislation could potentially reduce the overall administrative  New legislation may conflict with the existing legislation, e.g. burdens on Member States and farmers. when introducing more stringent requirements or applying existing requirements on a wider scope.

The overall conclusion of the assessment is that introducing new legislation focussed on manure management (Option 4.1) would ensure regulatory transparency, consistency and comparability among different Member States.

It would also provide a high degree of certainty in achieving the environmental objectives set as it would specify best practice requirements and would apply to manure producers as well as their contractors.

Introduction of a new integrated nitrogen directive (Option 4.2), on the other hand, would bring together all relevant existing nitrogen legislation and would cover all major agricultural activities that pose a risk of emitting pollutants to air and water, including intensive pig, poultry and cattle rearing enterprises and their contractors. The option would potentially improve streamlining of current legislation targeted at agriculture reducing overlaps. However, a lot of effort would be required to develop such a Directive considering the broad scope and need to review a number of pieces of existing legislation.

Overall, introduction of new legislation (Options 4.1 and 4.2) could entail substantial compliance costs for manure producers and those spreading it as well as substantial administrative costs for competent authorities and the sector, e.g. additional permitting and monitoring. Administrative costs, however, would depend on the specific approach taken. In particular, adopting a lighter touch approach would minimize administrative burden.

Having regard to the limitations described above, introduction of new legislation (Option 4.1) or a new integrated nitrogen Directive (Option 4.2) could only be feasible in a longer-term.

4.4 Scope of Coverage

4.4.1 Overview

A further issue to consider for the development of possible options for assessment is the overall scope of coverage i.e. which size and types of farms may be affected. This may be influenced by the choice of overall framework for controlling emissions. For example, if the IED were to be amended to require the application of BAT to the spreading of manure and slurries outside the site of the installation then only those pig and poultry farms above the thresholds in Annex I of the Directive would be captured.

The scope of coverage of a particular option could be defined in two main ways: geographical and/or numerical. Each of these is discussed in turn below.

4.4.2 Geographical

A geographical approach could be taken in a similar way to that under the Nitrates Directive where certain areas of a Member State are designated Nitrate Vulnerable Zones (NVZs) and farms in these areas are required to adopt certain measures to reduce pollution to water bodies (as presented in Table 3.8). This approach has the benefit that an existing framework is already in place although the current approach is focussed solely on water pollution and does not consider issues related to air pollution. Furthermore, as discussed above, revision of the Nitrates Directive is considered extremely unlikely in the short term. Designating certain zones close to populated areas and/or sensitive sites where farms have to apply certain measures could be valuable for reducing health and environmental impacts from emissions to air. However, from a greenhouse gas perspective and considering compliance with future emission ceilings for ammonia, the exact location of emission is not important.

A geographical approach could be combined with a numerical threshold approach to ensure that only certain sized farms are targeted rather than including even the smallest farms where costs may be disproportionate to the benefits that may be realised.

4.4.3 Numerical Thresholds

The scope of coverage of a policy option could be defined by using a numerical threshold approach which would aim to ensure that only the largest farms are targeted. Numerical thresholds could be established in a number of ways:

 Number of animal places: this approach is already applied in the IED to ensure that only the largest farms are covered by the legislation. Single species thresholds are set for pigs and poultry but cattle is excluded. A number of Member States also apply a similar approach (beyond the IED requirements) in some cases setting thresholds lower than those in the IED and/or also including thresholds for cattle. A similar approach could be taken (if not via the IED itself) whereby thresholds could be established for each species e.g. IED thresholds for pigs and poultry and an agreed “intensive” threshold for cattle such as 300 (dairy) and 400 (beef) as applied in Estonia;

 Livestock Units (LSUs): A similar approach to the above could be to define thresholds in terms of LSUs. This has the advantage (over an animal places approach) of ensuring that farms with a similar environmental impact (including the volume of manure produced) would be captured by the policy even if for each species they would fall below any species specific thresholds. Possible thresholds could be 5 LSU (as specified in the highest aspiration level from the guidance document developed for the Gothenburg Protocol revision, lower levels of ambition include 50-200 LSU) or 15 LSU (as currently included in IIASA‟s GAINS modelling). However, a set of standard LSUs for each species would need to be agreed and applied by all MSs e.g. as provided by Eurostat89;

 Volume of manure produced or being spread: An alternative approach to the two options presented above could be to define those farms captured by the policy in terms of either (a) the volume of manure being produced or (b) the volume of manure being spread (e.g. on an annual basis). This would ensure that those farms spreading large volumes of manure would be captured by the policy even if the manure is provided by a number of smaller farms that would perhaps not be captured individually by any size thresholds. However, this option could perhaps be quite challenging to regulate as it would require precise data on the volumes of manure being produced and/or spread by a particular farm which is likely to vary from year to year.

4.4.4 Summary

89 Available from: http://epp.eurostat.ec.europa.eu/statistics_explained/index.php/Glossary:LSU

numbers approach (heads or LSU) is fine. In order to ensure that it would still be spread according to the policy there would need to be a requirement for those farms producing the manure to subsequently require their contractors to spread the manure appropriately. This could be in the form of a manure transfer note, similar to current approaches for waste management. In particular, where manure is being spread by a third party rather than by manure producer, responsibility to ensure compliance with the best practice requirements could be placed on the manure producer. This could be achieved, for instance, by using contract arrangements based on duty of care philosophy, e.g. manure transfer notes that would make the best practice requirements also binding for the parties spreading the manure. This type of approach is already applied by some Member States in their national legislation. However, if an option is to target those spreading the manure directly then an approach based on geographical area or manure volumes would be most appropriate.

An assessment of the implications of possible thresholds based on animal places and LSUs in terms of numbers of farms and animals affected has been undertaken and is presented in Section 5.3.1.

4.5 Defining Best Practice

4.5.1 Overview

This section covers Best Practice definition in relation to manure storage and spreading techniques (including equipment) as well as spreading practices including spreading quantities, area and timing. The description of the measures and practices provided cover both reducing ammonia emissions to air and reducing nitrate (NO3-) leaching to water courses.

The Intensive Rearing of Poultry and Pigs BREF (July 2003) is undergoing revision at present. In particular, work is ongoing on definition of possible BAT for the whole sector (general conclusions) and other sector-specific BAT including how they should be formulated, the level of details needed to describe and inform about possible applicability constraints of each BAT, in order to fulfil the requirements of the IED. In particular, information concerning applicability may include constraints related to three different climatic zones, economic viability, different implementation to new or existing installations, etc. Combinations of techniques which could support the formulation of BAT conclusions for the whole farm are also being explored. Economic assessment of possible BAT measures was originally anticipated to be available by the end of March 2013 but it appears to have been delayed. In order to reduce environmental impacts, both preventive measures (genetic selection, better housing, more adequate feed) and curative measures (storage, exportation and processing of liquid manure, compost, improvement of infrastructures) can be applied.

Furthermore, Annex II and Annex III of the Nitrates Directive set out requirements that should be covered by the Code of Good Agricultural Practice and Action Programmes. For instance, Action Programmes for the NVZs have to set out periods when the land application of manure is prohibited and associated minimum capacity of manure storage. The Directive, however, does not prescribe any specific measures or thresholds that should be followed. For instance, while CoGAP should set out conditions for land application of fertilizer near water courses it does not prescribe a minimum distance. Similarly, the NEC Directive does not prescribe any specific measures aimed at reduction of ammonia emissions from agriculture.

Therefore, consideration of potential “best practice” measures aimed to reduce ammonia emissions to air and nitrate leaching was based on the review of literature, the Intensive Rearing of Poultry and Pigs BREF (July 2003) and associated national BAT/BREF documents, national Codes of GAP and Action Programmes under the Nitrates Directive and National Programmes under the NEC Directive.

In general, best practices in relation to manure storage and spreading techniques are more relevant to tackling air emissions, while best practices in manure management are more relevant to avoiding nitrate leaching to water.

4.5.2 Best Practice in Manure Storage

In the context of air pollution, for manure storage, abating ammonia emissions is based on one or more of the following principles (i) decreasing the surface area where emissions can take place, i.e. through covering of the storage, (ii) decreasing the time that emissions can take place, i.e. through frequent removal of the slurry/ manure; and (iii) decreasing the source strength of the emitting surface, i.e., through lowering the pH and NH4+ concentration.

Keeping animals indoors (i.e. mostly mono-gastric animals such as poultry, pig and rabbits, plus cattle under some systems) is generally associated with a greater relative loss of ammonia per unit ammonia excreted, due to the larger and longer duration of fouling areas and higher temperatures (Kaveolis, 2006) potentially contributing to air emissions. Housing, however, makes it possible to collect excrements, store these properly, and apply them at moments and in places where crops are most in need of the nutrients they contain, thereby contributing to the reduction of nitrate leaching. Free ranging animals (sheep, goats, horses and cattle under various grazing regimes), by contrast, tend to leave their excrements in hot spots (e.g. where animals concentrate in search of water, shade or shelter) as a result of which crop uptake and hence nutrient utilization can be extremely low (EEA, 2000).

The Intensive Rearing of Poultry and Pigs BREF (July 2003) sets out the following BAT requirements for manure storage: BAT is to design storage facilities for pig and poultry manure with sufficient capacity until further treatment or application to land can be carried out. The required capacity depends on the climate and the periods in which application to land is not possible. For pig manure, for example, the capacity can differ from the manure that is produced on a farm over a 4 – 5 month period in a Mediterranean climate, a 7 – 8 month period in the Atlantic or continental conditions, to a 9 – 12 month period in boreal areas. For poultry manure the required capacity depends on the climate and the periods in which application to land is not possible.

The Nitrates Directive (Annex II and Annex III) also sets requirements regarding manure storage. In particular, Codes of Good Agricultural Practice should cover, as a minimum, requirements on the capacity and construction of storage vessels for livestock manures. The main aim of the measures is to prevent water pollution by run-off and seepage into the groundwater and surface water of liquids containing livestock manures and effluents from stored plant materials such as silage. Furthermore, Action Programmes developed by the Member States have to stipulate the capacity of storage vessels for livestock manure. The capacity needed must exceed that required for storage throughout the longest period during which land application in the vulnerable zone is prohibited, except where it can be demonstrated to the competent authority that any quantity of manure in excess of the actual storage capacity will be disposed of in a manner which will not cause harm to the environment. While the Nitrates Directive primarily aims to protect water environment, having a sufficient and self-contained storage for manure potentially

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indirectly contributes to reducing the time that ammonia emissions can take place as manure and slurry can be removed frequently and stored safely.

According to the Intensive Rearing of Poultry and Pigs BREF (July 2003) for pig manure that is always situated on the same place, either on the installation or in the field, BAT is to:

 Have a concrete floor, with a collection system and a tank for run-off liquid; and

 Locate any new build manure storage areas where they are least likely to cause annoyance to sensitive receptors for odour, taking into account the distance to receptors and the prevailing wind direction.

If poultry manure needs to be stored, BAT is for it to be dried and stored in a covered structure with an impermeable floor, and with sufficient ventilation.

For a temporary stack of pig or poultry manure in the field, BAT is to position the manure heap away from sensitive receptors such as, neighbours, and watercourses (including field drains) that liquid run-off might enter.

A range of odour control measures are available to farmers (Shaw, 2009; Toombs 2013), including:

 Reducing or inhibiting emissions by prevent manure compound volatilisation (reducing storage area surface, decreasing temperature and limit air moving, and incorporating manure shortly after spreading) and by reducing dust which transport odour compounds;

 Dilution of odours and odorous compounds by using for example biofilters such as trees and shrubs or shelterbelt and windbreak walls at various heights ; and

 Biological or chemical transformation into something less odorous by composting manure, using enzyme or chemical additives.

Measures aimed at controlling odours from a permanent or temporary storage of pig or poultry manure are also likely to contribute to reducing ammonia emissions to air.

Control of the precursors of malodour formation could also be employed for instance by modifying manure composition (dietary change that limit excess of nutrient and thus excretion in manure) and by reducing anaerobic fermentation of manure (drying and composting manure, redesigning of the site to avoid inadvertent addition of water such as rain, overflowing of waters, using bedding-packs to maintain the bedding dry).

BAT on the storage of pig slurry in a concrete or steel tank comprises all of the following: i) a stable tank able to withstand likely mechanical, thermal and chemical influences; ii) the base and walls of the tank are impermeable and protected against corrosion; iii) the store is emptied regularly for inspection and maintenance, preferably every year; iv) double valves are used on any valved outlet from the store; and v) the slurry is stirred only just before emptying the tank for, e.g., application on land (BREF, 2003). It is BAT to cover slurry tanks using one of the following options a rigid lid, roof or tent structure, or a floating cover, such as chopped straw, natural crust, canvas, foil, peat, light expanded clay aggregate (LECA) or expanded polystyrene (EPS). A lagoon used for storing slurry is equally as viable as a slurry tank, providing it has impermeable base and walls (sufficient clay content or lined

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with plastic) in combination with leakage detection and provisions for a cover. It is BAT to cover lagoons where slurry is stored using a plastic cover, or a floating cover, such as chopped straw, LECA or natural crust.

The box below provides a summary of some of the feedback received from Member States on practices currently being applied for manure storage

Box 7 Consultation with Member States: Manure Storage

Consultation with the Member States indicated a wide range of existing practices. Majority of the Member States set out the required storage capacity for manure (ranging from 3 to 12 months). However substantial variations seem to exist with regard to geographical scope of application, i.e. whole territory versus NVZ only as well as depending on size of the farms (Sweden) or type of production (Belgium).  Austria – storage capacity for 6 months at least (whole territory);  Estonia – storage capacity for 8 months;  Denmark – storage capacity for 7-9 months (all livestock production);  Finland – storage capacity for 12 months excluding manure remaining on pasture during the same grazing period (whole territory);  Germany – storage capacity of 26 weeks (ca 6.5 months);  In Sweden, any farm with more than 10 livestock units (LU) in an NVZ must have manure storage facilities for at least 8 months (for cattle, horses, sheep and goats) or 10 months (for other animals). These requirements also apply to farms with more than 100 LU outside this area. Farms outside of NVZs must have storage facilities equivalent to 6 months manure production. Farms with less than 10 LU are obliged to have storage facilities for 6 months;  In Belgium (Flanders) required manure storage capacity depends on the type of production, i.e. it should be at least 9 months production for animals kept in stables, at least 6 months production for animals with outdoor access and at least 3 months production for farmyard manure;  The UK requires storage capacity of at least 6 months‟ worth for pig slurry and poultry manure, and 5 months‟ worth for other slurries;  Hungary, Lithuania, Portugal, Slovenia, France set out requirements on storage capacity and construction. Furthermore, some Member States impose requirements on cover and location of storage.  Finland – storage and manure gutters must be watertight (whole territory);  Hungary – technical parameters of manure storage;  Germany, Lithuania, Netherlands, Denmark (all livestock production) require mandatory cover of manure storages. In Belgium (Wallonia) the cover is required in the case of wet dung. Finland, Lithuania, Belgium (Wallonia) also set out requirements regarding location of manure storages, such as manure heaps must not be located in areas that may become flooded or in groundwater areas (Finland), manure storages must not be located closer than 25 meters to dug wells (Lithuania) and 20 meters from any water body, well or sewer in Belgium.

In general, installing a cover on the manure storage, frequent removal of manure and slurry as well as lowering the pH and NH4+ concentration of manure will contribute to the reduction of ammonia emissions to air.

As part of the discussions for the revision of the Gothenburg Protocol, a Guidance Document which contains detailed descriptions of measures that could be applied has been adopted by the Parties in the LRTAP Executive in December 2012.A draft revised Annex IX on measures for the control of emissions of ammonia from agricultural sources (ECE/EB.AIR/WG.5/2011/3) is also available. These documents set out options for the control of emissions from agriculture with three differing ambition levels: A (high), B (moderate) and C (low); see Section 3.4.1 for further details. Please note that the low level of ambition (level C) is not identical to the business as usual scenario or Option C as defined in the later chapters, although it has been considered. The key measures and reduction levels associated with each ambition level for manure storage are summarised in the table below. In particular, in relation to manure storage use of floating cover (with an associated reduction efficiency of 40%)

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constitutes low level of ambition in comparison to the use of tight lid with an expected efficiency of 80% which is classified as a high level of ambition.

Table 4.6 Summary of ambition levels included in draft Gothenburg Protocol revision guidance document for preventing and abating ammonia emissions from manure storage

Element Main requirements A (high) B (moderate) C (low)

Manure Based on one or more of following Target NH3 Target NH3 Target NH3 emission reduction of storages principles: (i) decreasing the surface emission reduction emission reduction >40%. area where emissions can take place i.e. of >80%. of >60%. Techniques – floating cover through covering of storage (ii) Techniques – tight Techniques – decreasing the time emissions can take lid plastic sheet place i.e. through frequent removal of slurry/manure (iii) decreasing the source strength of the emitting surface i.e.

through lowering the pH and NH4+ concentration.

During storage and before application, organic nitrogen is transformed into a mineralised form (ammoniacal nitrogen) which can volatilize as ammonia, or denitrified and volatilize as nitrous oxide. The rate of change mainly depend on temperature and moisture, the direction of the nitrogen conversion (i.e. net mineralisation or net immobilisation) depend of the C to N ratio, which is determined by the amount and nature of added bedding material. Thus, ammonia emissions to air can be controlled by:

 Reducing slurry pH: the decrease of slurry pH results in a higher volatile fatty acid and a reduction in ammonia emission. For each unit decrease of the pig slurry pH, the ammonia emissions decreased by 45% (Canh, Aarnink, Verstegen, & Schrama, 1998). The pH of slurry can be reduced artificially by the addition of acid. Exhaust air can also be treated. Acid scrubbers have demonstrated ammonia removal efficiencies of 70-90%, depending on their pH-set values. Scrubbers and biotrickling filters also reduce odour and particulate matter by 75% and 70%, respectively (Alterra, 2012);

 Decrease of temperature: the volatilisation rate of ammonia change from 15% up to 38% when temperature increase from 17°C to 28°C (Dourmad, Étienne, Valancogne, Dubois, van Milgen, & Noblet, 2008);

 Reducing the interface manure/air especially for slurry can be achieved by decreasing the storage surface area, covering manure, limiting turning and mixing (which is naturally done by pigs while searching into the litter) and rapid removal of urine (INRA, 2012). Weekly removal from the manure belts and transfer to covered storages reduces emissions by 50% compared with bi-weekly removal (Alterra, 2012). Nonetheless, for manure, an inefficient aeration can induce anaerobic fermentation which results in methane emissions and nitrification/denitrification and thus contributing to climate change and odour emission;

 Drying manure (specifically for poultry litter) to decrease water content and thus minimise transformation of ammonium into ammonia; and

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 Using partly slatted floors for pig: covering 50% of floor area generally emits 15% to 20% less ammonia (Alterra, 2012).

Furthermore, processing manure can be used to change manure composition and thus increasing manure efficiency and / or limit manure emissions. Manure can be processed according to the following three main actions:

 Composting of solid products: a stable, aesthetically acceptable and consistent soil amendment that is sometimes saleable can be produced by increasing the C to N ratio. Composting also reduces the volume of the original material by over 50% (Barrington, Choiniere, Trigui, & Knight, 2002);

 Anaerobic digestion: during anaerobic digestion of slurries, around 25% of organic matter is decomposed. It results in an increase of the share of ammoniacal nitrogen compared to total nitrogen (0.50 to 0.65 in cattle slurry and from 0.65 to 0.75 in pig slurry) (Martinez, Dabert, Barrington, & Burton, 2009). If the ammoniacal nitrogen is directly assimilable by the crops, it requires more attention in terms of appropriate timing and incorporation in order to avoid losses, as the ammoniacal nitrogen can volatilize; and

 Separation: a successful separation, depending on the used techniques (Hjorth, Christensen, Christensen, & Sommer, 2010), should yield a solid fraction that is rich in Phosphorus and less bulky. The N (largely ammoniacal nitrogen) to P ratio of the remaining liquid fraction matches better with the requirements of forage crops. In the case of this process, the nitrogen fertilizer replacement value (NRFV) decrease for the solid part while it increases for the liquid part. Nonetheless, as mentioned above, the liquid part requires attention to limit volatilisation of nitrogen.

Solid manure is a much more stable organic product than slurry thanks to its carbon substrate and its high C to N ratio, which permits efficient use and stabilisation of nitrogen. For crop fertilised with slurry, the emission ranges from 17 to 22 kg N / ha, while for crops fertilised with solid manure, it is between 2.2 and 3 kg N / ha. However, mineral nitrogen fertiliser must be applied in addition to manure to fulfil fertilisation needs of the crops, while slurry applications do not need such supplementation (Basset-Mens, 2005).

Another process is to recover energy from manure, e.g. through biogas production. However, while these practices generally reduce emissions to air, the risk of pollution of soils and in particular of leaching of N and P to water causing eutrophication is not reduced, and sometimes even increases. Additional processes are then required to ensure that pollution is reduced. There are practices to recover nutrients (in particular P and N) and/or energy from different techniques, for example P through inverse osmosis, or N to grow algae that can then be used for other purposes. However, these practices are often costly (Alterra 2010).

Where manure nutrients exceed crop uptake, surplus nutrient can be treated in order to remove unwanted components or separate and process themed into a useful products. Nitrogen removal is achieved via the process of nitrification (ammonia converted to nitrites and/or nitrates) followed by de-nitrification (nitrites and nitrates broken down to nitrous oxide) (Béline, Daumer, & Guiziou, 2004). With aeration, organic matter is oxidized to produce carbon dioxide and water, while with anaerobic digestion acetic acid is produced and then used by methanogens to produce methane. Manure components which cannot be eliminated, such as phosphorous and heavy metals, can only be removed by separation, concentration and exportation. Separation is achieved through screening, centrifugation and sedimentation. The final product has a solids content of 30 %, which is ideal for composting.

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Techniques are now available for increasing the dry matter content even further to produce a relatively dry friable material that can be used as bedding.

Chemicals such as lime or flocculants can also be added to precipitate some manure components. However, they have to be used in complement of other treatment. Additives for controlling odour can also be used, although the use these additives remains controversial with limited published work actually demonstrating that they are effective (Martinez, Dabert, Barrington, & Burton, 2009).

4.5.3 Best practice in manure spreading techniques

According to the draft guidance document developed as part of the Gothenburg Protocol revision, low-emission manure application is based on one or more of the following principles: (i) decreasing the surface area where emissions can take place, i.e. through band application, injection, incorporation; (ii) decreasing the time that emissions can take place, i.e. through rapid incorporation of manure into the soil or immediate irrigation; and (iii) decreasing the source strength of the emitting surface, i.e., through lowering the pH and NH4+ concentration (through dilution). These measures are primarily aimed at reducing ammonia emissions to air. Options available to decrease the source strength of the emitting surface, i.e., through lowering the pH and NH4+ concentration are discussed in the previous section and this section focuses on manure application techniques.

Choice of specific manure application technique as well as time of incorporation reduces the time of exposure to air and thus limit ammonia volatilisation. For instance, the use of drop pipes reduces the ammonia emissions by 25- 35% and direct landfill or injection can reduce emissions up to 70-90% (INRA, 2012).

The National Emission Ceilings Directive does not stipulate specific requirements regarding spreading of manure (or any other sectors/activities) and it is up to the Member States to decide how best to achieve their ceilings. The Directive did require Member States to set out specific measures in their National Programmes to ensure compliance with the 2010 emission ceilings. The box below (Box 8) summarises the key agriculture measures related to manure reported in the National Programmes submitted by Member States under the NEC Directive in 2006.

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Box 8 Review of the National Programmes under NEC Directive: application techniques

Review of the National Programmes under the NEC Directive in 2006 indicated that the majority of the Member States do not seem to be

proposing additional measures aimed to reduce NH3 emissions from agriculture over and above the existing measures and policies already in place (Latvia, Poland, Lithuania, Czech Republic, Portugal, Estonia, Sweden, Malta, France, Italy, Luxembourg, Hungary, Finland, Slovakia, Ireland, Greece, Cyprus, UK, Belgium, Austria, Spain, Slovenia). Denmark, for instance, sets out enhanced requirements in its Action Plan fro the Aquatic Environment III (2004-2014) and Action Plan for Reducing Ammonia Volatization from Agriculture (2001). For instance, from 2011 a general requirement to inject liquid manure that is applied to bare-soiled farmland and grassland has been introduced. Before 2011, liquid manure injection was suggested in particularly vulnerable nature areas and in buffer zones in the range of up to 1000 metres from the vulnerable areas. Netherlands have a compulsory low-emission application of manure to land while Ireland is implementing a programme aimed to promote the uptake of low emission application since 2005. The programme provides a 40% subsidy for low emission trailing shoe slurry spreading technology. Slovenia identified subsidizing the purchase of special equipment for application of manure and education of farmers as potential additional measure if implementation of the Operational Programme for GHG emission reducing measures would not give the expected effects.

Germany, Cyprus, Austria and Belgium are implementing measures aimed to reduce NH3 emissions including low emission manure spreading with some specifying specific technique. For instance, Austria requires the use of trailing hose, while Germany (Fertilizer Ordinance) stipulates the use of trailing hose, trailing shoe, slotted disc or other emission minimizing technique on grasslands.

According to the Nitrates Directive Member States have to develop Codes of Good Agricultural Practice and Action Programmes for the designated Nitrate Vulnerable Zones covering among other aspects procedures for the land application of manure. No specific best practice measures on manure spreading are set out in the Nitrate Directive itself and it is up to the Member States to define such practices.

The Intensive Rearing of Poultry and Pigs BREF (July 2003) sets out BAT for installations with numbers of animal places above the relevant thresholds in Annex I of the IED. In particular, the installations covered within the scope of the IED include intensive rearing of poultry or pigs: (a) with more than 40 000 places for poultry; (b) with more than 2 000 places for production pigs (over 30 kg), or (c) with more than 750 places for sows. The BREF is currently being revised and a final draft was expected to be published at some point in 2012 although this has been delayed. BAT requirements are described for on-farm treatment and landspreading with the primary aim of reducing ammonia emissions.

For pigs, the current BREF indicates that emissions of ammonia to air caused by landspreading (reference technique is broadcast spreader, not followed by fast incorporation) can be reduced through the selection of the right equipment; this is summarised in the table below.

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Table 4.7 BAT on Land-spreading Equipment

Land use BAT Emission Type of Applicability reduction manure

Grassland and land Trailing hose 30% this may be Slurry Slope (<15% for tankers; <25% for umbilical systems); with crop height (bandspreading) less if applied on not for slurry that is viscous or has a high straw below 30cm grass height content, size and shape of the field are important >10cm

Mainly grassland Trailing shoe 40 % Slurry Slope (<20% for tankers; <30% for umbilical systems); (bandspreading) not viscous slurry, size and shape of the field are important

Grassland Shallow injection 60% Slurry Slope <12%, greater limitations for soil type and (open slot) conditions, not viscous slurry

Mainly grassland, Deep injection 80% Slurry Slope <12%, greater limitations for soil type and arable land (closed slot) conditions, not viscous slurry

Arable land Bandspreading 80% Slurry Incorporation is only applicable for land that can be and incorporation easily cultivated, in other situations BAT is within 4 hours bandspreading without incorporation

Arable land Incorporation as Within 4 hours: Solid pig Only for land that can be easily cultivated soon as possible 80% manure but at least within 12 hours: 60- 12 hours 70% Source: BREF (2003). It should be noted that two Member States did not support the conclusion that bandspreading of pig slurry on arable land followed by incorporation is BAT and expressed a view that applying bandspreading on its own is a BAT. Furthermore, in their view, incorporation within 24 hours is BAT.

For poultry, the BREF (2003) concludes that for reducing ammonia emissions from land-spreading poultry manure, incorporation is the important factor not the spreading technique and does not present a conclusion on which spreading technique is BAT. It should, however, be noted that, for permanent grassland incorporation is not possible. An accurate application rate and an even spread distribution are important. BAT on land-spreading – wet or dry – solid poultry manure is incorporation within 12 hours90. Some of the Member States have developed national versions of BREF documents on intensive rearing of poultry and pigs. For instance, Cyprus has developed national BREF documents covering pig and poultry farms (as these are responsible for 94% of total ammonia emissions) while Germany evaluated 139 methods and defined BAT. Some Member States have extended the scope of the IED and BREF in terms of thresholds (e.g. Denmark requires all new or expanded or changed existing farms above 75LSU (instead of 250LSU) to comply with BAT; national framework in Germany covers small herds and extensive agriculture) while others extended the scope to cattle (e.g. Estonia requires compliance with BAT for intensive rearing of cattle, i.e. above 400 dairy cattle places).

Consultation with the Member States indicated that some countries are setting specific requirements with regard to manure application techniques. For instance, overall spreading of manure is prohibited in Denmark and band

90 However, this was contested by two Member States who considered that incorporation within 24 hours, which has an associated ammonia emission reduction of around 60 – 70 %, is BAT.

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spreading and injection are required (on grassland and bare soil – injection only). Germany stipulates the use of trailing hose, trailing shoe, slotted disc or other emission minimizing technique on grasslands. Ireland is also promoting the use of trailing shoe/ trailing hose technology. Similarly, England is providing grants for precision manure spreading equipment (such as slurry injectors and slurry band spreaders) which make significantly more efficient use of the nitrogen in manures and reduce ammonia emissions. Belgium (Flanders) set requirements to use manure injection (on cultivated and uncultivated arable land) and trailing hose on cultivated arable land. Italy is employing a different approach by setting the use efficiency of 50% for slurries and 40% minimum for solid manure. A wide range of good practices (with some regional differences) are suggested to ensure compliance, such as fast incorporation of the land spread manure, band spreading, application of slurry diluted with irrigation water (e.g. with low pressure sprinklers or drip lines), trailing hoses, shallow and deep injection, etc. Due to the costs associated with different equipment, fast incorporation is the more commonly used technique.

In Belgium, manure has to be incorporated within two hours of broadcast spreading while in Denmark incorporation of solid manure has to take place within 6 hours from field application of manure. Slovenia also identifies rapid manure incorporation as a potential further measure to reduce ammonia emissions. Germany requires immediate incorporation of manure on uncultivated land. Cyprus also requires that manure should be injected in the soil or quickly ploughed into it. Consultation with the Member States revealed substantial variation in the required incorporation time ranging from immediate in Germany up to five days in Cyprus under certain conditions. For solid manure, 24h incorporation time seems to be quite typical among Member States, while for slurry it ranges from immediate up to 12h. Sweden employs interesting approach by setting region, i.e. county specific incorporation requirements (4h vs 12h in other areas).

The Guidance Document adopted by the Parties in the LRTAP Executive in December 2012 (and draft revised Annex IX of the Gothenburg Protocol on measures for the control of emissions of ammonia to air from agricultural sources (ECE/EB.AIR/WG.5/2011/3) set out options for the control of emissions from agriculture with three differing ambition levels: A (high), B (moderate) and C (low). Please note that while the measures associated with the low level of ambition (level C) were considered when developing the Option C for this study, the low level of ambition set in the Guidance document is not identical to the business as usual scenario or Option C as defined in the later chapters. The key measures and reduction levels associated with each ambition level for manure spreading are summarised in the table below. In particular, in relation to manure application anticipated efficiency in reducing

NH3 emissions varies between 30% and 60% depending on technique and type of manure (see the table).

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Table 4.8 Summary of ambition levels included in draft Gothenburg Protocol Revision guidance document for preventing and abating ammonia emissions from manure spreading

Element Main Requirements A (high) B (moderate) C (low)

Low emission Based on one or more of following Target NH3 Target NH3 Target NH3 emission reduction of manure principles: (i) decreasing the surface emission reduction emission reduction >30% (slurry) and >30% (solid). area where emissions can take place i.e. of >60% (slurry of >30% (slurry) application Techniques – band spreading / through band application, injection, application) and and >30% (solid). dilution / management systems incorporation (ii) decreasing the time that >30% (solid Techniques – (slurry) / direct incorporation, emissions can take place i.e. through manure band spreading where feasible (solid) rapid incorporation of manure into soil or application). (slurry) / direct immediate irrigation (iii) decreasing the Techniques – incorporation, source strength of the emitting surface trailing shoe / where feasible i.e. through lowering the pH and NH + 4 injection (slurry) / (solid) concentration (through dilution). direct incorporation, where feasible (solid)

It should be noted that prompt incorporation of land spread manure may result in potential surplus and increase risk of nitrate leaching unless nutrient balance has been taken into account. The nitrous oxide (N2O) emissions are higher with injection of slurries, in particular in insufficiently-ventilated soil, compared to surface (and band) spreading of slurries (Alterra, 2012). Since these techniques increase the nitrogen available for crops through the ammonia available in the soil, it has to be taken into account in nitrogen balance to avoid surplus and limit leaching risk. Moreover, applying high rates of manure, at the same time, especially liquid manure, increases the risk of leaching (Czymmek, Geohring, Ketterings, Wright, & Eaton, 2005).

4.5.4 Best Practice in Manure Spreading Practices

Overview

In addition to possible techniques that can be used to spread the manure, the amounts of manure being spread as well as at what times of the year and where (i.e. types of land, proximity to watercourses, frozen, waterlogged etc.) has a significant impact on emissions and should be considered in the context of possible best practices. While best practices in relation to manure spreading techniques and incorporation time primarily contribute to reducing atmospheric ammonia emissions, restrictions imposed regarding location and times of spreading would mainly contribute to the reduced risk of nitrate (NO3-) leaching to water. Application of an accurate amount of manure that does not exceed crop requirements is critical to avoiding nitrate (NO3-) leaching to water. Consideration of nutrient crop needs becomes even more important when prompt incorporation of manure is employed aiming to reduce ammonia emissions as this may result in a potential surplus of nutrients available to crops.

As described in Sections 3.4.1 and 4.3.3 the Nitrates Directive (Annex II and Annex III) requires Member States to develop Codes of Good Agricultural Practices (GAP) covering various aspects including manure spreading. Compliance with the Code of GAP is voluntary outside the designated Nitrate Vulnerable Zones (NVZs). However,

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Austria, Denmark, Finland, Germany, Ireland, Lithuania, Luxembourg, Malta, the Netherlands and Slovenia have adopted a whole territory approach under the Directive.

The Intensive Rearing of Poultry and Pigs BREF (July 2003) sets out the following BAT requirements for manure application practices:

 BAT is to minimise emissions from manure to soil and groundwater by balancing the amount of manure with the foreseeable requirements of the crop (nitrogen and phosphorus, and the mineral supply to the crop from the soil and from fertilisation);

 BAT is to take into account the characteristics of the land concerned when applying manure; in particular soil conditions, soil type and slope, climatic conditions, rainfall and irrigation, land use and agricultural practices, including crop rotation systems. The risk of nutrient run-off is increase in case of application on frozen or snow covered ground, on water-saturated soil, and before precipitation (Moncrief & Bloom). Moreover, the application of manure near surface water bodies have to be done carefully since the risk of run-off is high (Czymmek, Geohring, Ketterings, Wright, & Eaton, 2005). BAT is to reduce pollution of water by doing in particular all of the following:

- Not applying manure to land when the field is: water-saturated, flooded, frozen, snow covered;

- Not applying manure to steeply sloping fields;

- Not applying manure adjacent to any watercourse (leaving an untreated strip of land), and

- Spreading the manure as close as possible before maximum crop growth and nutrient uptake occur.

 BAT is managing the landspreading of manure to reduce odour nuisance where neighbours are likely to be affected, by doing in particular all of the following:

- Spreading during the day when people are less likely to be at home and avoiding weekends and public holidays, and

- Paying attention to wind direction in relation to neighbouring houses.

The Gothenburg Protocol (at Annex IX) require Member States to issue codes of good agricultural practice which are designed to prevent pollution of air. The Gothenburg Protocol states at Section 3 of Annex IX:

“Within one year from the date of entry into force of the present Protocol for it, a Party shall establish, publish and disseminate an advisory code of good agricultural practice to control ammonia emissions. The code shall take into account the specific conditions within the territory of the Party and shall include provisions on:

 Nitrogen management, taking account of the whole nitrogen cycle;

 Livestock feeding strategies;

 Low-emission manure spreading techniques;

 Low-emission manure storage systems;

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 Low-emission animal housing systems; and

 Possibilities for limiting ammonia emissions from the use of mineral fertilizers.”

How Much to Spread

First of all requirements could be set regarding manure application quantities; associated thresholds could be absolute or variable:

 Absolute thresholds: specific values that should not be exceeded; and

 Variable thresholds: a requirement to not exceed plant requirements.

Both these types of targets/thresholds have been embodied in legislation and aim mainly at reducing nitrate (NO3-) leaching to soil and water.

The thresholds will need to take into account soil composition; Soil Nutrient Supply (SNS) is a specific soil factor which will influence manure application rate. SNS reflects what is already available in the soil and so can be deducted from what needs to be applied. For instance, clay soils will tend to be more fertile than sandy ones. Furthermore, SNS is strongly affected by previous cropping. A crop of beansor peas leaves high levels of residual N. Finally, soil‟s droughtiness is another important factor; sandy soils are more prone to drought than clay soils, and so soil moisture deficits tend to be higher on sands and applied nutrients may be unable to go into solution for plant uptake.

Using appropriate tillage techniques could increase soil aeration and the soil draining function. Thus, it limits nitrification, which results in creating nitrate (NO3-) molecules, and denitrification, which results in emitting nitrous oxide molecules. The impact of tillage is particularly observed in the case of clay soil which can reduce

N2O emissions significantly. However increasing soil aeration increases ammonia emissions. If the soil is already well-ventilated, direct seeding can be used: it increases the carbon content of soil by incorporating crop residues and contributes to nitrogen immobilisation.

It should be noted that due to the lack of uniformity in the nature of manures and its chemical composition it is not feasible to describe target or threshold application rates in terms of tonnes per hectare. Rather, targets and thresholds are usually quoted in terms of the quantity of specific nutrients (for example, under the Nitrates Directive, the unit is kg N/ha). First of all, manure is not a homogenous or standardised material. It can vary in dry matter content, most notably (and by definition) between manures and slurries. The data from Menzi (2002) suggests that slurries are typically in the range of 5 – 17% dry matter, whereas solid manures are typically between 20 and 45%. Further, at a MS level, the average dry matter content of manures differs. The second important variable is the chemical composition of the material will vary, particularly in relation to the livestock that produced it. It is also pertinent to note that composition will vary with diet, and so can vary within and between seasons, and also with the amount and type (e.g. wood chipping, sand, straw) of bedding used.

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In the case of an absolute threshold, it is specified as an absolute value, e.g. the limit placed on applications of animal manures in terms of kgN/ha set in Annex III of the Nitrates Directive that limits the amount of livestock applied to the land each year, including by the animals themselves, to 170 kg N.

In the case of setting relative application thresholds, the key underpinning principle is that nutrients should not be applied in excess of the plants‟ requirements, given the specific crop circumstances. In this way, it is to be expected that all nutrients would be taken up by the crop and so not be available to pollute.

This type of threshold is used in the Nitrates Directive (Annex III) that sets out the need to take into account the characteristics of the areas concerned, including soil conditions, soil type and slope, climatic conditions, rainfall and irrigation, land use and agricultural practices, including crop rotation systems when setting application thresholds. The threshold should be based on a balance between the estimated nitrogen requirements of the crops and the nitrogen supply to the crops from the soil and from fertilization. The factors affecting the amount of nitrogen present in the soil at the moment when the crop starts to use it to a significant degree include outstanding nitrogen amounts at the end of winter, the supply of nitrogen through the net mineralization of the reserves of organic nitrogen in the soil, additions of nitrogen compounds from livestock manure and additions of nitrogen compounds from chemical and other fertilizers.

The draft revised BREF for Pigs and Poultry (March 2012), at Section 4.13.1, stresses the importance of balancing nutrients applied with the ability of soil and crops to take them up, and so avoid them becoming pollutants. It identifies two generic „tools‟ for converting this principle into actions:

 A soil nutrient balance; and

 A rating system (appears to involve calculating stocking rates) and quotes the UK‟s „Tried and Tested‟ and MANNER mechanisms as examples of good practice.

This can be a difficult assessment to make, significant effort is likely to be required for developing suitable aids to farmers and their advisers. For example, in the UK, Defra produces the Fertiliser Manual91 – so-called “RB209”. This lengthy document provides a detailed description of the process of deciding what level of nutrients to apply to crops (including grass) in every conceivable set of circumstances. It also addresses the point about „economic optimum‟ rates as well as „agronomic optimum‟ (i.e. if fertiliser prices decline, a higher application rate may be justified – to a point). To further assist farmers and their advisers, computer software is available to work out optimum application rates. Examples include MANNER-NPK (see: http://www.planet4farmers.co.uk/Manner). Other UK examples include “Tried and Tested” (see: http://www.nutrientmanagement.org/) and PLANET (http://www.planet4farmers.co.uk/).

An essential component of decision-making is the testing of soil to determine nutrient status. The British Survey of Fertiliser Practice92 provides some useful data which allows some insights to be gained as to what happens in

91 Defra (2011). The Fertiliser Manual. Eighth edition. See: http://www.defra.gov.uk/publications/files/rb209-fertiliser-manual- 110412.pdf (Visited 19-02-13)

92 GfK Kynetic (2012) British Survey of Fertiliser Practice. See: http://www.defra.gov.uk/statistics/files/defra-stats-foodfarm- environ-fertiliserpractice-2011-120425.pdf (Visited 20-02-13)

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practice. Although no specific questions were asked of farmers‟ attempts to adjust applications of mineral/artificial fertiliser to allow for applications of organic manures, it has data on fields with and without manures. This shows that:

 For all major tillage crops, overall rate of nitrogen from mineral fertiliser was consistently higher on fields which have not received organic manures (implying that an adjustment had been made); and

 For all grassland, levels of N, P and K applied as mineral fertiliser are all lower on fields where organic manure has not been applied, the effect being most pronounced on silage ground.

Superficially, this suggests that no adjustment is made by grassland managers. However, it needs to be noted that there is great variability in grassland systems, some being very low output and some very high output. So, for example, a heavily stocked dairy farm will need to apply much higher levels of nutrient to meet the crop‟s needs than a lightly-stocked beef and sheep unit.

A further point of interest from the survey is the frequency of use of computer programs for record keeping (and – by inference – on manure management). The survey indicates the majority of farmers do not make use of the software packages available to help them with nutrient management. The use rate varies between 8% to 31% depending on type of fertiliser (mineral or organic) and type of farms (dairy, cereals etc.)

The adopted Gothenburg Protocol Guidance Document also adopts the principle of matching nutrients applied to crop needs, taking into account nutrients available in the soil (see Section III). The strategies advised include implementation of nitrogen management at farm level is an effective strategy to increase nitrogen use efficiency and to decrease nitrogen losses. The process involves an iterative set of annual activities including i) analysis of nitrogen demands of crops and animals, availability of nitrogen, storage conditions and possible leakages and of available techniques for using nitrogen efficiently; ii) decision making including development and assessment of alternative management options from agronomic and environmental point of view; iii) planning including development of plan, iv) execution of the nitrogen management plan in practice, followed by v) monitoring and vi) evaluation in terms of nitrogen surplus and nitrogen use efficiency.

Assessment of the absolute thresholds set by the Member States indicates that the majority of the countries seem to set the limit of 170kgN/ha (e.g. Bulgaria, Latvia, Lithuania, Portugal). Ireland allows for 250 kgN/ha limit if the farm is availing itself of and complying with a derogation provided by legislation.

To ensure a balanced application of nutrients, some Member State require development of fertiliser plans, for example (non-exhaustive):

 Estonia and Lithuania require farmers to record all the use of fertilisers on the field-level in their field book;

 Latvia requires a fertiliser plan for the year and field history must be tracked and documented for certain farms above a certain area threshold, and records kept for at least three years;

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 Germany requires annual nutrient input/output budgets to be drawn up at farm level for nitrogen and phosphorus. Nutrient inputs are compared to nutrients removed from the system. The difference (nutrient balance) must be established per plot or area. The following data must be recorded: (1) Soil nitrogen content and method of determination, (2) Soil analysis results for phosphorus, (3) Total nitrogen and total phosphorus contents of fertilisers and method of de-termination; also the ammonium-N content in the case of slurry, liquid manure, other liquid organic or fertilisers and poultry manure, (4) Baseline data and results of input/output budgets;

 Portugal, Romania, Scotland (UK) require certain records to be kept with regards to fertiliser use.

When to Spread

Time of manure spreading could also have a direct impact on the extent of pollution and can be considered in two ways:

 Closed periods; and

 Short-term criteria.

The idea of a closed period is a logical consequence of the previous discussion about relative thresholds being based on crop requirements. During the winter, crops are dormant and so their needs are effectively nil. Therefore any nutrient applied during the dormancy period is available to pollute. Limitations set regarding the timing of manure application including closed periods and short-term restrictions are aimed at reducing nitrate (NO3-) leaching to soil and water.

The Nitrates Directive (at Annex III) requires Member States to introduce measures that include “periods when the land application of certain types of fertilizer is prohibited”. In England, closed periods vary with certain circumstances as follows (see table below).

Table 4.9 Closed Periods in England

Grassland Tillage Land

Sandy or shallow soil 1 September to 31 December 1 August to 31 December*

All other soils 15 October to 15 January 1 October to 15 January

Manufactured fertiliser 15 September to 15 January 1 September to 15 January

*If crop sown before 15 Sept - applications permitted 1 Aug → 15 Sep

A necessity of the „closed period‟ requirement is one that ensures sufficient storage is available on every farm so that enforced spreading is avoided, except in extreme circumstances.

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In Finland, Government Decree No. 931/2000 of 9 November 2000 on the restriction of discharge of nitrates from agriculture into waters specifies periods during which manure spreading is authorised. Malta prohibits application of livestock manure during the rainy season 15 October – 15 March, while Germany is operating a ban of spreading between 1 November to 31 January on farmed land, and from 15 November to 31 January on grassland. In Austria Periods manure spreading is banned on grassland from 30 November to 28 February and on other lands from 15 October to 15 February. In Belgium (Flanders) different closed periods are set for different types of land use (e.g. grassland versus arable land) and different types of soils (e.g. heavy clay soil).

In addition, short-term manure application restrictions could be considered and imposed. The Nitrates Directive (at Article 5 (4)(a)) require Member States to issue codes of good agricultural practice which are designed to prevent pollution of water.

The Nitrate Directive states, at Annex II:

“A. A code or codes of good agricultural practice with the objective of reducing pollution by nitrates and taking account of conditions in the different regions of the Community should certain [sic] provisions covering the following items, in so far as they are relevant:

1. periods when the land application of fertilizer is inappropriate; 2. …” These requirements have been transposed into UK legislation in the form of a Code of Good Agricultural Practice. The latest Defra code gives guidance on the timing of manure and dirty water applications (see Box below).

Box 9 Good practice on timing of manure and dirty water applications

“Timing of applications 384. You should apply livestock manures when grass and crops can make efficient use of nitrogen. Spring applications on all soil types make best use of nitrogen in the manures (see Section 2). 385. You should not apply livestock manures and dirty water when:  The soil is waterlogged; or  The soil is frozen hard; or  The field is snow covered; or  The soil is cracked down to field drains or backfill; or  The field has been pipe or mole drained or subsoiled over drains in the last 12 months; or  Heavy rain is forecast within the next 48 hours. 386. Use a weather forecast to help choose suitable conditions for spreading. The best conditions are where air mixes to a great height above the ground, which are typically sunny, windy days, followed by cloudy, windy nights. These conditions cause odours to be diluted quickly. Check wind direction in relation to nearby housing before spreading. 387. Avoid spreading at weekends, bank holidays, or in the evening unless it is solid manure that has been well composted, or slurry that is to be band spread, or injected or has been treated to reduce odour.”

Source: Defra (2009). Protecting our Water, Soil and Air - A Code of Good Agricultural Practice for farmers, growers and land managers. (see: http://www.defra.gov.uk/publications/files/pb13558-cogap-090202.pdf visited 19-02-13)

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Finland applies restrictions to animal manure spreading on snow-covered, frozen or water-saturated ground (Government Decree No. 931/2000 of 9 November 2000). In 2004, Malta adopted the Code of Good Agricultural Practice (CoGAP) that prohibits application of manure to saturated soils and to soils in flood-prone areas. The Code of Good Agricultural Practice in Portugal (Article 6 of Decree-Law No. 235/97) includes restrictions on application of fertilisers on saturated, flooded, frozen or snow-covered land.

Effectively short-term restrictions for application are related to farmers being able to adjust to weather and soil conditions (heavy rain, frost, snow cover etc.) in order to minimise nitrate (NO3-) leaching primarily and to be considerate with respect to potential impact on neighbouring properties, i.e. reducing odour.

It is also pertinent to note that the Guidance Document associated with Annex IX of the Gothenburg Protocol highlights (at Para 213) that “Fertilizer applications under cooler conditions and prior to rainfall (although bearing in mind the need to avoid the associated risk of run-off to water bodies) are associated with lower ammonia emissions.” Furthermore, at para 217, it highlights that: “Fertilizing grassland within the first few days after cutting provides surplus N resulting in a larger emission from the combined effects of cutting and fertilization. Delaying N fertilizer application following cutting allows the grass to recover thereby reducing NH3 emissions.” However, these measures are not enforced through any regulations.

Where to Spread

At present the regulatory route used to determine where manure is spread is via codes of practice, as required by the Nitrates Directive and other protocols. The requirements set are primarily aimed at reducing nitrate leaching and resulting soil and water pollution.

In the UK these have been transposed into the legislation in the form of a Code of Good Agricultural Practice. The latest Defra code gives guidance on the timing of manure and dirty water applications (see Box below).

Box 10 Good Practice on the Restriction over where to apply Manure and Dirty Water

“Restrictions on certain areas 389. You should not apply livestock manures and dirty water:  Within 10 metres of any ditch, pond or surface water; or  Within 50 metres of any spring, well, borehole or reservoir that supplies water for human consumption or for farm dairies; or  On very steep slopes where run-off is a high risk throughout the year; or  On any areas where you are not allowed to because of specific management agreements. 390. You should only broadcast slurry and solid manures to bare land or stubble if soil conditions are suitable for incorporation within a few hours (see paragraphs 398 to 400). 391. Avoid spreading solid manure, slurry or dirty water in fields close to and upwind of houses. 392. If there is an outbreak of a notifiable disease, you must comply with any conditions for livestock manures set by the Secretary of State. 393. Some veterinary products contain highly polluting compounds, and manures from treated livestock should only be applied to land according to advice from the Environment Agency. You must follow any instructions provided with the products.”

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With reference to the last bullet point of Paragraph 389 (see Box 4 above), examples of such agreements are:

 Agri-environment scheme options (which require no fertilisers to be applied);

 Management agreements on designated sites such as SSSIs, SPAs and SACs (spreading manure on a SSSI may be regarded as a „Potentially Damaging Operation‟ in some circumstances); and

 Groundwater protection schemes.

The Austrian Nitrate Action Programme requires buffer zones to water bodies (5 m in general) to be set where it is not allowed to spread fertilizer (also manure) as well as set out specific application regulations on steep slopes (more than 10%). Buffer zones (10m) along watercourses and lakes as well as local housings are being applied in Denmark.

Finland applies restrictions to animal manure spreading on buffer zones between the field and watercourses (Government Decree No. 931/2000 of 9 November 2000). Malta also imposes restrictions on application of manure to steeply sloping land and sets minimum distances from watercourses and shoreline. Portugal sets restrictions on application of manure on steeply sloping land and near watercourses (Code of Good Agricultural Practice).

Germany sets minimum distance of 3 metres to water courses (or 1 metre if a precision fertiliser spreader is used) in its Code of GAP. There must be no direct input and no runoff of nutrients into the watercourse or waterbody. Terrain and soil conditions must be given adequate consideration. Additional water-rights-related distance and management regulations must be observed. Furthermore a minimum distance of 3 metres with no exceptions applies to steeply sloping arable land (ground which has an incline of 10% or more within the first 20 metres from the top of the bank).

In Sweden, manure may not be spread on agricultural land closer than 2 metres from an edge adjacent to a watercourse or a lake. Manure may not be spread on agricultural land adjacent to a watercourse or a lake where the slope exceeds 10%.

4.6 Summary

Overall Framework for Control

Article 73(2)(c) does not limit the scope of the review to any specific mechanism so any of a number of ways in which emissions from manure spreading could be managed may be considered. Section 4.3 describes the various approaches available for the development of policy options and identifies the particular advantages and disadvantages presented with regard to managing emissions from manure spreading.

For the short term: Based on this review, it appears that, in the short term, the current revision of the NEC Directive (Option 2.3) offers the most feasible route for promoting a broader uptake at EU level of measures targeted at reducing emissions to air from manure storage and spreading. This could be via the inclusion of implementing measures alongside a revised emission ceiling for ammonia. Other short term options may include

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measures under Pillar II of CAP although this requires MS to prioritize these measures in the process of developing Rural Development Programmes for the time period 2014-2020 (Option 3.2).

For the long term: A possible longer term option could be the revision of the IED or the BAT reference documents developed under it to target manure spreading more actively than at present (Option 2.1). However, the recent IED Article 73 review report concluded that the Commission does not intend to include cattle farms within the scope of the Directive or amend any other elements of the Directive in relation to intensive livestock farms as the inclusion of cattle would deliver somewhat limited environmental benefits while potentially imposing significant administrative and compliance costs to a large number of farms. The report did recognise the significance of emissions from manure spreading but indicated that the IED itself is not the most appropriate instrument. Therefore other longer term options could include the revision of the Nitrates Directive to require more specific measures within NVZs (Option 2.2) or new legislation targeted specifically at manure storage and spreading (Option 4.1) or the development of an integrated nitrogen management directive (Option 4.2). The latter options may provide a good way of targeting both emissions to air and water in an integrated way. Inclusion of the best practice manure spreading measures under the CAP Pillar I cross-compliance requirements (Option 3.1) could also be feasible in the long-term, i.e. post 2020.

Voluntary approaches (Option 1) could be a possibility and have been applied already in some MSs but these don‟t offer certainty in delivering emission reductions as uptake is highly uncertain.

Scope of Coverage

The scope of coverage of a particular option could be defined in two main ways: geographical and/or numerical. Both are discussed in Section 4.4. A geographical approach is most compatible with any new or revised regulations targeted at reducing water pollution in line with the current NVZ approach under the Nitrates Directive. Numerical thresholds are most appropriate overall as they take into account the overall impact that a farm has on the environment, certain measures are considerably less cost effective when applied at smaller farms and any administrative burdens are likely to affect smaller farms most. As the analysis of numbers of farms and animals that could be affected by any new regulation presented in Section 5.3.1 shows, there are a significant number of farms in the EU with a small number of animals.

Definition of Best Practice

The potential options for best practice in relation to manure storage, spreading techniques and practices include:

 Storage requirements setting out the need to design manure storage facilities with sufficient capacity until further treatment or application to land can be carried out. The required capacity depends on the climate and the periods in which application to land is not possible. For pig manure, for example, the capacity can differ from the manure that is produced on a farm over a 4 – 5 month period in Mediterranean climate, a 7 – 8 month period in the Atlantic or continental conditions, to a 9 – 12 month period in boreal areas. Specific requirements setting out the need to cover the manure/ slurry storage;

 Manure application methods;

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 Conditions on maximum permissible timings for incorporation of manures/slurries within the soil (e.g. 6, 12 or 24 hours, depending on manure type);

 Restrictions related to timing of spreading (short-term restrictions such as not applying to frozen or waterlogged ground, during adverse weather conditions, e.g. heavy rain, strong winds etc. and closed periods);

 Restrictions related to location of spreading (spreading not to occur within a specified distance from boreholes, streams, waterbodies, within SSSI if potentially damaging, etc.);

 A condition that application of nutrients (whether organic or manufactured) should be balanced with the needs of the crop and available nutrients in the soil. Associated requirement to prepare plant nutrient balances and to keep records of calculations and decisions made. Ensuring that overall fertilizer inputs are fine-tuned to match the amount of nitrogen saved should allow farmers to also save time and costs by reducing other fertilizer inputs, as reduced nitrogen losses translates to a larger fraction of nitrogen inputs being available to reach the agricultural crops; and

 Conditions related to applicability to spreading by a third party (e.g. a contractor acting for the installation manager or another farmer benefiting from receipt of manure for use on his own land).

Specific quantitative and qualitative best practice options associated with manure storage, spreading techniques and practices corresponding to high (Option A), medium (Option B) and low (Option C) level of ambitions are

summarised in the table below. These are primarily targeted at reducing NH3 emissions to both air and water but will also have knock on effects (both positive and negative) for other environmental impacts. These are considered in Section 5.3.6. It should be noted that for some elements, e.g. requirements of the Nitrate Directive, Option C corresponds to the baseline and no additional costs or environmental benefits are anticipated. Such instances are clearly identified in the following section. Other elements set out under ambition level Option C correspond to requirements over and above the baseline, e.g. requirements regarding manure storage and manure spreading techniques. Therefore, while some of the elements under the Option C correspond to the baseline, the option as a whole includes a range of additional requirements that are considered in the analysis in Section 5.

Table 4.10 Summary of Ambition Levels Associated with Best Practices

Element Primary Impact A (high) B (moderate) C (low)

Manure Water (to avoid Sufficient storage capacity Sufficient storage capacity in Sufficient storage capacity in storages: nitrate leaching) across whole of the country NVZ and above certain threshold NVZ capacity outside NVZ (100AU)

Manure Air (reduced NH3 Target NH3 emission reduction of Target NH3 emission reduction of Target NH3 emission reduction of storages: emissions) >80% >60% >40% cover Techniques – tight lid Techniques – plastic sheet Techniques – floating cover

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Element Primary Impact A (high) B (moderate) C (low)

Manure Air (reduced NH3 Target NH3 emission reduction of Target NH3 emission reduction of Target NH3 emission reduction of spreading emissions) >60% (slurry application) and >30% (slurry) and >30% (solid). >30% (slurry) and >30% (solid). technique and >30% (solid manure application). Techniques: Techniques: incorporation Techniques: Slurry: band spreading (trailing Slurry: band spreading (trailing Slurry: injection (grassland, hose or trailing shoe) hose or trailing shoe) arable))/ band spreading with (grassland)/ with incorporation (grassland)/ dilution / incorporation within 2h (arable) within 4h (arable) management systems with incorporation within 12h Solid: direct incorporation (within Solid: direct incorporation (within 4h) , where feasible (applicable 12h), where feasible (applicable Solid: direct incorporation (within on arable land only) on arable land only) 24h), where feasible (applicable on arable land only

Quantity Water (to reduce 170kg N/ha (manure) including 170kg N/ha (manure) including 170kg N/ha (manure) including thresholds nitrate leaching) potential grassland derogation potential grassland derogation potential grassland derogation (absolute) up to 250 kg/ha where applicable up to 250 kg/ha where applicable up to 250 kg/ha where applicable Scope: whole territory Scope: NVZ +voluntary with Scope: NVZ +voluntary active support

Quantity Water (to reduce Application based on crop Application based on crop thresholds nitrate leaching) and nutrient needs nutrient needs (variable) indirectly air (reduced Scope: NVZ + voluntary with Scope: NVZ + voluntary NH3 emissions) support

Timing of Water (to reduce Set closed periods Set closed periods Set closed periods application nitrate leaching) No application on water- No application on water- No application on water- saturated, flooded, frozen or saturated, flooded, frozen or saturated, flooded, frozen or snow-covered ground snow-covered ground snow-covered ground Scope: whole territory Scope: NVZ+ voluntary with Scope: NVZ + voluntary active support

Areas of Water (to reduce No application on a steeply No application on a steeply No application on a steeply application nitrate leaching) sloping ground sloping ground sloping ground No application near water No application near water No application near water courses courses courses Scope: whole territory Scope: NVZ+ voluntary with Scope: NVZ + voluntary active support

Fertiliser Water (to reduce Establishment of fertiliser plans Establishment of fertiliser plans plans nitrate leaching) and on a farm-by-farm basis and the on a farm-by-farm basis and the air (reduced NH3 keeping of records on fertilizer keeping of records on fertilizer emissions) use use Scope: NVZ+ voluntary with Scope: NVZ +voluntary active support

Farm Water (to reduce Use of crop rotation systems Use of crop rotation systems management nitrate leaching) Set proportion of the land area Set proportion of the land area devoted to permanent crops devoted to permanent crops relative to annual tillage crops relative to annual tillage crops Maintain minimum vegetation Maintain minimum vegetation cover during (rainy) periods cover during (rainy) periods Scope: NVZ + voluntary with Scope: NVZ + voluntary support

Building on the consultation undertaken for the study, we have attempted to summarise where some Member States are already applying the best practices described above; this is presented in the table below. It should be noted that this is based on a review of consultation responses and should not be considered comprehensive as such, not least

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because some Member States did not respond to the consultation and/or only provided limited information. Furthermore, whilst there may be some requirements set in the legislation in many cases Member States apply various size thresholds and furthermore this does not necessarily mean that specific techniques/practices are applied uniformly. Where possible, this information has been taken into account in the analysis described in the following section.

Table 4.11 Summary of current uptake of best practices by Member State based on consultation responses*

Element A (high) B (moderate) C (low)

Manure Austria, Finland, Lithuania, Ireland, Sweden (10 LSU in NVZ, 100 LSU Baseline requirement for all Member storages: Slovenia, Denmark, Germany, Belgium outside) States capacity (Flanders)

Manure Austria, Lithuania, Netherlands, Denmark (whole territory, mandatory cover but no details provided on the type of cover). Belgium storages: cover (Wallonia) (NVZ)

Manure Netherlands (whole territory, immediate Austria (whole territory) Estonia (spreading techniques set out in spreading incorporation on some types of land) Ireland (TS/TH/injection techniques CGAP) technique and Denmark (whole territory, injection only encouraged through grants; upward Lithuania (spreading techniques set out in incorporation for some type of land use; overall facing splashing banned) (whole territory) CGAP; spraying techniques prohibited spreading banned) Belgium (Flanders) from 2014; incorporation times) Sweden UK (grants to support low emission Latvia (incorporation times) techniques; incorporation times set) Portugal (CGAP sets conditions on spreading techniques and incorporation Germany (whole territory, immediate incorporation on some types of land) time) Slovenia (low emission techniques recommended but not generally applied; whole territory) Italy (requirements on nitrogen efficiency, more stringent in NVZ and to achieve these low emission techniques are recommended: injection, TS/TH, dilution with irrigation water) Spain (different requirements in different regions) France (depending on size of farms) Belgium (Wallonia)

Quantity Estonia, Denmark (140kg/ha for non- EU 27 countries excluding the countries Latvia, Hungary, Greece (different units, thresholds cattle farms), Germany(specific listed under Ambition level A mg/acre), Portugal, UK, Spain, France, (absolute) requirements on different types of land), Belgium (Wallonia) Belgium (Flanders) Austria, Lithuania, Ireland (with derogations of 250kg/ha in some cases), Slovenia, Netherlands (with derogations of 250kg/ha in some cases), Italy (with derogations of 250kg/ha in some cases), Sweden

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Element A (high) B (moderate) C (low)

Quantity Austria, Finland, Slovenia and Estonia, Latvia, Greece (only treated thresholds Netherlands, Germany (whole territory) manure is permitted), Portugal, Sweden, (variable) Spain, France, UK Lithuania (fertilisation plans mandatory for spreading areas above 50ha) Denmark (nitrogen standards 10% below economic optimum; mandatory fertilization plans)

Timing of Austria, Finland, Lithuania, Ireland, Sweden Baseline requirement for all Member application Slovenia, Denmark, Germany, Belgium States (Flanders)

Areas of Austria, Finland, Slovenia, Denmark, Greece, Portugal (including restrictions Baseline requirement for all Member application Belgium (Flanders), Lithuania, Ireland, on proximity to drinking water States Germany (also restrictions on proximity to abstraction), Italy (including distances to drinking water abstraction) roads and buildings), Sweden, Spain (including restrictions on proximity to drinking water abstraction in some regions)

Fertiliser plans Austria (whole territory) Latvia (including proof that manure is Estonia (farms over 300 LU must get an passed on to other holdings or used in another way when density exceeds approval from Environmental Board) 170kg/ha) Finland (national BAT document on cattle) Hungary (permission required for spreading slurry on arable land) Lithuania (including analysis) Greece (the establishment of any animal Portugal (in certain circumstances, farm requires an impact analysis of all livestock manure is subject to farm emissions and a special license for authorization, and registration of its use) the handling and spreading of animal Netherlands (registration of manure manure) production) Italy (non-IED farms above specified Germany (whole territory; authorisation of thresholds to apply for general new stables is subject to standards, e.g. authorisation) proof of sufficient land for manure UK spreading; filter for ammonia, dust and odour in closed stables; coverage of the France manure storage)

Farm Lithuania (50% of area sown with Use of crop rotation systems management wintering plants in farms with more than Latvia (50% of agricultural land to be 15ha of arable land) occupied with grassland, winter cereals Ireland (whole territory; periods when and rape, vegetables, stubble and fodder green cover is required) crops during autumn and winter) Denmark (winter plant cover required, Italy (to achieve efficiency at derogated mandatory demands for late crops (grass, farms, i.e.250 kg/ha, 70% or more of the beets, catch crops). Local action plans acreage of the farm shall be cultivated foresee additional 140.000 ha late crops with crops with high nitrogen demand and and more wetlands. Restrictions in soil long growing season (eg. silage mais, management in the autumn double crop, etc.) Sweden (depending on county, 50-60% of arable land shall be under vegetative cover during the autumn and winter) France (soil cover in autumn) Note: * information presented on Member States is based on consultation responses and may not be comprehensive in some instances.

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5. Data Analysis

5.1 Overview

The aim of this task was to undertake an assessment of the main relevant environmental, economic and social impacts of the options and practices described in the previous section in line with the Commission‟s Impact Assessment (IA) Guidelines and associated guidance and toolkits.

The following impacts have been considered:

 Number of holdings and animals that could be affected;

 Potential impacts on emissions of ammonia and other pollutants (including methane and N2O emissions), as well as the implications on nitrate (NO3-) losses to waters and on biodiversity;

 Compliance (costs of measures, actions) and administrative costs – we have considered costs associated with measures primarily targeted at reducing NH3 emissions to air and nitrate (NO3-) leaching to water separately recognising that possible policy options may only target one of these areas rather than both;

 Monetised benefits associated with NH3 emission reductions to air (where possible);

 Wider environmental impacts;

 Wider socio-economic impacts.

5.2 Approach to Assessing Impacts

5.2.1 Potential Numbers of Holdings/ Animals Affected

As described in Section 3.2 there are a significant number of pig, poultry and cattle holdings in the EU (over 12 million in total based on available Eurostat data). However, the majority of these are very small and benefits of their inclusion in any new or revised legislation would be minimal (and potentially at a high cost). Therefore, we have undertaken a review of the Eurostat data available for each animal species focussed on the numbers of holdings and animal heads broken down by farm size for the EU as a whole. This provides a useful proxy for the volumes of manure that could be targeted in any new or revised policy. This is described below in Section 5.3.1.

It should be noted that this doesn‟t take into account those holdings that may already be captured by national legislation but is intended to provide a useful summary of where appropriate thresholds could be set if a policy were to be introduced at an EU level.

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5.2.2 Compliance Costs

As described above, we have considered the costs of compliance with possible best practices separately for those measures targeted primarily at reducing emissions to air (manure storage and spreading techniques) and those

targeted primarily at reducing nitrate (NO3-) leaching to water (manure management practices). Our approaches for each are described below.

Costs associated with Best Practice Techniques for Manure Storage and Spreading (primarily for reducing NH3 emissions to air)

The costs associated with best practice for manure storage and spreading have been considered in two ways.

Firstly, a comparison of the cost-effectiveness of different abatement measures targeted at the agriculture sector has been undertaken based on a range of sources. Secondly, we have taken the reference scenario developed by IIASA for the TSAP review for the EU28 using the GAINS model and modelled separately (through manipulation of the modelling of the reference scenario) the potential additional costs and emission reductions of applying the maximum uptake rate (i.e. difference relative to BAU uptake in the reference scenario) for the following measures in the model:

 Covered manure storage: GAINS has two measures for storage relating to low (e.g. floating foils or polystyrene) and high (e.g. concrete, corrugated iron or polyester caps) efficiency systems. These broadly correlate to our proposed best practice ambition levels C and A, respectively. GAINS assumes abatement efficiencies of 40% (low efficiency) and 80% (high efficiency) for NH3.

 Low ammonia application: GAINS has two measures for manure spreading relating to low (e.g. slit injection, trailing shoe, slurry dilution, band spreading for liquid slurry and incorporation of solid manure the day after application) and high (e.g. immediate incorporation within 4 hours of application, deep and shallow injection of liquid manure and immediate incorporation within 12 hours of application for solid manure) efficiency systems. These broadly correlate to our proposed best practice ambition levels C/B and B/A, respectively (they include measures that have been defined in more than one best practice ambition level in Table 4.10). GAINS assumes abatement efficiencies of 30-40% (low efficiency) and 80% (high efficiency) for NH3.

The maximum uptake rates applied are those currently used within the GAINS model and are specific for each MS, animal and manure type and technique. They are based on the following assumptions (further details are provided in Winiwarter et al (2011)):

 Farms with less than 15 LSU have been excluded as it is considered unlikely that these smaller farms would implement such measures for practical and cost reasons93.

 Assumptions regarding climatic, topographical and geological conditions in each MS;

93 When converted using Eurostat LSU conversion factors for each animal type, 15 LSU is roughly equivalent to 15-20 heads for cattle (varies between dairy and others), 30-50 heads for pigs (varies between sows and others) or 1,000-2,000 heads for poultry (varies between broilers and laying hens). These are therefore lower than the thresholds assumed in the modelling of measures focussed primarily at reducing emissions to water.

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 Technical limitations of each technique.

All cost and emissions data is based directly on that applied in the GAINS model and the results are presented in terms of additional costs and emission reductions relative to the reference scenario in 2025. This means that uptake of measures expected under current legislation (both EU and MS level) is already taken into account so as to avoid overestimating potential for further reductions.

It should be noted that we present the results separately for maximum uptake of all four measures as it is not possible to simply combine the results for each as in some cases the measures may be mutually exclusive (e.g. you could not have maximum uptake of both low and high efficiency options) and applying measures for storage can impact on emissions from application (due to an increase in available nitrogen in the manure). It was not within the scope of this study to develop a more complex model to take into account these interactions to avoid overlaps with the GAINS modelling. The approach taken provides an indication of the maximum additional costs and emission reductions that could be realised.

Furthermore, GAINS models a number of combinations of different measures targeted at different phases of livestock rearing i.e. feeding, housing, storage and application. These have not been considered in the analysis.

Costs Associated with Manure Spreading Best Practices (primarily for reducing nitrate leaching to water)

Best practice in relation to manure spreading practices would result in additional compliance costs to farmers.

Overall the costs associated with compliance with best practice requirements on manure application practices are likely to include the following elements:

 Manpower costs associated with time and effort required for farmers, for instance to develop manure management plans; and

 Costs of soil and manure testing.

Limitations imposed may result in the need for, and additional costs associated with, extra manure storage. Limitations to manure application could also result in farmers choosing to transport manure to other fields (incurring transportation costs) or to choose alternative manure treatment techniques (or disposal in other ways – such as poultry manure for incineration). The table below presents potential implications to farmers as a result of defining best practice on spreading practices and some of the assumptions applied in the analysis. Where time estimates have been developed we have applied the average EU wage rate for farmers of €32.12 per hour as presented in the Commission‟s CAP Reform Impact Assessment (inflated to 2012 prices).

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Table 5.1 Cost Implications of Best Practice on Spreading Practices

Best Practices Cost Implications to Farmers Assumptions for Analysis

Absolute thresholds Costs of manure testing to farmers 4-12 man hours per farm per year for manure testing / €15-30 per sample (assumed 5-10 samples per year).

Variable thresholds (i.e. Costs of soil and manure testing 1 4-12 man hours per farm per year for manure testing / subject to soil nutrient needs) €15-30 per sample (assumed 5-10 samples per year). Costs of estimating optimal application of organic manures and of adjusting application of mineral/ 4-12 man hours per farm per year for soil testing / artificial fertilisers to allow for application of organic €15-30 per sample (assumed 5-10 samples per year). manures 2-5 man days for estimating optimal application of Costs of development of nutrient balances and manures. manure management plans (manpower, software, 2 2-5 man days for developing nutrient balances and record keeping , use of external consultants due to manure management plans (could be higher if using lack of knowledge etc.) external consultants).

Short-term restrictions (i.e. Costs associated with extra manure storage capacity Additional storage capacity highly uncertain – subject to weather conditions Costs to farmers in terms of time, effort and excluded. (forecasts of heavy rain within knowledge required to adjust their manure spreading 4-8 man days per farm per year the next 48 hours), soil timing while taking into account specific Costs associated with development of codes of conditions (frozen, circumstances (manpower, software, record practice etc. not estimated as uncertain. waterlogged, mole drained) keeping2 etc.) etc.)

Closed periods Costs associated with manure storage (vary Highly uncertain – excluded depending on soil type, type of fertilizer and type of crop/ land use)

Types of crops (i.e. potential Costs of transportation (if the requirement limits the Assumed to be captured under requirements for contamination of crops from a area available) thresholds. livestock or human health Costs associated with extra manure storage capacity perspective) or costs of alternative manure treatment Costs associated with consideration and adaptation of “best” crop choices (manpower)

Types of land (topography, Costs associated with the need to avoid spreading Assumed to be captured under requirements for water courses, protected on steep slopes, areas sensitive to odour, near water thresholds. areas etc.) courses, SSSI etc. in terms of limitations imposed on the areas available to spreading. Costs of transportation (to other fields) and/or Costs associated with extra manure storage capacity or Costs of alternative manure treatment Costs associated with consideration and adaptation of practice (manpower) Costs of development of Codes of Practices and training (in MS where such Codes do not yet exist)3

Fertiliser plans Costs of development of fertiliser plans Assumed to be captured under requirements for Costs of record keeping thresholds. Costs associated with consideration and adaptation of best crop choices

Farm management Set proportion of the land area devoted to Costs highly uncertain - excluded permanent crops relative to annual tillage crops Use of crop rotation systems Maintain minimum vegetation cover during certain periods

Note 1: There is no information on trends in soil testing. It is considered likely that arable land is more regularly tested than grassland and forage crops; 2. According to a survey of the frequency of use of computer programs for record keeping, the majority of farmers do not make use of the software packages available to help them with nutrient management.

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Using the unit time/cost assumptions described above we have estimated total costs for the EU27 as a whole taking into account existing uptake of best practices (based on feedback from Member States during the consultation – see Table 4.11) and existing NVZ coverage. For the latter point we have assumed a linear relationship between proportion of a country designated as an NVZ and the proportion of the total number of farms that are located in or out of an NVZ e.g. if a country has designated 50% of its territory as an NVZ then it is assumed that half of its farms are located in the NVZ (and half outside). Whilst this is a very simplistic assumption we have no available evidence to further refine it. Where a measure is voluntary outside of an NVZ we have assumed 25% uptake rate where active support is provided but no additional costs if not. Potential uptake of measures under a voluntary scheme is highly uncertain.

For those farms captured by the IED we have assumed that they would still need to make the changes described and incur the costs as whilst they are required to operate according to BAT, the best practices described generally go beyond what is described as BAT and furthermore many IED regulated farms don‟t actually have the land on which to spread the manure so it is often transferred to a third party to spread elsewhere. It is important that even if this is the case there is an obligation on the producing farm to ensure that the manure is subsequently spread in line with the best practices described even if the receiving farm isn‟t captured by any new or revised legislation e.g. if it doesn‟t rear livestock. Therefore these costs would still be incurred but by another farmer. Overall this is likely to lead to an overestimation of costs associated with manure spreading best practices (primarily for reducing nitrate leaching to water) as some IED regulated farms may already be operating in line with some or all of the best practices described, but this is thought not to be significant for the reasons described above.

5.2.3 Administrative Costs

As described in Section 4, depending on the actual instrument selected there are a wide range of options for how any best practice requirements could be implemented in practice linked to whether an option is targeted at those farms producing the manure (requiring it to be spread according to best practice even if spread off site by a third party) or directly at those spreading it. These could vary from a permitting scheme approach such as that applied under the IED to a much lighter touch approach whereby a small number of farms are audited each year and are required to keep records of volumes of manure produced and how it has been processed, applied etc. The costs associated with the various best practice requirements are included under the compliance costs sections.

For the administrative costs we have made the following assumptions:

 A light touch approach to regulation would be taken whereby farmers would be required to maintain records of manure production, storage, processing and application including evidence of any transfers to other farms and that it has subsequently been stored and applied in line with the best practice requirements. This is considered most feasible in the current economic climate relative to a more costly permitting regime which would perhaps offer greater certainty in terms of compliance;

 For farmers we have assumed 2-4 man hours per year to maintain records on top of the time already assumed for developing manure management plans etc. under the different ambition levels. This time is only assumed for farmers outside of NVZs and not regulated under the IED as we assume that suitable records are already maintained for those in an NVZ or operating according to environmental permit. The same rate as applied under compliance costs has been used;

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 For regulators we have assumed that they would check the records of 5-10% of these farms per year. This is assumed to take 2-4 man hours using a rate of €18.96 per hour as documented in the Commission‟s CAP Reform Impact Assessment.

Irrespective of whether an option is targeted at either water and/or air emissions, the administrative costs are expected to be broadly the same as the types of records to be maintained and checks made will be similar.

5.2.4 Emission Reductions

The NH3 emission reductions presented are based on the modelling described above under compliance costs using outputs from the GAINS model to assess potential maximum uptake of measures for manure storage and spreading. As described above, the GAINS low and high manure storage efficiency systems broadly correlate to our proposed best practice ambition levels C and A, respectively, whilst their low and high efficiency manure spreading measures broadly correlate to our proposed best practice ambition levels C/B and B/A, respectively (the spreading measures include techniques that have been defined in more than one of our best practice ambition levels in Table 4.10 hence why they don‟t correlate to a single level).

Impacts on emissions to water are considered separately in Section 5.3.6.

5.2.5 Monetised Benefits

Indicative health and environmental (crop damage) benefits associated with our estimated reductions in NH3 emissions have been monetised through the application of the damage cost functions developed under the CAFE programme94 for the EU to the estimated emission reductions; the damage cost functions have been uplifted to 2012 prices. Low and high values are applied in order to reflect the sensitivities with the functions. Damage cost functions are monetary values (i.e. € per tonne of pollutant reduced) that can be applied to emission reductions to estimate indicative benefits.

5.3 Estimated Impacts

5.3.1 Potential Numbers of Holdings/ Animals Affected

Cattle

The table below indicates the numbers of holdings and heads of cattle likely to be affected with different thresholds based on Eurostat data for 2007. The thresholds are based on cattle heads although the equivalent threshold is also provided separately for dairy and other cattle based on LSU using values from Eurostat (1 and 0.74 for dairy and other cattle, respectively).

94 Available from: http://www.cafe-cba.org/assets/marginal_damage_03-05.pdf

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Table 5.2 Number of holdings (and cattle heads) covered by different thresholds (EU27)

Possible Possible Dairy Possible Other cattle threshold(s) threshold threshold (cattle (LSU - (LSU - other) No. of holdings No. of heads No. of holdings No. of heads heads) dairy) (thousands) [% (millions) [% of (thousands) [% (millions) [% of of total holdings] total heads] of total holdings] total heads]

0 0 2486 [100%] 25 [100%] 0 846 [100%] 65 [100%]

50 50 289 [12%] 18 [72%] 37 195 [23%] 51 [79%]

100 100 153 [6%] 13 [53%] 74 94 [11%] 39 [60%]

150 150 84 [3%] 10 [38%] 111 53 [6%] 30 [45%]

200 200 49 [2%] 7 [28%] 148 32 [4%] 22 [34%]

250 250 31 [1%] 6 [21%] 185 20 [2%] 17 [26%]

300 300 21 [1%] 5 [17%] 222 14 [2%] 14 [21%]

350 350 14 [1%] 4 [14%] 259 10 [1%] 11 [17%]

400 400 11 [0%] 3 [12%] 296 8 [1%] 10 [14%]

450 450 8 [0%] 3 [10%] 333 6 [1%] 8 [12%]

500 500 7 [0%] 3 [9%] 370 5 [1%] 7 [11%]

550 550 6 [0%] 2 [8%] 407 4 [0%] 7 [9%]

600 600 5 [0%] 2 [7%] 444 3 [0%] 6 [8%]

650 650 4 [0%] 2 [7%] 481 3 [0%] 5 [7%]

700 700 4 [0%] 2 [6%] 518 2 [0%] 5 [7%]

750 750 3 [0%] 2 [6%] 555 2 [0%] 5 [6%]

800 800 3 [0%] 2 [5%] 592 2 [0%] 4 [6%]

850 850 3 [0%] 2 [5%] 629 2 [0%] 4 [5%]

900 900 2 [0%] 2 [5%] 666 2 [0%] 4 [5%]

950 950 2 [0%] 2 [4%] 703 1 [0%] 3 [5%]

1,000 1000 2 [0%] 1 [4%] 740 1 [0%] 3 [4%]

Source: Eurostat

The figure below presents the data graphically to highlight the significant drop off in numbers (heads and holdings) as any potential threshold increases with the most significant change between a threshold of 0 or 50 heads (i.e. there are a significant number of small cattle farms in the EU – 2,848 thousand or 77% of total cattle farms with 0- 50 heads – which only equates to 24% of total cattle numbers). Above a threshold of 250 or 300 heads the number of farms potentially affected declines at a much slower rate as the threshold increases.

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Figure 5.1 Percentage of total EU27 Cattle Holdings and Heads above Different Thresholds

100%

90% Dairy cattle holdings Other cattle holdings 80% Dairy cattle heads 70% Other cattle heads 60%

50%

40%

30%

20%

10%

Thresholds

As described in Section 3.2.4, cattle are estimated to produce around 80% of total EU manure production. Animal numbers can broadly be considered as a proxy for the volume of this manure that could be captured by any new or revised legislation i.e. a threshold of 100 heads would mean just under 60% of total cattle manure would be affected or almost 50% of EU total manure production.

Poultry

The table below indicates the numbers of holdings and heads of poultry (broilers and laying hens) likely to be affected with different thresholds based on Eurostat data for 2010. The thresholds are based on poultry heads although the equivalent threshold is also provided separately for broilers and laying hens based on LSU using Eurostat LSU (0.007 and 0.014 for broilers and laying hens, respectively).

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Table 5.3 Number of holdings (and poultry heads) covered by different thresholds (EU27)

Possible Possible Broilers Possible Laying hens threshold(s) threshold threshold (poultry (LSU - (LSU - laying heads) broilers) No. of holdings No. of heads hens) No. of holdings No. of heads (in thousands) (millions) [% of (in thousands) (millions) [% of [% of total total heads] [% of total total heads] holdings] holdings]

0 0 2238 [100%] 871 [100%] 0 4148 [100%] 506 [100%]

10,000 70 17 [1%] 808 [93%] 140 8 [0%] 410 [81%]

20,000 140 12 [0%] 736 [84%] 280 5 [0%] 367 [72%]

25,000 175 10 [0%] 695 [80%] 350 5 [0%] 347 [69%]

30,000 210 8 [0%] 657 [75%] 420 4 [0%] 332 [66%]

35,000 245 7 [0%] 618 [71%] 490 3 [0%] 316 [62%]

40,000 280 6 [0%] 585 [67%] 560 3 [0%] 302 [60%]

Source: Eurostat

The figure below presents the data graphically to highlight the significant drop off in numbers of holdings between 0 and 10,000 heads whereas the actual number of poultry heads decline at a significantly lower rate. This highlights both the significant number of much smaller poultry holdings as well as the relatively small number of larger holdings which have a high number of animal places. The data also shows that over 60% of broilers and laying hens are captured under the IED regime (by animal numbers) yet this accounts for less than 1% of the total number of holdings. A threshold of 10,000 poultry heads would capture less than 1% of total poultry holdings (around 25 thousand) but almost 90% of total poultry heads.

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Figure 5.2 Percentage of total EU27 Poultry Holdings and Heads above Different Thresholds

100%

90%

80%

70%

60%

50% Broiler holdings 40% Broiler heads 30% Laying hen holdings 20% Laying hen heads

10%

Thresholds

As described in Section 3.2.4, poultry are estimated to produce around 8% of total EU manure production. Animal numbers can broadly be considered as a proxy for the volume of this manure that could be captured by any new or revised legislation i.e. a threshold of 10,000 heads would mean just under 90% of total poultry manure would be affected or around 7% of EU total manure production.

Pigs

The table below indicates the numbers of pig holdings and heads likely to be affected with different thresholds based on Eurostat data for 2010. The thresholds are based on pig heads although the equivalent threshold is also provided separately for sows and other pigs based on LSU using Eurostat LSU (0.5 and 0.3 for sows and other pigs, respectively).

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Table 5.4 Number of Holdings (and pig heads) covered by Different Thresholds (EU27)

Possible Possible Breeding sows Possible Other pigs threshold(s) threshold threshold (pig heads) (LSU - (LSU - others) No. of holdings No. of heads No. of holdings No. of heads sows) (thousands) [% (millions) [% of (thousands) [% (millions) [% of of total holdings] total heads] of total holdings] total heads]

0 0 626 [100%] 15 [100%] 0 2494 [100%] 95 [100%]

150 75 59 [9%] 13 [88%] 45 101 [4%] 86 [90%]

300 150 43 [7%] 12 [84%] 90 77 [3%] 82 [86%]

450 225 36 [6%] 12 [81%] 135 63 [3%] 79 [82%]

600 300 31 [5%] 11 [78%] 180 54 [2%] 75 [79%]

750 375 27 [4%] 11 [75%] 225 46 [2%] 71 [75%]

900 450 24 [4%] 11 [72%] 270 40 [2%] 68 [71%]

1050 525 22 [3%] 10 [69%] 315 34 [1%] 64 [67%]

1200 600 20 [3%] 10 [67%] 360 30 [1%] 61 [64%]

1350 675 18 [3%] 9 [64%] 405 27 [1%] 57 [60%]

1500 750 16 [2%] 9 [61%] 450 24 [1%] 55 [57%]

1650 825 14 [2%] 9 [59%] 495 21 [1%] 52 [54%]

1800 900 13 [2%] 8 [57%] 540 19 [1%] 49 [52%]

1950 975 12 [2%] 8 [54%] 585 17 [1%] 47 [49%]

2100 1050 11 [2%] 8 [52%] 630 15 [1%] 44 [46%] Source: Eurostat

The figure below presents the data graphically to highlight the significant drop off in holding numbers between a threshold of 0 and 150 heads. As for poultry (although not as pronounced), the numbers of heads affected declines at a significantly lower rate. A threshold of 150 heads would only capture around 5% of all holdings (around 160 thousand) yet around 90% of pig numbers.

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Figure 5.3 Percentage of total EU27 Pig Holdings and Heads above Different Thresholds

100% Breeding sow holdings 90% Breeding sow heads 80% Other pigs holdings 70% Other pigs heads

60%

50%

40%

30%

20%

10%

Thresholds

As described in Section 3.2.4, pigs are estimated to produce around 13% of total EU manure production. Animal numbers can broadly be considered as a proxy for the volume of this manure that could be captured by any new or revised legislation i.e. a threshold of 150 heads would mean around 90% of total pig manure would be affected or just over 11% of EU total manure production.

Summary

As the figures above clearly demonstrate, for all three animal types there are a significant number of farms with a small number of animals so there is merit in setting thresholds for coverage under any new or revised legislation. This will exclude the smallest farms where minimal benefits are likely to be realised (and possibly at excessive cost).

 All cattle: 50 heads;

 All poultry: 10,000 heads; and

 All pigs: 150 heads.

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Applying these thresholds would mean that around 670,000 holdings would be captured in the EU (only around 5% of total number of holdings yet around 90% of total animal heads), of which 289,000 holdings would be dairy cattle, 195,000 beef cattle, 160,000 pigs and 25,000 poultry. It should be noted that around 10% of these are already regulated under the IED regime95 and a significant number are likely to fall in NVZs so may already be subject to manure specific measures under the Nitrates Directive requirements and other national legislation.

These thresholds have been selected as they would ensure that the majority of manure produced across the EU (potentially around 90%) would be captured yet only around 5% of livestock farms would be affected. Note, this does not take into account the numbers of farms spreading the manure. As highlighted above, these thresholds have only been taken into account in the assessment of potential compliance costs for applying best practices for manure spreading (measures focused primarily on reducing emissions to water) and administrative costs. Costs for measures targeted specifically at manure storage and spreading have been modelled based on the reference and maximum applicable uptake rates assumed in the GAINS model. This assumes that the smallest farms (below 15 LSU) would not have to apply any of the measures and thus assumes tighter thresholds than those described in this section.

5.3.2 Compliance Costs

Measures for reducing NH3 Emissions to air

Cost-effectiveness of measures targeted at the agriculture sector A number of sources have described the cost effectiveness of measures targeted at reducing ammonia emissions from different phases of the livestock sector. The techniques and associated costs and cost effectiveness as presented in the Gothenburg Guidance document as adopted by the CLRTAP Executive Body in 2012 are summarised in the table below. This shows how manure storage and application measures tend to be at the lower end of the cost spectrum i.e. they are relatively cost effective compared to other ammonia abatement measures. Some of the application measures can even show a negative overall cost as, when applied properly, manure can reduce the need for purchased fertilisers.

95 IED thresholds are 40,000 animal places for all poultry, 2,000 places for production pigs and 750 places for sows.

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Table 5.5 Summary of Measures from the draft Gothenburg Protocol Agriculture Guidance Document

3 Measures Costs, Euro per kg/m /year Cost, Euro per kg NH3-N saved

Manure storage

Tight lid (>80% reduction) 2-8 2-4

Plastic sheet (>60% reduction) 1-2 0.5-1.5

Floating cover (>40% reduction) 1-2 1-2

Manure application

Slurry: trailing shoe/injection (>60% reduction) -0.5-2

Slurry: band spreading (>30% reduction) 0-2

Solid manure: direct incorporation, where -0.5-2 feasible (>30% reduction)

Animal housing

Existing IED regulated farms (20% reduction) 0-3

New or largely rebuilt cattle housing (25% 1-6 reduction)

New or largely rebuilt pig housing (25-60% 0-10 (depending on ambition level) reduction)

New or largely rebuilt broiler housing (20% 0-2 reduction)

New or largely rebuilt layer housing (30-60% 0-8 (depending on ambition level) reduction) Source: GUIDANCE DOCUMENT FOR PREVENTING AND ABATING AMMONIA EMISSIONS FROM AGRICULTURAL SOURCES, adopted by the CLRTAP Executive Bureau in December 2012.

In addition to the source described above, IIASA‟s GAINS model also includes a wide range of measures targeted at the livestock sector. These have recently been described in TSAP Report #3 for the European Commission (IIASA/Alterra 2012) as well as by IIASA (2011)33. Table 5.1 of the report summarises the costs of ammonia emission abatement options applied to pig production (cattle production being in the same range), poultry production and fertiliser application. The table presents 25 and 75 percentiles in order to indicate the range of values applied across the EU (excluding extreme values) and again demonstrates how cost effective manure spreading measures are compared to other measures. In particular, the highest efficiency application techniques are some of the most cost effective measures available, alongside low protein feed.

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Table 5.6 Costs from IIASA/Alterra 2012 (TSAP Report #3)

As highlighted in the table above, the costs of the techniques will vary from country to country. Due to economies of scale, some of the spreading techniques may be more cost-effective on large farms than on smaller farms particularly when a technique requires the purchase of capital equipment e.g. low emission slurry measures. In these instances, as would be expected the unit costs increase as the volumes of manure decrease. The guidance document under the Gothenburg Protocol also indicates that a greater cost burden for smaller farms may also be the case for immediate incorporation of manures. However, it also specifies that for both slurry application and manure incorporation, the costs for small farms can generally be reduced by hiring a third party contractor with access to the required equipment.

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As described above, some measures for the spreading of manure can result in cost savings as a result of a reduction in the use of fertilisers through conserved nitrogen. The recently issued second draft of the revised Intensive Livestock BREF (August 2013)96 provides some data on the economic “bonus” that certain spreading techniques can bring to farmers. This bonus is a value of extra-N uptake due to conserved nitrogen; the value of such conserved nitrogen depends on fertiliser prices and ammonia abatement efficiency.

Table 5.7 Bonus for Conserved Nitrogen, achieved by applying Low Emission Spreading Techniques for Slurry (relative to use of a broadcast spreader)

Technique Example from Germany Example from UK

3 3 Associated NH3 Bonus (€/m slurry) Associated NH3 Bonus (€/m slurry) emission reduction (%) emission reduction (%)

Trailing hose 30 0.27 40 0.53

Trailing shoe 50 0.45 65 0.85

Open slot injector 60 0.54 80 1.07

Closed slot injector 90 0.81

Immediate incorporation 95 1.27

Incorporation within 1h 90 0.81

Incorporation within 4h 70 0.63

Assessment of maximum application of manure storage and application measures The figure below presents the additional costs associated with the maximum uptake of GAINS measures for covered storage (low and high efficiency – broadly correlating to our ambition levels C and A, respectively) and low nitrogen application (low and high efficiency – broadly correlating to our ambition levels C/B and B/A, respectively). These costs are additional to any uptake anticipated under the reference scenario i.e. as a result of existing obligations. Costs are presented disaggregated for different livestock and manure types and are based on GAINS data for 2025.

This shows that maximum application of the low efficiency storage measure results in limited additional costs reflecting primarily the high existing uptake of the measure under the baseline. However, maximum application of the high efficiency storage measure would lead to considerable additional costs as it not expected to be applied widely by 2025 under existing obligations. For spreading, maximum application of both the low and high efficiency measures is expected to result in similar additional costs reflecting the varying costs of the measures (both costs and savings through reduced fertiliser use) and uptake of the measures under the baseline.

96 Available at: http://eippcb.jrc.ec.europa.eu/reference/BREF/IRPP_D2_082013online.pdf

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Figure 5.4 Maximum additional Costs for Manure Storage and Spreading Measures (relative to GAINS reference scenario, €m per year)

The overall cost-effectiveness (based on the modelled maximum uptake) varies from €1.2 (low efficiency – broadly correlated to our ambition level C) to €4.2 (high efficiency – ambition level A) per kg of ammonia abated for covered storage and €1.4 (low efficiency – broadly correlated to our ambition levels C/B) to €0.4 (high efficiency – B/A) per kg of ammonia abated for spreading i.e. the high efficiency spreading techniques are more cost effective than the low efficiency measures due to the increased economic bonus from increased nitrogen and subsequent reduced need for fertilisers.

It is worth noting that as part of the TSAP revision modelling, IIASA have undertaken various sensitivity analyses (as document in TSAP report #10, March 2013) including an assessment of how applying the differing ambition levels from the draft guidance document under the Gothenburg Protocol across the EU (i.e. by all Member States) might change the overall cost-effectiveness relative to the optimisation scenario (i.e. where measures uptake is determined by cost-effectiveness rather than any EU wide requirements). Whilst emission control costs increase slightly relative to the optimisation scenario (and emission reductions are slightly less), overall the change (negative) is relatively small (around 1%). This demonstrates that an EU wide approach (i.e. setting requirements at an EU level for all Member States to meet) for agriculture as a whole could be cost effective relative to individual Member State action and provide much greater certainty.

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Costs of Best Practices for Spreading (measures for reducing nitrate leaching to water)

The table below summarises the range of costs associated with best practice ambition levels A and B (as described in Section 4.5). No costs have been estimated for ambition level C as the majority of measures proposed related to reducing emissions to water can be considered BAU in most Member States e.g. they only apply within NVZs and/or are voluntary outside. Where voluntary outside of an NVZ we have not estimated any costs unless they are actively supported (as for ambition level B).

Table 5.8 Estimated Costs associated with Best Practice Ambition Levels A and B for Measures Targeted Primarily at Reducing Nitrate Leaching to Water (€ million per year)

Average Range

Ambition level A 1,260 727 – 1,825

Ambition level B 126 79 – 175

These cost estimates are based on the estimated number of holdings that could be affected using the thresholds described above in Section 5.3.1. Taking a lower or higher set of thresholds would of course affect a differing number of holdings and subsequently change these costs. The cost estimates for ambition level A are considerably higher than B as in general they require application of best practice measures across the whole of a Member State‟s territory and not just in an NVZ thus capturing a much greater number of farms.

There is a high degree of uncertainty associated with these cost estimates due to uncertainties over current practices in each of the Member States.

5.3.3 Administrative Costs

As described above, a light touch approach to regulation is assumed with no additional burden expected for those farms operating in NVZs and/or under the IED. The range of costs estimated for those remaining farms are described in the table below.

Table 5.9 Estimated Costs associated with Administrative Burden (€ million per year)

Average Range

Farmers 26 17 – 35

Regulators 1.3 0.5 – 2

Total 27 18 – 37

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This only considers existing NVZ and IED requirements and therefore may be an overestimate of administrative burden as some Member States may already require this information to be maintained by operators. Furthermore, some of the best practices require the development of manure management plans and suitable record keeping so there may be some overlap in terms of time needed.

5.3.4 Emission Reductions

The figure below presents the additional emission reductions associated with the maximum uptake of GAINS measures for covered storage (low and high efficiency) and low nitrogen application (low and high efficiency). These emission reductions are additional to any uptake anticipated under the reference scenario i.e. as a result of existing obligations. Emission reductions are presented disaggregated for different livestock and manure types and are based on GAINS data for 2025.

This shows that maximum application of high efficiency spreading measure is expected to result in significantly greater emission reductions than the other measures considered reflecting the high abatement efficiency and low uptake of the measure under the baseline. Maximum uptake of the high efficiency spreading measures is expected

to result in emission reductions of over 250kt of NH3 in 2025 over and above the baseline compared to around 80kt reduction with maximum uptake of the low efficiency spreading measures (lower abatement efficiency and much higher uptake assumed in the baseline). Maximum uptake of the covered storage measures is estimated to reduce

NH3 emissions in 2025 by 15kt and 50kt for the low and high efficiency measures, respectively. Note, as described previously it is not possible to combine the impacts of these measures due to interactions.

For comparison, total NH3 emissions from all livestock activities in 2025 for the EU28 under the reference scenario are expected to be around 2,100 kt (GAINS).

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Figure 5.5 Maximum additional Emission Reductions for Manure Storage and Spreading Measures (relative to GAINS reference scenario, kt NH3 per year)

Whilst potential impacts on N2O and methane emissions have not been modelled by IIASA or in this study, we would expect them to reduce as a result of the measures being considered. For example, Nicholson et al (2011)97

identified that improving manure application efficiency would lead to reductions in both NH3 and N2O emissions. However, it also found that extending the „closed periods‟ by 2 months (rather than just 1) more than the current

NVZ requirements could increase the potential for NH3, methane and nitrous oxide emissions during manure storage, because of the requirement to store it for longer, as well as leading to greater application in the summer months.

5.3.5 Monetised Benefits

The potential benefits associated with reductions in NH3 emissions under the central case scenario described above have been monetised using the CAFE damage cost functions as described in Section 5.2.5. The total benefits

97 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/82414/20111220nitrates-directive-consult- evid7.pdf

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associated with the maximum uptake of each measure (mid point of range) are summarised in the figure below alongside the associated costs (replicated from Figure 5.4 above). As the figure demonstrates, benefits outweigh costs by a significant distance for all measures considered.

Figure 5.6 Comparison of Monetised Benefits (using CAFE damage cost functions) and Costs associated with Maximum Uptake of each Measure (relative to GAINS reference scenario, €m per year)

5.3.6 Wider Environmental Impacts

The addition of excess organic and/or mineral fertilisers by farmers can potentially pollute air, water and soil and have consequences on biodiversity. The risks and their magnitude depend on:

 Climatic conditions: temperature, humidity;

 Farming practices: nutrient management (type of fertilisers, dose, timing, application techniques) and farm management (type of crop, timing, irrigation and drainage, tillage, soil coverage, crop rotation, livestock feeding and housing, manure storage);

 Nature of the soil (in the case of spreading): texture, structure, depth, soil organic matter, carbon content;

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 Geographical conditions (in the case of spreading): proximity to waterbodies, slopes. Vulnerability of water bodies is also an important factor to consider while assessing risk for water pollution due to leaching and run off of nutrients.

Risks of water and soil pollution are high, when the availability due to a surplus of nitrogen (N) and phosphorus (P) is high, under pedo-climatic conditions that are favourable to leaching and run-off. The resulting impacts are negative when they cause eutrophication and/or result in water that is inappropriate for drinking (>50mg/L of nitrates) or bathing purposes. Manure spreading on land is not the only source of nitrates pollution as mineral fertilisers are responsible for about half of the load from agriculture (responsible for about 50%-80% of the total nutrient load in waters).

Within the Nitrates Directive, the Member States are required to define Nitrate Vulnerable Zones (NVZ) based on water quality criteria (and expected quality in case no action is taken, see Annex I of the Directive). In these areas, specific conditions apply to limit the negative impacts from nitrate pollution. About 40% of the EU27 territory is now designated as NVZ (considering the countries that are applying a whole-country approach) (European Commission, 2011). In 2003, seven countries had designated less than 50% of their territory as NVZ, and the European Commission took legal procedures against all seven of them (DOENI, 2003). Outside of NVZ, the benefits of reducing nitrate emissions for reducing water pollution issues seem to be limited. Current issues with nitrates are in particular due to insufficient implementation of the Nitrates Directive. The Fitness check and the Commission‟s report on implementation of the Nitrates Directive indeed highlight “insufficient designation of nitrate vulnerable zones and non-conformity of action programmes” (European Commission, 2012 and European Commission, 2011). In general, the reason for Member States to follow a “whole territory” approach (i.e. implementing an action plan for the whole territory rather than designating NVZ and applying action plans there) seems to be for equity reasons rather than environmental reasons98.

Strictly in terms of water pollution reduction a whole territory approach is not necessarily a cost-efficient measure throughout the EU. In addition, careful attention must be paid to the risks of pollution swapping, as reducing air emissions may lead to increased risks of emissions to water (e.g. spreading techniques that reduce air emissions) and vice-versa (e.g. ban of spreading in certain periods and associated obligation to store manure may lead to increased air emissions), necessitating a holistic approach to nitrogen pollution mitigation (OECD, 2012). For example, when the soil is well aerated, nitrate and nitric oxide production decreases (reducing the risks of leaching to water bodies) while ammonia emissions increase (increasing emissions to air). To ensure that individual ammonia measures also reduce N2O and nitrate losses, it is essential that overall fertilizer inputs are fine-tuned to match the amount of nitrogen saved. In this way, farmers can also save time and costs by reducing other fertilizer inputs, as reduced nitrogen losses translates to a larger fraction of nitrogen inputs being available to reach the agricultural crops.

98 See Jacobsson et al., 2002. In addition, for example Austria justified the use of a whole territory approach as providing overall environmental benefits, and ensuring a level playing field for all farmers (response to the consultation). Similarly the response of RSPB to the England consultation, that recommends a whole territory approach, does not justify it on the grounds of environmental benefits, but of administrative, communication and equity benefits, etc. (RSPB, 2008).

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The options that have been proposed aim to reduce emissions from manure, resulting in one or more positive environmental impacts. The effects of the options proposed are summarised in the table below. The possible trade- offs and the factors influencing the magnitude of the options‟ effects are detailed in more detail in Appendix D. Note impacts for air emissions are described separately above.

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Table 5.10 Effects of the Options regarding the different Environmental Impacts

Manure Manure Quantity Quantity Manure spreading Timing of Areas of Farm Land use Type of storages: thresholds thresholds storages: cover technique and application application management management assessment capacity (absolute) (variable) incorporation* A B C A B C A B C A B C A B C A B C A B C A B C A B C Water – acidification Qualitative = = = +++ ++ + +++ ++ + + + = + + ======/(+) =/(+) = = = = Water – eutrophication Qualitative + + = risk - risk - = -- - - + (+) = + (+) = (+) (+) = (+) (+) = =/(+) =/(+) = + + = Biodiversity – soil Qualitative (+) (+) = (+) (+) = ? ? ? (+) (+) = (+) (+) = (+) (+) = (+) (+) = =/(+) =/(+) = ++ ++ = biodiversity Biodiversity – animals Qualitative (+) (+) = (+) (+) = ? ? ? (+) (+) = (+) (+) = (+) (+) = (+) (+) = =/(+) =/(+) = ++ ++ = Biodiversity - habitats Qualitative (+) (+) = (+) (+) = ? ? ? (+) (+) = (+) (+) = (+) (+) = (+) (+) = =/(+) =/(+) = ++ ++ = Ecosystem services Qualitative (+) (+) = (+) (+) = ? ? ? (+) (+) = (+) (+) = (+) (+) = (+) (+) = =/(+) =/(+) = ++ ++ = Carbon sequestration Qualitative ======+ + + ======/(+) =/(+) = ++ ++ = Landscape – maintenance of Qualitative ======/(+) =/(+) = ++ ++ = pasture, etc. Soil water retention Qualitative ======+ + + (-) (-) = (-) (-) ======/(+) =/(+) = ++ ++ = Soil organic matter Qualitative ======+ + + - (-) = - (-) ======/(+) =/(+) = ++ ++ = Soil erosion Qualitative ======+ + + (-) (-) = (-) (-) ======/(+) =/(+) = ++ ++ = Leaching of nutrients (N) Qualitative + + = risk - risk - = -- - - + (+) = + (+) = + + = + + = =/(+) =/(+) = + + = Leaching of nutrients (P, K) Qualitative + + = risk - risk - = - (-) (-) + (+) = + (+) = + + = + + = =/(+) =/(+) = + + = Pollution (heavy metals, Qualitative + + = risk - risk - = - (-) (-) + + = + + = + + = + + = =/(+) =/(+) = + + = chemicals) in soils

* Estimated impacts based on the assumption that no change in amounts of manure applied takes place. Using these techniques needs adapting overall approach to manure management. =: the option will not have additonal effect compared to current regulation (-) or (+): the option might have an negative/positive effect on the concerned indicator or no effect compared to the current regulation + to +++: the option may have positive effect on the concerned indicator compared to the current risk: requires more careful implementation of best practices to avoid risk regulation - to ---: the option may have negative effect on the concerned indicator compared to the current regulation ?: unknown as depends on the resulting balance (effects will compensate each other)

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5.3.7 Wider Economic and Social Impacts

Introduction

Any combination of the options considered, which result in an additional financial burden to the operator (administrative/compliance), will present operators with a choice of how to react (hereafter referred to as „operator reaction‟):

 To cover the additional burden by increasing productivity; increasing productivity through expansion to achieve economies of scale is the most likely (particularly for the dairy sector);

 To reduce the scale of operation to below a relevant threshold, to avoid the additional burdens imposed by any regulatory regime (in this case, this might mean reducing operations so that the volume of manure produced is below the quantity equivalent to 170 kg N/ha of available land or below any farm size thresholds);

 To apply for the RDP funding under the CAP Pillar II. In the course of the ongoing CAP reform for the 2014-2020 period, ammonia has been added to the Rural Development Indicators thereby allowing Member States to develop support measures that more specifically target manure to reduce ammonia emissions;

 To go out of business (or at least to cease that particular enterprise) rather than face the additional burdens imposed by the regime;

 Accept a reduction in profits, due to increased compliance costs and administrative burden;

 For new entrants, the additional cost of regulation imposes a hurdle to industry expansion; operators have to decide whether to enter the market with herd numbers below the threshold, or enter with a herd sufficiently large that the economies of scale covers the extra compliance costs involved.

The „operator reaction‟ is dependent on a number of factors:

 The relative size of the additional burdens imposed by the regime relative to an appropriate financial performance indicator (e.g. turnover, operating costs, gross value added, gross operating surplus etc.), which is influenced by:

- The absolute size of the additional burden; influenced by the measures and regulation required and measures already adopted as BAU;

- The absolute scale of other variables (operating costs/ income).

 Underlying trends in the sector, such as moves to reduce operating costs, or increase product differentiation to increase international competitiveness. In the dairy sector, particularly in longer standing MSs, increased productivity is likely to be achieved through economies of scale; in the beef sector increased productivity may also be achieved through, for example, greater use of selective breeding. In the pig and poultry industries, economies of scale may be achieved through further consolidation, especially in those Member States in which the industry remains fragmented across multiple smaller holdings;

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 The ability to pass on costs through higher product prices. This is generally taken to be inversely linked to the level of competition within an industry, especially non-EU competition, i.e. the greater the degree of competition (especially non-EU competition), the more limited is the likelihood that EU producers will be able to pass on any additional costs, thus limiting their potential reactions;

 The capacity (physical, financial) of the herd to expand in order to achieve greater economies of scale and thus increase the operator‟s ability to shoulder an additional regulatory burden (c.f. Figure 5.7 below, on decreasing unit costs of ammonia abatement measures with increasing volumes of manure). If the herd cannot feasibly expand, the cost-effective compliance options available are reduced;

 The personal preferences of the farm operator; farmers may prefer to accept a reduction in profits rather than cease operations due to an emotional attachment to the profession, or not to change their operating systems, due to an attachment to the traditional systems.

Perhaps the most significant factors will be the scale of the additional burden relative to existing operating costs, as well as operators‟ ability to shoulder the costs via economies of scale. This is illustrated in Figure 5.7, which shows that average investment costs to abate ammonia emissions from manure (per cubic metre of manure) increase rapidly below 500m3. This further demonstrated in

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Figure 5.8 which illustrates how costs associated with slurry injection and manure incorporation are lower at higher application rates (figure also provides comparison between GAINS and UK data).

Figure 5.7 Size-dependent Investment Costs for High Efficiency Measures to abate Ammonia from Manure Storage. The inverted regression function (line) indicates high costs for small units (costs expressed in EURO of the year 2005)

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Figure 5.8 Comparison of cost data for slurry injection (orange) and for incorporation of manure (blue)

Both figures reproduced from: Klimont & Winiwarter (2011) Integrated ammonia abatement – Modelling of emission control potentials and costs in GAINS, Interim Report IR-11-027, IIASA, September 2011

The types of operation and region where it is expected that the additional burden will be relatively large are:

 Operators in regions where the ratio of number of animals (manure volume) to available arable land on which to spread manure is high;

 Operators outside NVZs (under the policy options that extend the requirements of the Nitrates Directive from NVZs only to whole territory);

 Operators of smaller herds (dependent on threshold limit) are expected to be more affected, due to:

- Proportionately higher administrative and compliance costs per unit of production;

- Existing operating costs are higher for smaller herds, due to diseconomies of scale;

- MSs with a higher proportion of smaller herds will be more affected;

 Operators in MSs with lighter regulatory regimes. For instance, MS with low proportions of territory currently designated as NVZs.

The wider socio-economic impacts of the policy options can therefore be estimated by assessing the number of operators that fall into the above categories.

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Geographical Considerations

Some of the key differences between the options under consideration relate to their geographical scope, particularly whether the option provisions apply to the whole of MS territories or to NVZs only. For this reason, it is worthwhile to consider how these areas (i.e. NVZ vs. whole territory) compare. In addition to this, it is also worthwhile to compare NVZ areas to the areas covered by agricultural land, as this is the land category most relevant to the study.

As a starting point, it is noted that 10 Member States have designated their entire territories as NVZ99 (AT, DK, FI, DE, IE, LT, LU, MT, NL and SI), as is clear from the map below. For these Member States, the differences in impact between options (and compared to the baseline) will be lower than for others.

Figure 5.9 NVZ Map

Source: JRC, http://fate-gis.jrc.ec.europa.eu/geohub/MapViewer.aspx?id=2

For Member States that have not designated their entire territories as NVZ, a comparison of NVZ land areas to both the whole territory and the land area comprising arable land, land under permanent crops and permanent grassland is provided below.

99 http://ec.europa.eu/environment/pubs/pdf/factsheets/nitrates.pdf

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Figure 5.10 NVZ Land Area as a Percentage of 1) Whole Territory and 2) Arable Land, Land under Permanent Crops and Permanent Grassland, 2008

Source: Eurostat query on [aei_pr_gnb] database, EC Working Paper SEC (2011) 913

From the above figure, it can be seen that for some Member States (SE, BE and BG), while the proportion of total territory that is classified as NVZ is not 100%, the NVZ land areas is larger than the land area upon which manure might be spread. While this does not necessarily mean that all such land is classified as NVZ in these territories, it may nonetheless be supposed that a very large proportion (if not all) of it probably is. Therefore, the option impacts that are linked to extending certain NVZ requirements to the whole territory are likely to be very limited in these Member States.

Conversely, the impacts of such NVZ scope expansion stand to be quite significant in those Member States where NVZs represent a small proportion of land upon which manure might be spread. The Member States most likely to be impacted in such a way are Poland, Portugal, Romania, Spain and Italy, with Cyprus, Estonia, Latvia and Greece also potentially significantly affected.

Another measure of the geographical distribution of impacts may be assessed by considering the average manure nitrogen input per hectare in the Member States. This is presented in the figure below.

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Figure 5.11 Nitrogen input per hectare of Lands Classified as Arable Land, Land under Permanent Crops and Permanent Grassland (kg/ha), 2008

Source: Eurostat query on [aei_pr_gnb] database

Note: The 170 kg N/ha threshold does not apply in all Members States, as many have derogations, as described in section 3. For instance, this is the case in the Netherlands, for which the Nitrates Directive threshold is 250 kg N/ha from manure from grazing livestock on grassland farms with at least 70% or more of the agricultural land is grassland.

The impacts described below (competitiveness, labour) are expected to be greater for the types of operations and regions listed above.

Competitiveness

As stated earlier, the European beef and dairy sectors are undergoing a period of liberalisation, which will result in increased internal and international competition in products and is likely to result in lower beef and milk prices in future years. It also means that operators are unlikely to be able to pass on additional costs by increasing prices. These trends will be reinforced if additional trade agreements are reached. In response, farmers are likely to seek to reduce operating costs (economies of scale, increased productivity per cow/hectare), or be forced to close. Regulation will impose additional costs on farmers, which will reduce international competitiveness; this will reinforce the existing drivers for changes in the sector and reactions within the beef and dairy industries (closure, expansion, increased productivity). It should be noted, however, that some Member States (e.g. the Netherlands and Denmark) already set out ambitious national requirements with regard to manure storage, spreading and

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management. Introducing EU wide measures would ensure a level playing field across the EU. In the short term, Member States already implementing more stringent national legislation may benefit from a relative increase in competitiveness (as a result of additional burdens on other Member States). It should be noted, however, that the ongoing CAP reform and, in particular, addition of ammonia to the Rural Development indicators will provide Member States with an opportunity to financially support measures that specifically target manure with the aim to reduce ammonia emissions. In the Member States that would choose to include such measures in their RDPs, such financial support could partially or fully offset the additional costs.

The pig and poultry sectors are both undergoing periods of consolidation, with average herd sizes increasing while the number of holdings decreases. The baseline pattern is thus one of increasing competitiveness linked to greater economies of scale. This pattern is expected to continue and amplify with increasing environmental and animal welfare requirements (e.g. Council Directive 2001/88/EC, which has applied to all pig holdings since 1 January 2013). In this context, this pattern is expected to become more pronounced as the policy options impose further regulatory requirements. Overall, the additional costs imposed by further regulation will reduce competitiveness in the first instance, especially in those Member States in which the pig and poultry sectors remain relatively unconsolidated (e.g. many CEE countries). However, they are also likely to amplify the existing trends of industry consolidation, potentially driving greater competitiveness eventually. As for the beef and dairy sector, those Member States that would choose to include measures aimed at ammonia emissions reduction in their RDPs, the financial support available could partially or fully offset the additional costs.

It should also be noted that consumer awareness of animal welfare and wider environmental issues linked to agriculture has increased greatly in recent years, as reported in a European consumer survey by the European Animal Welfare Platform100 and in an investor briefing note by the Business Benchmark on Farm Animal Welfare (BBAFW)101. While regulation pertaining to the spreading of manure is not directly related to the main animal welfare issues of concern to consumers, it may nevertheless be the case that the policy options under consideration might aid the industries in developing a „greener‟ image, especially in comparison to imported meat, eggs and dairy products. Should this be the case, the competitiveness of these European industries would be enhanced. More stringent environmental standards overall may also aid European producers to reach concerned consumers in non- EU markets. For instance, the BBFAW note reports that “US consumers were willing to pay almost twice as much for their meat when pigs were reared in open barns, pasture and organic systems”.

The type of farmers‟ reaction in response to the additional regulatory burden, will determine the impact of the regulation on the farm‟s and sectors‟ competitiveness. The likely impact of different farmers‟ reactions on competitiveness is summarised in Table 5.11 (below).

100 http://www.animalwelfareplatform.eu/documents/ProjOutput-consumerconcerns.pdf

101 http://www.bbfaw.com/wp-content/uploads/2010/08/Briefing-No7_FAW_and_the_Consumer.pdf

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Table 5.11 Impact of Farmer Reaction on Competitiveness

Farmer Reaction Impact on Competitiveness

Increase in scale to The impact on competitiveness depends on the scale of expansion: counteract increase in - If the farm undergoes a significant expansion, so that the economies of scale exceed the additional operating costs regulatory burden, the farm‟s competitiveness will have increased due to a net reduction in operating costs; - If the economies of scale realised are equal to the additional regulatory burden, the farm will merely maintain its competitive position. The impact of this operator reaction on European competitiveness in beef and dairy products will be to maintain, or increase international competitiveness. This is also expected to be the case in the poultry sector, although the countering effect of further expansion will be limited for those holdings that are already very large and have already achieved significant economies of scale. In the pig sectors (both sows and pigmeat), however, the combined effect of the increased environmental regulation and of higher pig welfare standards (from Directive 2001/88/EC) may mean that the sector‟s competitiveness would still reduce overall, especially for larger holdings brought into use prior to 1 January 2003, and that which have already achieved significant economies of scale.

Reduce scale of Operators could experience small diseconomies of scale due to herd size reduction, but are likely to maintain the operation so that existing level of farm competitiveness as only operators with herds that are close to the threshold are likely to do manure produced is this. As smaller herds are (on average) less competitive in the baseline situation, farms will continue to be under below 170 kg N/ha pressure to increase competitiveness (through increased productivity or specialisation) or face closure. limit Operators are more likely to choose this option, where: - existing herd produces manure in quantities close to the quantity threshold; - there are opportunities for greater specialisation (e.g. specialist breeds), or increased productivity (e.g. greater use of selective breeding in the beef industry); - there are physical or financial barriers to expansion; - the operator‟s personal preferences are to continue operating with the existing herd size. The impact of this operator reaction on European competitiveness in beef and dairy products, as well as with poultry, is uncertain and dependent on other steps taken by operators to increase competitiveness. For pig holdings, the impacts would be additional to the impacts arising from the operator reaction to the full implementation of Directive 2001/88/EC. In this context, it would be difficult to disentangle the competitiveness impacts arising from the different regulatory requirements, except for holdings built since 1 January 2003 (for which Directive 2001/88/EC has always applied).

Use available RDP Farmers in the Member States that will use the opportunity to support measures aimed at reducing ammonia funding under CAP emissions would be able to benefit from RDP funding. This additional funding could cover additional costs fully or Pillar II to offset partially. In the instances, where the additional costs will be fully covered the impact on farmers‟ competitiveness additional costs will be neutral.

Cease operations It is expected that only the least efficient farms, or those farms without opportunities to reduce costs, or increase specialisation will choose to cease operations. The impact of this operator reaction on European competitiveness in all sectors is likely to be an increase in (average) international competitiveness, as the least efficient firms drop out of the market. For the poultry and pig sectors, this operator reaction would serve to amplify the baseline trend of industry consolidation around fewer, larger more vertically integrated holdings.

Accept a reduction in An increase in operating costs, without any operator reaction, results in a reduction of competitiveness for the farm profits and for the sector.

Broadly, the impacts of the options under consideration on competitiveness according to some key elements, as summarised in Table 5.12 (below).

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Table 5.12 Broad Impacts of Option Elements on Competitiveness

Option/ Element Impacts on Competitiveness

Voluntary approach If the approach was voluntary, the immediate impact on competitiveness would be significantly less than for the mandatory options, as operators would be free to choose whether to adopt the approach or not. If the voluntary scheme can be adopted on a „menu‟ basis, operators can choose to implement those measures that will not jeopardise the viability of their business (low cost).

Regulatory approach Depending on any differences in regulatory approach (e.g. permitting versus non-permitting) impacts (reductions) on competitiveness could be more pronounced (at this stage we have simply modelled a relatively light touch regulatory approach without any permitting as such).

Differing levels of ambition for The overall compliance costs with the lower levels of ambition are much lower than with the most stringent best practices level (A), both in terms of specific costs for the affected operators, but also in terms of the number of operators affected. Therefore, the reduction in competitiveness will be more pronounced the higher the level of ambition.

Geographical coverage Options that extend requirements that are equivalent to (or go beyond) ND ones beyond NVZs will affect more holdings than those that are limited to NVZs, thus imposing greater overall costs and having a greater potential impact on competitiveness overall. This applies only to operators in Member States that have not designated their entire territory as NVZ.

These broad considerations can then be applied to the specific options under consideration, as presented below.

Table 5.13 Specific Impacts of Best Practice Elements on Competitiveness

Element A (high) B (moderate) C (low)

Manure Option extends storage requirements to Option extends storage requirements to Equivalent to current Nitrates Directive storages: whole territory, so greatest large operations outside NVZs, so requirements, so no impacts capacity competitiveness impact expected for some impact expected for these operators outside NVZs. operators.

Manure Tight lid cover requirements impose Plastic sheet cover requirements Floating cover requirements impose storages: cover additional costs of €2-8 per kg/m3/year, impose additional costs of €1-2 per additional costs of €1-2 per kg/m3/year, so some competitiveness impact kg/m3/year, so some competitiveness so some competitiveness impact expected. However, this cost/impact is impact expected. However, this expected. However, this cost/impact is expected to be low proportionally to cost/impact is expected to be low expected to be low proportionally to other farm operating costs, so the proportionally to other farm operating other farm operating costs, so the impact is likely to be limited. costs, so the impact is likely to be impact is likely to be limited. limited.

Manure Total costs for using specific Total costs for using specific Measures are mostly equivalent to spreading techniques and rapid incorporation techniques and rapid incorporation BAU, so limited competitiveness technique and (possible additional time/costs for (less than ambition level A) could be impacts expected. incorporation farmers) could be high potentially high potentially impacting industry impacting industry competitiveness. competitiveness. However, more However, more efficient application of efficient application of manure could manure could reduce use of fertilisers reduce use of fertilisers and improve and improve yields thus saving costs. yields thus saving costs.

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Element A (high) B (moderate) C (low)

Quantity Extends Nitrates Directive requirement Equivalent to current Nitrates Directive thresholds to cover whole territory. Equivalent to current Nitrates Directive requirements, so no impacts Competitiveness impacts may be (absolute) requirements, so no impacts expected outside NVZ, which will impact some Member States far more Active support increases potential than others. uptake. Voluntary nature means that only operators whose competitiveness does not stand to be adversely affected will take part.

Quantity Application based on crop nutrient Application based on crop nutrient No requirements, so no impacts thresholds needs likely to have a positive impact needs likely to have a positive impact (variable) on competitiveness via more efficient on competitiveness via more efficient use of resources and reduced fertiliser use of resources and reduced fertiliser use, further aided by the support use measures provided

Timing of Extension of Nitrates Directive Equivalent to current Nitrates Directive Equivalent to current Nitrates Directive application requirements to whole territory, so requirements, so no impacts requirements, so no impacts impacts may be expected outside NVZ, Active support increases potential which will impact some Member States uptake. Voluntary nature means that far more than others. only operators whose competitiveness does not stand to be adversely affected will take part.

Areas of Extension of Nitrates Directive Equivalent to current Nitrates Directive Equivalent to current Nitrates Directive application requirements to whole territory, so requirements, so no impacts requirements, so no impacts impacts may be expected outside NVZ, Active support increases potential which will impact some Member States uptake. Voluntary nature means that far more than others. only operators whose competitiveness does not stand to be adversely affected will take part.

Farm Use of fertiliser plans has potential Use of fertiliser plans has potential No requirements, so no impacts management likely to have a positive impact on likely to have a positive impact on competitiveness via more efficient use competitiveness via more efficient use of resources and reduced fertiliser use of resources and reduced fertiliser use (i.e. input costs). (i.e. input costs). Voluntary nature means that only Voluntary nature means that only operators whose competitiveness does operators whose competitiveness does not stand to be adversely affected will not stand to be adversely affected will take part. take part. Support measures increase potential uptake, thus increasing these benefits

Land use Cost and competitiveness impacts Cost and competitiveness impacts No requirements, so no impacts management highly uncertain highly uncertain

In summary, those options which impose the greatest additional burden on operators will result in the greatest loss of competitiveness in the short-term.

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However, it should be noted that this burden could be somewhat mitigated by the benefits linked to more efficient resource use arising from the options, particularly relating to more efficient and optimal use of manure/fertiliser. It has not been possible to quantify the extent to which this might happen under the different ambition levels, but the effect may nonetheless be significant. These may potentially outweigh the costs in the longer term, once the initial costs of meeting the regulatory requirements have been met. Furthermore, the emerging opportunity to use RDP funding under CAP Pillar II to explicitly support measures aimed at reducing ammonia emissions could fully or partially alleviate additional burdens and mitigate adverse impacts on competitiveness.

Similarly, the options which impose a greater additional burden on farmers increase the driver for pro-active „reaction‟ and are likely to accelerate the uptake of options to increase competitiveness; in the medium-term the shock of greater additional burden may result in changes to industry structure which make the sectors more competitive.

Employment and Labour Market

As discussed in the introduction to the socio-economic section, options which result in increased compliance costs will present operators with a choice of how to react. Table 5.14 (below) discusses the impact on employment and labour market of the different operator reactions.

Table 5.14 Impact of Operator Reaction on Employment

Operator Reaction Impact on Employment and Labour Market

Increase in scale to counteract increase in An increased herd size will result in an increase in the labour input required. This route will be operating costs favoured by those who have capacity to expand whilst incurring additional costs that are proportionately lower. Therefore, the increase in employment is unlikely to be proportional, as lower labour inputs are required per animal with larger herds.

Use RDP funding under Pillar II New CAP reform added ammonia to the Rural Development Indicators thereby allowing Member States to develop support measures that target manure and ammonia emission reductions. In the Member States affected, i.e. the ones who will take up the measure, farmers could benefit from the additional funding aimed to cover additional costs. In such instances, the impact on employment will be neutral as funding to cover the costs of measures would allow farmers to continue their operations.

Reduce scale of operation below threshold A reduced herd size will result in a decrease in the labour input required.

Cease operations Job losses

Accept a reduction in profits Farm operators may seek to counter a reduction in profits, by reducing wages for farm workers (e.g. reduced overtime, or a shift from full-time employment to contract arrangements). For owner-operated enterprises, a reduction in profits will directly affect the income they are able to extract from the business.

The aggregate impact of all of these reactions is likely to be a net reduction in the number of persons employed in the affected industries; even if the expansion in herd size in expanding installations offsets the reduction in herd size at those installations which scale down or close, fewer employees will be required as the labour input required at larger installations is proportionately less. It should be reiterated that the closure of smaller installations and the expansion of other installations is a trend in the baseline for all the sectors under consideration; the impact of the

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options under consideration is to reinforce this trend. However, the opportunity to use RDP funding under the CAP Pillar II to support measures targeting reductions of ammonia emissions may, to a large degree, offset negative impacts (if these measures are taken up by the Member States).

The impacts of the options under consideration on employment and labour markets are summarised in Table 5.15 (below).

Table 5.15 Impact of Options on Employment and Labour Markets

Option Impacts on Employment and Labour Markets

Voluntary approach If the approach was voluntary, the impacts on employment are likely to be less than for the most expensive options (ambition level A), as operators would be free to choose whether to implement compliance measures or not. If the compliance measures are relatively expensive and would reduce the operators competitiveness to an extent that a change in modus operandi is required (closure, expansion), the operator can choose not to implement the measure and no change in employment is to be expected.

Regulatory approach The total costs under a permitting regime (or similar arrangements) would be significantly higher than the light touch approach considered in the analysis, therefore the drivers for operator reaction (e.g. closure, expansion) and the associated changes in employment would be higher as well.

Level of ambition for best The compliance costs with the lower ambition levels are significantly lower than the most stringent level (A); practices therefore the drivers for operator reaction (e.g. closure, expansion) and the associated changes in employment are higher also.

Geographical coverage Options that extend requirements that are equivalent to (or go beyond) ND ones beyond NVZs will affect more holdings than those that are limited to NVZs. In this way, more operators are likely to respond to the regulatory change in the ways identified above. The employment impacts (both positive and negative depending on the specific policy option and operator reaction) will thus be amplified relative to options that affect NVZ operators only. This applies only to operators in Member States that have not designated their entire territory as NVZ.

As mentioned above, the use of RDP funding where available would alleviate negative impacts on employment.

As with competitiveness, the magnitude of employment impacts for the specific options relative to one another are expected to be in line with the relative magnitudes of associated costs.

Standards and Rights Related to Job Quality

It is likely that the health and safety of workers at affected installations would improve due to reductions in

NH3/other gaseous emissions. This would be likely to have both positive health impacts, but will also improve job quality via reduced odour arising from more and better manure storage and improved spreading techniques. This effect is only likely to be relevant where livestock are housed.

Workers may feel that the welfare of animals is improved as a result of improved management measures and so derive greater job satisfaction.

The measures would facilitate and bring about technological innovation on some affected installations (i.e. those that are forced to implement BAT measures such as more sophisticated manure spreading processes and techniques).

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Social Inclusion and Protection of Particular Groups

The options proposed are not expected to result in any changes to the social inclusion, or protection of particular groups.

Equality of Treatment and Opportunities, Non-discrimination

The proposed changes are not expected to have any impacts in terms of equality of treatment and opportunities, non-discrimination.

Access to Social Protection, Health and Social Security and Educational Systems

The proposed changes are not expected to have any impacts in terms of access to systems of social protection, health and social services and educational systems.

Public Health and Safety

The public health benefits are primarily linked to reductions in ammonia emissions and associated health benefits. These are presented above under “Monetised Benefits”.

5.4 Summary

Numbers of Holdings and Animal Heads

There are a very large number of pig, poultry and cattle holdings in the EU (over 12 million in total based on available Eurostat data). However, the majority of these are very small and including them in any new or revised legislation is likely to provide minimal benefits and potentially at a high cost. Therefore, we have undertaken a review of the Eurostat data available for each animal species focussed on the numbers of holdings and animal heads broken down by farm size for the EU as a whole. This provides a useful proxy for the volumes of manure that could be targeted in any new or revised policy. It demonstrates for all three animal types that there are a significant number of farms with a small number of animals so there is merit in setting thresholds for coverage under any new or revised legislation.

For assessing potential compliance costs for applying best practices for manure spreading (measures focused primarily on reducing emissions to water) and administrative costs (applicable for both air or water focus), we have assumed the following thresholds of 50 heads for cattle, 10,000 heads for poultry and 150 heads for pigs. Applying these thresholds would mean that around 670,000 holdings would be captured in the EU (only around 5% of total number of holdings yet around 90% of total animal heads).

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only been taken into account in the assessment of potential compliance costs for applying best practices for manure spreading (measures focused primarily on reducing emissions to water) and administrative costs. Costs for measures targeted specifically at manure storage and spreading have been modelled based on the reference and maximum applicable uptake rates assumed in the GAINS model. This assumes that the smallest farms (below 15 LSU) would not have to apply any of the measures and thus assumes tighter thresholds than those described in this section.

Costs and Benefits of Measures Targeted at reducing Ammonia Emissions to Air

The costs associated with best practice for manure storage and spreading (i.e. those measures targeted primarily at reducing ammonia emissions to air) have been considered in two ways:

 Secondly, we have taken the reference scenario developed by IIASA for the TSAP review for the EU28 using the GAINS model and modelled separately (through manipulation of the modelling of the reference scenario) the potential additional costs and emission reductions of applying the maximum uptake rate (i.e. difference relative to BAU uptake in the reference scenario) for the following measures:

- Covered manure storage: GAINS has two measures for storage relating to low (e.g. floating foils or polystyrene) and high (e.g. concrete, corrugated iron or polyester caps) efficiency systems. These broadly correlate to our proposed best practice ambition levels C and A, respectively. GAINS assumes abatement efficiencies of 40% (low efficiency) and 80% (high efficiency) for NH3.

- Low ammonia application: GAINS has two measures for manure spreading relating to low (e.g. slit injection, trailing shoe, slurry dilution, band spreading for liquid slurry and incorporation of solid manure the day after application) and high (e.g. immediate incorporation within 4 hours of application, deep and shallow injection of liquid manure and immediate incorporation within 12 hours of application for solid manure) efficiency systems. These broadly correlate to our proposed best practice ambition levels C/B and B/A, respectively (they include measures that have been defined in more than one best practice ambition level in Table 4.10). GAINS assumes abatement efficiencies of 30-40% (low efficiency) and 80% (high efficiency) for NH3.

 GAINS assumes that farms with less than 15 LSU would not implement such measures for practical and cost reasons.

The additional costs associated with the maximum uptake of these measures are estimated to be around €20 million to €210 million per year for covered storage (low and high efficiency, respectively) and around €120 million and €100 million per year for low nitrogen application (low and high efficiency, respectively). The overall cost- effectiveness varies from €1.2 (low efficiency) to €4.2 (high efficiency) per kg of ammonia abated for covered storage and €1.4 (low efficiency) to €0.4 (high efficiency) per kg of ammonia abated for spreading i.e. the high

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efficiency spreading techniques are more cost effective than the low efficiency measures due to the increased economic bonus from increased nitrogen and subsequent reduced need for fertilisers.

The ammonia emission reductions presented are based on the modelling described above for compliance costs using outputs from the GAINS model to assess potential maximum uptake of measures for manure storage and spreading. These show a potential additional reduction in ammonia emissions from livestock (over and above the reference scenario) of around 15kt and 50kt for low and high efficiency covered storage measures, respectively, and around 80kt and 260kt for the low and high efficiency spreading measures, respectively.

These have subsequently been monetised using the damage cost functions developed under the CAFE programme giving total monetised benefits of around €0.4 billion (€0.2-0.6 bn range) and €1.2 billion (€0.6-1.8 bn range) for low and high efficiency covered storage measures, respectively, and around €2 billion (€1.1-3 bn range) and €6.5 billion (€3.4-9.7 bn range) for the low and high efficiency spreading measures, respectively, which are substantially higher than the associated costs (even if the costs for manure spreading practices targeted at water pollution and administrative burden as described below are included).

Costs of Measures Targeted at Reducing Nitrate Leachage to Water

The costs associated with best practice for manure spreading practices (i.e. those measures targeted primarily at reducing nitrate leaching to water) have been assessed separately taking into account existing uptake of best practices (based on feedback from Member States during the consultation) and existing NVZ coverage. The costs associated with ambition level A are estimated to be around €1.3 billion per year (€0.7-1.8bn range) whereas for level B they are considerably lower at around €0.2 billion per year (€0.1-0.2bn range). These cost estimates are based on the estimated number of holdings that could be affected using the thresholds described in the report. Taking a lower or higher set of thresholds would of course affect a differing number of holdings and subsequently change these costs. The cost estimates for ambition level A are considerably higher than B as in general they require application of best practice measures across the whole of a Member State‟s territory and not just in an NVZ thus capturing a much greater number of farms. No costs have been estimated for ambition level C as the majority of measures proposed targeted at reducing emissions to water can be considered BAU in most Member States e.g. they only apply within NVZs and/or are voluntary outside.

Administrative Burden (air and/or water)

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Wider Environmental Impacts

An assessment of the wider environmental impacts (i.e. beyond impacts on emissions to air) associated with the best practices defined in this study is described in Section 5.3.6. An important consideration when assessing impacts of these practices is the possibility of pollution swapping, i.e. the risk that reduced emissions to air increase risks of nutrient leaching. For example, the rapid soil incorporation of manure reduces N emissions to air but can increase the risk of leaching in water. However, the risk of trade-offs can be controlled by balancing fertilisation.

Impacts on Competitiveness and Employment

The scale and nature of impacts will be influenced primarily by farmer reaction to any options to control emissions, such as accepting a reduction in any profits, ceasing production, increasing or reducing the scale of production amongst others. Overall, operators of smaller farms (depending on any thresholds applied) and/or those Member States not already applying more stringent measures than existing EU legislation are expected to be the most affected. Conversely, Member States that already impose strict national requirements on manure storage, spreading and management could benefit in the short-term as a result of their relatively advanced position. Overall, the introduction of EU wide requirements will result in establishing a level-playing field among different Member States.

The options which impose the greatest additional burden on operators in terms of costs will result in the greatest loss of competitiveness in the short-term. However, it should be noted that this burden could be somewhat mitigated by the benefits linked to more efficient resource use arising from the options, particularly relating to more efficient and optimal use of manure/fertiliser. Furthermore, the emerging opportunity to use RDP funding under CAP Pillar II to explicitly support measures aimed at reducing ammonia emissions could mitigate adverse impacts on competitiveness and employment.

It has not been possible to quantify the extent to which this might happen under the different ambition levels, but the use of RDP funding and additional benefits associated with the reduced use of fertilisers may fully or partially alleviate additional burdens. Furthermore, the options imposing a greater additional burden on farmers increase the driver for their pro-active response, e.g. to increase productivity, apply for RDP funding etc., and are likely to accelerate the uptake of measures to increase competitiveness. Even in those instances where available RDP funding and/or benefits associated with the reduced use of fertilisers are not sufficient to compensate the additional costs, the shock of greater additional burden may result in changes to industry structure which make the sector more competitive in the medium-term.

In the context of employment, the aggregate impact of additional costs of any options is likely to be a net reduction in the number of persons employed. The magnitude of employment impacts for the specific options relative to one another are expected to be in line with the relative magnitudes of associated costs. However, the opportunity to use RDP funding under the CAP Pillar II to support measures targeting reductions of ammonia emissions may, to a certain degree, offset negative impacts and prevent job losses (if these measures are taken up by the Member States).

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6. Conclusions

6.1 Conclusions

Based on the analysis and research undertaken for this study the following findings and conclusions can be made:

Baseline Definition

1. Whilst there is no official reporting of the amount of manure produced across the EU, a recent report estimated that the entire manure production in the EU27 is about 1.4 billion tonnes102.

2. Emissions of ammonia to air from the spreading of manure across the EU are estimated to represent around 24-29% of the total emissions of ammonia from agriculture (around 800kt) so is a major source for this pollutant. The spreading of manure and other related activities such as storage also contribute to emissions of other air pollutants and greenhouse gases as well as impacts on other environmental media including water.

3. Key legislation affecting manure management includes the Nitrates Directive and other freshwater policies (e.g. Water Framework Directive), the Industrial Emissions Directive (only for poultry and pig farms above specific thresholds), the National Emission Ceilings Directive soon to be revised (includes an emissions ceiling for ammonia which is in effect a cap on agriculture emissions) and the Common Agricultural Policy (also under reform). Some Member States (see Table 4.11 for further details) are taking actions over and above EU legislation, but it is clear that there is a significant potential to do more in most MS.

Policy Options

4. There are a number of possible policy options for controlling emissions from manure spreading that cover three main elements. In particular, the policy options considered vary in terms of the overall framework, i.e. mechanism for control (e.g. voluntary, revisions to existing legislation, new legislation), the scope of coverage in terms of thresholds and the stringency of requirements i.e. best practices measures that would be required.

5. The different mechanisms by which specific measures could be implemented at an EU level include introduction or expansion of existing voluntary instruments, revision of existing legislation (IED, NECD and Nitrates Directive), introduction of new legislation (either covering only manure spreading/storage or a more comprehensive nitrogen management directive taking an integrated approach to nitrogen combining relevant requirements from other pieces of legislation), extension of the scope of cross-compliance under

102 Agro Business Park, 2011, Manure Processing Activities in Europe

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CAP Pillar I to include best practice on manure storage spreading or making use of existing opportunities to fund ammonia abatement under the Rural Development Programme (CAP Pillar II). There are a number of advantages and disadvantages associated with each design option as summarised in Section 4.3.

6. The key issues taken into consideration while considering alternative mechanisms included the certainty of impact (i.e. voluntary versus mandatory), potential conflicts between instruments targeted specifically at air (e.g. NECD) or water (e.g. Nitrates Directive) emissions, associated monitoring requirements and ease of introducing the mechanism. Overall, voluntary instruments offer uncertain uptake rate and, hence, environmental benefits. Introduction of a new legislation aimed to regulate specifically spreading of manure removes the need to “fit” the best practices into existing legislation which already have specific defined objectives. However, it is unlikely to constitute a feasible policy option in the short term due to potential conflicts and duplication with the existing legislation and the time required to develop and adopt such legal acts.

7. Revision and extension of the scope of IED or Nitrates Directive are not considered feasible options in the short-term as these directives are unlikely to be renegotiated in the near future. Furthermore, while the IED considers emissions to all environmental media, cattle are currently excluded from its scope and it is limited to existing farm size thresholds. To effectively target manure spreading would probably require its inclusion as a standalone activity in Annex I of the Directive. However, the recent IED Article 73 review report concluded that the Commission does not intend to include cattle farms within the scope of the Directive or amend any other elements of the Directive in relation to intensive livestock farms as the inclusion of cattle would deliver somewhat limited environmental benefits while potentially imposing significant administrative and compliance costs to a large number of farms. The report did recognise the significance of emissions from manure spreading but indicated that the IED itself is not the most appropriate instrument. Extending the scope of the Nitrates Directive to other environmental domains, on the other hand, may blur the specific objectives of the Directive. In particular, it may not be feasible to include air specific measures in an existing instrument targeted at water quality and vice versa.

8. In the short term, it therefore appears that the current revision of the NEC Directive offers the most feasible route for promoting a broader uptake at EU level of measures targeted at reducing emissions to air from manure storage and spreading (introducing measures for water would blur the aims and objectives of the Directive). This could be via the inclusion of implementing measures alongside a revised emission ceiling for ammonia. The other main short term option is to take stock of the possibility to fund ammonia abatement measures under the RDP under CAP Pillar II, following the recent agreement to include ammonia in one of the main priority areas of the instrument.

9. In the longer term, options could include the revision of the IED to target manure spreading more actively than at present although this appears to have been ruled out considering the Commission‟s conclusions in the Article 73 review report. Other options could include the revision of the Nitrates Directive to require more specific measures within NVZs, new legislation targeted specifically at manure storage and spreading or the development of an integrated nitrogen management directive (Option 4.2). The latter options may provide a good way of targeting both emissions to air and water in an integrated way. Inclusion of the best

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practice manure spreading measures under the CAP Pillar I cross-compliance requirements could also be feasible post 2020.

10. A further issue to consider for the development of possible policy options is the overall scope of coverage i.e. which size and types of farms may be affected. The scope of coverage of a particular option could be defined in two main ways: geographical and/or numerical (animal places, livestock units or manure volumes). Whilst a LSU approach might be the most equitable way of defining thresholds (farms with similar environmental impacts would be captured) it is more complex than the animal places approach which is already applied within the IED and impacts differently on grazing (ruminant) and non-grazing (monogastric) animals. Defining the farms captured by the policy in terms of either (a) the volume of manure being produced (if targeting those farms producing the manure) or (b) the volume of manure being spread (if targeting those farms spreading the manure) constitute an alternative approach. The advantage of the approach would be ensuring that those farms spreading large volumes of manure would be captured by the policy even if the manure is provided by a number of smaller farms that would perhaps not be captured individually by any size thresholds. However, similarly to the LSU approach it would be quite challenging to regulate as it would require precise data on the volumes of manure being produced and/or spread by a particular farm which is likely to vary from year to year. Pursuing a LSU or animal places approaches but requiring the farms producing the manure to subsequently request their contractors to spread the manure appropriately, e.g. using a manure transfer note, offers a potentially feasible solution.

11. Defining the best practice in relation to manure storage, spreading techniques (including equipment) and practices (e.g. quantities, areas and timing) constitute the remaining element of the design of alternative policy options. A review of relevant literature and existing practices in each of the Member States suggests different levels of ambition, while the consultation undertaken for the study, highlights that some Member States are already applying the best practices described in the report. However, it should be noted that this is based on a review of consultation responses and should not be considered comprehensive as such, not least because some Member States did not respond to the consultation and/or only provided limited information. In general, best practices in relation to manure storage and spreading techniques, including requirements to have a cover on manure storages, employing low-emission application techniques and rapid incorporation of the manure/slurry are more relevant to tackling air emissions, while best practices in relation to manure management, such as restricting areas and times of application are more relevant to avoiding nitrate leaching to water (see Table 4.10 for further details of best practices).

Analysis

12. There are a very large number of pig, poultry and cattle holdings in the EU (over 12 million in total based on available Eurostat data). However, the majority of these are very small and including them in any new or revised legislation is likely to provide minimal benefits and potentially at a high cost. Therefore, we have undertaken a review of the Eurostat data available for each animal species focussed on the numbers of holdings and animal heads broken down by farm size for the EU as a whole. This provides a useful proxy for the volumes of manure that could be targeted in any new or revised policy. It demonstrates for all three animal types that there are a significant number of farms with a small number of animals so there is merit

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in setting thresholds for coverage under any new or revised legislation. For assessing potential compliance costs for applying best practices for manure spreading (measures focused primarily on reducing emissions to water) and administrative costs (applicable for both air or water focus), we have assumed the following thresholds of 50 heads for cattle, 10,000 heads for poultry and 150 heads for pigs. Applying these thresholds would mean that around 670,000 holdings would be captured in the EU (only around 5% of total number of holdings yet around 90% of total animal heads). Costs for measures targeted specifically at manure storage and spreading (i.e. those focussed on reducing emissions to air) have been modelled based on the reference and maximum applicable uptake rates assumed in the GAINS model. This assumes that the smallest farms (below 15 LSU) would not have to apply any of the measures and thus assumes tighter thresholds than those described above.

13. The costs associated with best practice for manure storage and spreading (i.e. those measures targeted primarily at reducing ammonia emissions to air) have been considered in two ways:

 Firstly, a comparison of the cost-effectiveness of different abatement measures targeted at the agriculture sector has been undertaken based on a range of sources. This shows how manure storage and application measures tend to be at the lower end of the cost spectrum i.e. they are relatively cost effective, certainly more so than a number of other measures for the livestock sector. Some of the application measures can even show a negative overall cost as, when applied properly, manure can reduce the need for purchasing fertilisers;

- Low ammonia application: GAINS has two measures for manure spreading relating to low (e.g. slit injection, trailing shoe, slurry dilution, band spreading for liquid slurry and incorporation of solid manure the day after application) and high (e.g. immediate incorporation within 4 hours of application, deep and shallow injection of liquid manure and immediate incorporation within 12 hours of application for solid manure) efficiency systems. These broadly correlate to our proposed best practice ambition levels C/B and B/A, respectively (the low and high efficiency measures in GAINS include techniques that have been defined in more than one best practice ambition level in Table 4.10). GAINS assumes abatement efficiencies of 30-40% (low efficiency) and 80% (high efficiency) for NH3.

 The additional costs associated with the maximum uptake of these measures are estimated to be around €20 million to €210 million per year for covered storage (low and high efficiency, respectively, broadly correlating to our ambition levels C and A) and around €120 million and €100 million per year for low nitrogen application (low and high efficiency, respectively, broadly correlating to our ambition levels C/B and B/A). The overall cost-effectiveness varies from €1.2 (low efficiency) to €4.2 (high efficiency) per kg of ammonia abated for covered storage and €1.4 (low efficiency) to €0.4 (high

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efficiency) per kg of ammonia abated for spreading i.e. the high efficiency spreading techniques are more cost effective than the low efficiency measures due to the increased economic bonus from increased nitrogen and subsequent reduced need for fertilisers..

14. The ammonia emission reductions presented are based on the modelling described above for compliance costs using outputs from the GAINS model to assess potential maximum uptake of measures for manure storage and spreading. These show a potential additional reduction in ammonia emissions from livestock (over and above the reference scenario) of around 15kt and 50kt for low and high efficiency covered storage measures (broadly correlated to our ambition levels C and A), respectively, and around 80kt and 260kt for the low and high efficiency spreading measures (broadly correlated to our ambition levels C/B and B/A), respectively.

15. These have subsequently been monetised using the damage cost functions developed under the CAFE programme giving total monetised benefits of around €0.4 billion (€0.2-0.6 bn range) and €1.2 billion (€0.6-1.8 bn range) for low and high efficiency covered storage measures (broadly correlated to our ambition levels C and A), respectively, and around €2 billion (€1.1-3 bn range) and €6.5 billion (€3.4-9.7 bn range) for the low and high efficiency spreading measures (broadly correlated to our ambition levels C/B and B/A), respectively, which are substantially higher than the associated costs (even if the costs for manure spreading practices targeted at water pollution and administrative burden as described below are included).

16. The costs associated with best practice for manure spreading practices (i.e. those measures targeted primarily at reducing nitrate leaching to water) have been assessed separately taking into account existing uptake of best practices (based on feedback from Member States during the consultation) and existing NVZ coverage. The costs associated with ambition level A are estimated to be around €1.3 billion per year (€0.7- 1.8bn range) whereas for level B they are considerably lower at around €0.2 billion per year (€0.1-0.2bn range). These cost estimates are based on the estimated number of holdings that could be affected using the thresholds described in the report. Taking a lower or higher set of thresholds would of course affect a differing number of holdings and subsequently change these costs. The cost estimates for ambition level A are considerably higher than B as in general they require application of best practice measures across the whole of a Member State‟s territory and not just in an NVZ thus capturing a much greater number of farms. No costs have been estimated for ambition level C as the majority of measures proposed can be considered BAU in most Member States e.g. they only apply within NVZs and/or are voluntary outside.

17. Potential administrative costs associated with any new or revised legislation targeted at controlling emissions from manure management have been estimated based on a light touch approach to regulation whereby farmers would be required to maintain records of manure production, storage, processing and application including evidence of any transfers to other farms and that it has subsequently been stored and applied in line with the best practice requirements. Regulators are assumed to undertake a small check of records each year. Total administrative costs are estimated to be €18-37 million per year for farmers and regulators. Irrespective of whether an option is targeted at either water and/or air emissions, the administrative costs are expected to be broadly the same as the types of records to be maintained and checks made will be similar.

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18. An assessment of the wider environmental impacts (i.e. beyond impacts on emissions to air) associated with the best practices defined in this study has been undertaken and is presented in Section 5.3.6. An important consideration when assessing impacts of these practices is the possibility of pollution swapping, i.e. the risk that reduced emissions to air increase risks of nutrient leaching. For example, the rapid soil incorporation of manure reduces N emissions to air but can increase the risk of leaching in water. However, the risk of trade-offs can be controlled by balancing fertilisation.

19. An assessment of potential socio-economic impacts has been undertaken and is presented in Section 5.3.7. The scale and nature of impacts will be influenced primarily by “operator reaction” to any options to control emissions. Operators of smaller farms (depending on any thresholds applied) and/or those Member States not already applying more stringent measures than existing EU legislation are expected to be the most affected.

6.2 Uncertainties and Limitations

There are a number of uncertainties and limitations associated with the information presented in this study including the following:

 Absolute volumes of manure produced in each Member State are relatively uncertain. The data presented in this report are based on a study where an inventory of manure production across the EU has been compiled using relatively simplistic assumptions and approaches. A review of nitrogen excretion factors has shown significant variation between sources and Member States;

 Current application of best practices in each Member State. Whilst we have gathered a lot of useful information via a review of literature and consultation with the Member States, there is still significant uncertainty associated with the current application of particular techniques and practices;

 Locations of farms i.e. relative to NVZs. In the absence of any detailed information, a linear relationship between the % coverage of an NVZ in each Member State and the distribution of farms by type has been assumed;

 Compliance cost estimates for storage and spreading measures are presented separately for maximum uptake of all four measures as it is not possible to simply combine the results for each as in some cases the measures may be mutually exclusive (e.g. you could not have maximum uptake of both low and high efficiency options) and applying measures for storage can impact on emissions from application (due to an increase in available nitrogen in the manure). It was not within the scope of this study to develop a more complex model to take into account these interactions to avoid overlaps with the GAINS modelling. The approach taken provides an indication of the maximum additional costs and emission reductions that could be realised. Furthermore, GAINS models a number of combinations of different measures targeted at different phases of livestock rearing i.e. feeding, housing, storage and application. These have not been considered in the analysis;

 There is inevitably some uncertainty around the cost estimates and, in particular, the additional time estimates for farmers to comply with differing levels of ambition for best practices;

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 Damage cost functions for valuing ammonia emission reductions have been applied to estimate indicative health and environmental (crop) benefits. Whilst these are appropriate for a high level review such as this they do have a number of limitations not least the fact that they don‟t take into account the exact location where emissions are reduced (i.e. reductions close to densely populated areas will result in greater benefits than if they occur in rural areas) and the values available are quite old (2005). A more accurate approach would be through the use of emissions and air quality dispersion modelling but this is considerably more data, resource and time consuming.

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Appendix A Literature Review Summary

Data Source Summary

Phase I of the Impact Assessment The report assesses the likely impacts of the proposed revision of the IPPC Directive in relation to of Proposals for a Revised IPPC intensive agriculture installations in the UK. It focuses in particular on the proposed changes relating to Directive - Part 2: Intensive the definition of intensive poultry installations and the spreading of manure. This included an Livestock Farming (2008, final assessment of the costs and benefits of the extension of the IPPC Directive to require BAT for manure report developed by AMEC for spreading. Defra)

IIASA‟s GAINS model The Greenhouse Gas and Air Pollution Interactions and Synergies (GAINS) model provides information on economic activities (causing emissions), emisison control strategies (scenarios), control costs and impacts on the environment and human health. It covers a range of pollutants including NOx, N2O and NH3 (environmental and human health). The model contains a lot of data relevant to this project such as: updated excretion factors and emissions factors, the share of manure being spread on grassland or arable land.

Service Contract on Monitoring The report looked at updating the GAINS assessment model in line with recent developments in relation and Assessment of Sectorial to reduction of ammonia emissions from agriculture and their cost effectiveness. Implementation Actions It presents adjusted data on emission removal efficiencies and applicabilities, and emission control (ENV.C.3/SER/2011/0009) costs. It focuses on different relevant areas such as: Emissions from agriculture and  Animal feeding; their control potentials (Alterra,  Animal housing; 2012)  Manure handling; and  Nitrogen management An economic evaluation of The report focuses on greenhouse gas (methane and nitrous oxides) emissions from agriculture and in emission reductions of nitrous particular manure management. It provides a differentiated approach for cool and temperate climate oxides and methane in agriculture countries. in the EU (2001)

Survey of wastes spread on land The survey looks at the types and quantity of materials being spread on fifteen Member States‟ territory. (2001) Manure from farm animals is one of the most prominent waste being spread on land. The report contains recommendations for controls of wastes such as :classifying wastes into categories to each of which certain requirements for handling are attached, the registration of waste for landspreading or setting a permit system for landspreading.

Impact of the Nitrates Directive on The report assesses the effects of measures contained in the Nitrates Directive on gaseous nitrogen (N) gaseous N emissions – effects of emissions to the atmosphere. The reports contains a special method for calculation of excretion measures in nitrates action coefficient for dairy cattle taking into account milk yieds and grasslands yields at regional level. The programme on gaseous N MITERRA-Europe was used for the modelling of the various scenario developed. emissions (2010)

Recommendations for establishing The report is split in four parts: Action Programmes under  Part A looks at the impact of pedo-climatic conditions and their impacts for N leaching and Directive 91/676/EEC concerning run-off risk potention; the protection of waters against pollution caused by nitrates from  Part B looks at the link between farming practices and the risks for leaching/run off towards agricultural sources (2011) waters and eutrophication processes ;  Part C is focusing on soil and the processes that influence nutrient leaching and run off that could lead to pollution of waters and eutrophication processes ; and  Part D presents recommendation on establishing Action Programme. The recommendations are differentiated for each pedo-climatic zones identified in Part A.

Data Source Summary

Manure processing activities in The report gathered information on: Europe (2011)  Manure processing activities being carried out in Europe;  The different manure treatment techniques available;  The end and by-products generated by manure processing activities;  The economic feasibility and the environmental performance of certain treatment technologies; and  Future trends for manure processing activities.

Intensive livestock BREF (2003) The BREF is currently under review. A first draft was made available for consultation, but it did not and proposed revisions (2012) as include BAT conclusions. At this stage, the second draft has yet to be finalised. well as any relevant supporting The current BREF document: information  Sets out the major activities and production systems found in intensive poultry production, including housing, feeding startegy, rearing of animals, collection and storage of manure, on- site treatment of manure etc.  BAT conclusions.

ALTERRA/IIASA (2007): Alterra gathered data on: Integrated measures in agriculture  Total number of animals and installations by MS for EU 25 (2003 data from Eurostat). to reduce ammonia emissions  Information on national livestock legislation  Detailed breakdown of excretion factors for different livestock. IIASA assessed the costs and the emissions reductions that could be achieved by extending the IPPC Directive, building on the results of the work conducted by Alterra.

EUROSTAT data The Eurostat database includes an important number of data useful for our study. Some of the data necessary for the analysis of the social and economic impacts on employment, labour market and competitiveness of the options were extracted from the Eurostat database. Eurostat also hold data on the total number of holdings in Member States and the number of heads of livestock they contain.

Supporting Guidance Document Further details are included in Section 3.4 on relevant legislation developed as part of proposals for  Range of measures for controlling emissions of ammonia from agricultural sources. a revised Annex IX of the Gothenburg Protocol  Costs of implementation by measure (data not available for all measures).

 Benefits (in terms of NH3 emission reduction).  Proposed revised version covers poultry, pigs and cattle.

JRC (2008) Evaluation of the The report provides an estimate of the net emissions of GHGs and ammonia from livestock sector in the livestock sector's contribution to EU-27 according to animal species, animal products and livestock systems following a food chain the EU greenhouse gas emissions approach. (GGELS)

Member States submissions under Member States submissions under CLRTAP include total ammonia emissions from manure CLRTAP management from poultry, cattle and pigs.

Member States submissions under Member State submissions under the UNFCC include emissions of nitrous oxide and methane the UNFCCC emissions from manure management from poultry, cattle and pigs.

European Commission‟s Impact The report assessed the impact of the application of BAT to the spreading of manure. The impacts were Assessment (IA) of the IED assessed through the use of three models: RAINS, MITERRA Europe and CAPRI and concluded that applying BAT to the spreading of manure would lead to significant reduction of emissions of ammonia and provide an appropriate integrated management of nitrogen.

Data Source Summary

Other IED review reports The first report looked at the possibility to extend the scope of the IED to include „intensive rearing of developed by AMEC for the cattle‟ as one of the regulated activities. The reports re-appraised the assessment of the impacts. Commission (2012): The second report reviewed the possible impacts of applying differentiated thresholds for the rearing of - Collection and analysis of data to poultry sprecies. It also looked at theparticular situation of installations which have within a single support the Commission in installation, a mixture of livestock. reporting in line with Article Both reports‟ assessments are based on updated data, gathered from Member States consultation. 73(2)(b) of Directive 2010/75/EU on industrial emissions on the need to control emissions from the intensive rearing of cattle - Collection and analysis of data to inform certain reviews required under Directive 2010/75/EU on industrial emissions (IED): (a) Differentiated thresholds for the rearing of different poultry species; and (b) Capacity thresholds for the simultaneous rearing of different types of animals currently in the scope of the IED within the same installation

Study on variation of manure N The report focused on gaining a better understanding of the factors that influence the recovry of the efficiency throughout Europe nitrogen contained in manure by crops, and how these factors vary among the regions of the EU. (2010) The report looks at a diversity of factors such as soil type, crop and rotation type, the time of application and closed period, the climate, the application method, the types of manure and the time-lag in manure availability.

Workshop proceedings A lot of conferences and workshop have been organised on the management of manure from livestock. • Workshop “Managing The proceedings of these worshop were reviewed. Presentations include: livestock manure for sustainable  Presentations on Member States legal system and EU legislation regarding animal manure agriculture”, 24-25 November 2010 (presenation by the Commission on the role of the Nitrates Directive in relation to manure , management); • Workshop on best  Presentation of techniques available for the recovery of nutrients and energy from manure; practices in manure management in livestock production on farms,  Assessment of the state of livestock manure production and utilisation in the EU; 19 to 20 December 2011, Zagreb,  Presentation on BAT in relation to manure; Croatia  Some of the presentations includes case study focusing on some MS or regions (such as • Workshop Reduced Catalonia, Brittany or Poland and the Netherlands). discharge: towards full recovery of nutrient and energy from animal manure • Workshop Reconciling environmental and sanitary risks in the management of livestock wastes, October 2011

Data Source Summary

Publications A lot of material has been published in relation to manure management. • Burton and Turner Academic paper offer important information on manure management strategies and approach taken in (2002) Manure management – specific Member States. Treatment strategies for The publication in relation to the ReUseWaste project looks at the role of agriculture and manure sustainable agriculture, 455 pp. production for the pollution in EU-27 • Eric Lichtfouse (2007) Soil, a sponge for pollutants • Oenema (2012) Livestock production and manure management in EU-27, presentation for the ReUseWaste project • Oenema et al. (2004) Environmental effects of manure policy options in The Netherlands

EU Research projects (FP7)  The INEMAD project started in April 2012 and is interested in re-thinking the relationship • INEMAD - Improved between crops and livestock production. Processing is proposed to be linked with crop and Nutrient and Energy Management the livestock production, in order to increase agricultural productivity while reducing external through Anaerobic Digestion energy input and closing nutrient cycle. • EFFICIENTHEAT -  The EFFICIENTHEAT project aim is to develop an affordable technology for all types of Integrated and Cost-Effective farmers which reduces the transportation cost, currently accountings for almost 60% of the Solution to reduce the volume of total processing costs. Pig Slurry, minimize Pollutant Emissions and Process Energy Consumption

Member State rural development To be investigated following the submission of this report. plans

Member State implementation The latest implementation report available (SEC(2011)909) is based on information submitted by reports under the Nitrates Directive Member States referring to the period 2004-2007. The report was accompanied by maps showing nutrient pressures from agricultural sources, water quality and designated nitrate vulnerable zones. During this period, the spreading of manure was reported to have slightly decreased. The highest nutrient pressure identified were in the Netherlands, in Belgium (Flanders) and in Franec (Brittany). The report mentions that 3 infringements cases are open on designation of vulnerable zones (Spain) and contents of the action programme (Spain, France, Luxembourg). More recent country reports are also available for most MSs on the Reporting Obligations Database although some are locked and not available for public access (http://rod.eionet.europa.eu/obligations/106/deliveries?id=106&id=106&tab=deliveries&tab=deliveries&d- 4014547-p=1&d-4014547-o=1&d-4014547-s=1).

Appendix B Questionnaire sent to Member States

Questions

1. What legislation is in place at a national level targeted at reducing impacts on emissions to air and/or water as well as impacts on other environmental media (e.g. soil) from the spreading of manure? We have undertaken an initial review of available data on national legislation in place affecting manure spreading; this is summarised for your Member State below.

MS Summary of Information about Current Relevant Legislation on Manure Source

Please provide information on the requirements set in the legislation focussing on where any requirements go beyond those in existing EU legislation (e.g. Nitrates Directive) as well as how it is applied in practice (e.g. use of general binding rules, permitting). 2. What voluntary or any other systems/agreements (if any) are in place for controlling emissions to air and/or water from the spreading of manure in your Member State (e.g. codes of good practice, quality assurance schemes)? 3. Have any assessments been undertaken of the potential and/or actual impacts of the above national legislation and/or other agreements? If so please provide details. 4. Has best practice or something similar for controlling emissions from the spreading of manure been defined in your Member State? If so, please provide details of this as well as any data on the costs and emission reduction potential of these practices. In addition, are you able to provide any data on current application of these practices in your Member State? 5. Are you able to provide data on the volumes of different types of manure spread on different land types and the volume of manure exported (if any) for other uses (e.g. combustion)? 6. Do you have any other comments on this study?

If you would like to discuss any of the questions in this proforma please contact the person named below. Ben Grebot AMEC Environment & Infrastructure UK Limited 17 Angel Gate, City Road, London EC1V 2SH, UK Direct +44 (0)20 7843 1414 [email protected]

Appendix C National Legislation Affecting Member States

replies checked DK all the country is considered as a NVZ http://rhone-alpes.synagri.com/synagri/pj.nsf/TECHPJPARCLEF/06843/$File/09-Objectifs-59.pdf?OpenElement seems to go above the legislation seems to go below information is missing

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:31991L0676:EN:HTML

MS policy Assessment Period of application Environmental conditions for application Procedure for application Amount of livestock manure applied Manure storage Optional measures Source criteria Stricter recommendation and whether phorphorus Duration and timing Short distance to water bodies, no specification for slope (thresholds) More detailed recommendations. Duration evaluation is taken into account. The assessments of actual A balanced fertilisation is required. The application impacts of national legislations of more than 100kg N/ha/yr must be shared. There and also voluntary measures are provisions regarding the quantity to spread have been undertaken: depending on the timing. • Within the implementation of Organic fertilizer on land without land coverage Lebensministerium (website): Austria has implemented the Nitrates Directive with an ordinance, the Austrian Nitrates Action the Nitrates Directive reports should be incorporated within 4 hours but at least http://www.lebensministerium.at/wass Program. The program was recently undergoing a revision and adopted in 2012 (4th Action have been prepared every four within 24 hours. er/wasser- Program). Austria has decided already from the very beginning to implement the Action oesterreich/wasserrecht_national/recht years according to the The Action program provides tables on the quantity The main legal aspect to link livestock to the Program to the whole territory. The background is, that it was always the intention of Austria 15 October/15 November to 15/28 February. _gewaesserschutz/APNitrat2012.html Directive presenting The application of nitrogen fertilizers is forbidden on water-saturated, flooded, to spread per type of crop. agricultural land is the provision within the EU to achieve a well-balanced protection for the whole country and not to focus exclusively on For permanent grassland and meadow, the spreading and monitoring results of water frozen and snow-covered soil. Further best practice information on manure nitrates directive with a maximum application rate 6 months – T he storage capacity must be 6 months. individual problem areas (nitrate vulnerable zones, which would result in a rather small of fertilizers is forbidden from 30 November to 28 http://eagri.cz/public/web/en/mze/sub quality and also an assessment When slope exceed 10%, the application of nitrogen fertilizers is forbidden within management (application time respecting soil and of 170 kg N/ha stemming from manure. The capacity can be reduced in specific cases (storage percentage of Austria’s territory) as we are firmly convinced that this “entire territory February. Records on the fertilisation have to be sidies/cross-compliance/good- Austria AT measures. The current report 20m of water bodies, nitrogen input must not exceed 100 kg N/ha and must be weather conditions, application planning, dilution The decree also provides tables to calculate the in other places) but must be at least 2 months. There approach” is all in all more beneficial from the environmental side as it sets out legal For arable land, the spreading of fertilizers is provided. agriculture-and-environmental.html from 2012 can be downloaded incorporated. There are also particular conditions for late spring crops. of liquid manure, etc.) is provided by the Austrian amounts of nitrogen produced by each type of are specifics requirements for the vessels and the regulations for all farmers in Austria. forbidden from 15 October (30 November for solid http://www.lebensministerium.at/dms/ under: The distance to water bodies depends on the water body, the slope and the advisory services to the farmer directly via animal for different farming systems or that can be storage in fields (distance to water bodies, etc. ) Thus, Austria applies an action program on the whole territory and not only for nitrate manure) to 15 February. Exception for early crops is lmat/wasser/wasser- http://www.lebensministerium presence of buffer strip. The distance are from 2.5m to 20m. brochures or in form of seminars, programs and spread on land depending on the crops grown. vulnerable zones, which means for all waters. However, the whole territory approach does not .at/wasser/wasser-eu- possible. courses oesterreich/wasserrecht_national/recht mean that the whole territory is a nitrate vulnerable zone. In contrary for a large part of Austria international/europaeische_wa (http://www.maschinenring.at/default.asp?id=124 _gewaesserschutz/APNitrat2012/AP- this is definitely not the case. sserpolitik/Nitratbericht_2012. 222&tt=MR_STM_15_R3&ci=&medium=MR_STM_ Nitrat-2012-konsolidierte- html 15). Fassung/AP%20Nitrat%202012%20kons The report (summarizing the Guidelines for a balanced fertilization are in place in olidierte%20Fassung.pdf National Reports) of the Austria which provides general standards for European Commission on the fertilization (including manure). These are Nitrates Directive can be especially relevant for controlling emissions to downloaded under: water, as they provide information (in line with the Wallonia: Wallonia: In non vulnerable zone, the total quantity of Wallonia : In Wallonia, an order (arrêté) adopted in 1991 regulated the modalities for the spreading of In non vulnerable zone, spreading less than 6m from watercourses, in case of soil Wallonia : nitrogen (organic + mineral) applied in one year 6 months - Slurry, liquid manure and dung water must farm effluents (Arrêté de l’Exécutif regional wallon réglementant les modalités d’épandage des flooded or under snow and before or after a legume is forbidden. Spreading on a 15th October to the 15th January / 1st February, must not exceed 250 kg per ha of crops and 350 kg be stored in watertight tanks with six months’ capacity. effluents d’élevage, M.B. 01/10/1991, p.21503). However, this order was repealed by the frozen soil in only allowed to manure and compost and on bare soil to manure, depending on land use and type of manure. per ha of grassland, as an average for the farm. Wallonia : On the farm, solid farm manure must be stored on a Walloon Government Order (AGW, arrêté du gouvernement wallon) of 10 October 2002, art. compost and mineral nitrogen. Spreading on land with a slope of more than 15% is For crops: In vulnerable zone, the quantity of mineral nitrogen The annual quantity of organic nitrogen is 115 kg N watertight concrete surface with run-off collection. In 46, 1°. The Nitrates Directive is implemented in Wallonia by means of the Sustainable Nitrogen allowed for mineral nitrogen. Wallonia : Spreading of mineral nitrogen, slurry, liquid manure, applied is not restricted. Moreover, permanent per ha for crops and 230 kg per ha for grass.In case the case of wet dung the storage area must be Management Scheme for Agriculture (PGDA) which was adopted on 10 October 2002. The In vulnerable zone, in a cultivated field where more than 50% of the total area or an In vulnerable zones 75% of the area poultry effluent and soft manure is forbidden from grassland can be tilled between 1 February and 31 of vulnerable zone, the spreadable organic nitrogen covered. AGW of 3 March 2005 integrated the PGDA into Book II (regarding water) of the Environmental area of more than 0.50 ha has a slope of 10% or more, it is prohibited to spread harvested before 1 September which Wallex: the 15th October to the 1st February. There is no ban May only. Also, in view of the big risk of increasing to be taken into account is the lowest value Manure may be stored in the field under certain Code. The PGDA was modified by AGW of 15 February 2007 which led to ‘PGDA 2’, this latter mineral fertiliser if the crop is a spring crop or similar. This prohibition does not will be followed by a spring crop the http://wallex.wallonie.be/index.php?do for solid manure and composts. the leaching, after tillage it is prohibited to: calculated either on the basis of the 115/230 limits conditions: being again modified by AGW of 31 March 2011 (‘PGDA 2 bis’). apply in the following cases: following year must be planted with c=3461&rev=2790-1591&from=rss For grassland: - Spread organic nitrogen for two years after tillage; or on the basis of the 170 limit. - The heap must be more than 20 metres from any For Flanders, agriculture is characterised by an intensive use of the limited space, leading to - If there is a 6-metre grass strip at the foot of the slope and round the sides of the nitrate catch crops by 15 September NitraWal : Belgium BE Spreading of mineral nitrogen is forbidden from the - Spread nitrogen in the first year; Flanders: sewer, water body or well high consumption levels of mineral fertiliser, concentrate and pesticides, which in turn leads to plot. and destroyed after 30 November. Note http://www.nitrawal.be/upload_files/3. 15th October to the 1st February. - Sow vegetables or legumes (except as grassland 170 kg N/ha manure (including grazing) is allowed. - Heaps should not be located in low-lying areas a high pressure on the environment. Flanders has implemented the Flemish Fertiliser Action - If there is a meadow, a grass in mono- or mixed cropping, a set-aside area or a that flax and peas are disregarded when 1.1%20PGDA/NW_FeuilletPGDA_2010( Spreading of slurry, liquid manure, poultry effluent cover) for two years after tillage. Only P2O5 from organic fertiliser is allowed (with - The heap should be relocated each year Plan (Mestactieplan or MAP) in 2007 with additional and / or stricter limitations for nature- wooded area at the foot of the slope. calculating the 75% ratio. UK)02.pdf and soft manure is forbidden from the 15th October This does not apply to temporary grassland. some minor exceptions). P2O5 is limited to 100 - Poultry dung and manure must have a dry matter and forest areas, and phosphate-saturated areas. The entire territory is considered as an NVZ. - If no side of the plot is less than 30 metres from surface water. Flanders: to the 15th January. From the 15th January to the 1st Flanders: kg/ha on grass, and 85 kg/ha on maize. In content of more than 55%. The storage time must not The current action program (MAP4) is in place from 2011 until the end of 2014. Engagements Moreover, It is not permissible to spread manure on soil if the surface temperature No information available February, reduced spreading is allowed (up to 80kg N Maximum amount of N depends on the soil type phosphate-saturated areas this is limited to 40 exceed 1 month. made in the action programs are translated in legislation by the ‘Manure Decree’ (Decree of is below zero for a continuous period of more than 24 hours. per ha). (sandy vs. non-sandy soils), and on type of crop. For kg/ha. - Cattle manure must be dry. The storage time must 22nd December 2006 for the protection of waters against pollution by nitrates from Flanders: Flanders: grass, a max of 350 kg N/ha (including max. 170 kg not exceed 8 months. agricultural sources).The MAP is not publicly available, at least in English. No information available. 1st September to the 15 February for both chemical N/ha manure) is allowed, for maize this is limited to Flanders: Brussels region – no information available to date. and organic fertilisers. 275 kg N/ha. These numbers apply to regions with No information available the least restrictions, but without derogation. P2O5 is limited to 100 kg/ha on grass, and 85 kg/ha Brussel-Capital reply is missing on maize. P2O5 from mineral fertiliser is not 1 November and 31 January. On bare lands with no The application rates of organic manures according 3-4 months - Where animals are housed during the In compliance with the Nitrates Directive, Bulgaria adopted a Code of Good Agricultural crops the ban is till 15 February. New orchards can Farmers are prohibited to use fertilisers in belt II of sanitation zones of drinking to the Code should reflect both the nutrient winter or other period, there must be adequate Practice, setting rules to prevent the pollution of waters by nitrates from agricultural sources. The application of slurry or solid manures should be receive organic fertilisers till 15 November. water sources where nitrates are over 35 mg/l. requirements of the crop being grown and the storage capacity to safely contain all the wastes The Code was approved by Decree RD-09-431 of the Minister of Agriculture and Forests from carried out as early as practicable in the growing As a general rule, the application of slurry and other Fertilisers should not be applied within 5 m of water bodies in flat areas. nutrient status of the soil, provided the nitrogen produced by the animals. The rules envisage storage 22 August 2005. It is based on Regulation No 2 of 16 October 2000 (of the Bulgarian Water season, so as to maximise the uptake of nutrients BSNN (NGO): concentrated organic fertilisers to land should be The appropriate application rates for grass and tillage crops are based on: previous content of the applied organic fertilisers does not facilities with a capacity of 3 months plus 1 month (in Bulgaria BG Law of 1999) for the protection of waters from nitrate pollution from agricultural sources, by crops and to minimise pollution risks. For most http://www.bsnn.org/pdf/GoodAgricult avoided during the non-growing season, which is cropping, fertilisation history of the field, and soil type. Type of crop, type of soil, exceed 170 kg/ha (17 kg/dKa) of active substance case of cold and long winter) depending on the number issued by the Minister of the Environment and Waters, Minister of Public Health and Minister crops this will be before the main summer period of uralPractice-DRPII-21728.pdf typically October to March. Exception to this rule may terrain, vegetation, vicinity of water bodies and weather conditions are all factors annually. Where the recommended nitrogen and kind of animals or poultry. of Agriculture and Forests (Official Gazette, issue 87 from 24 October 2000). July and August. be permitted if the landowner, in consultations with a incorporated in the rules giving prescriptions for the application of fertilisers. application rates for crops exceed these limits, the All tanks must be leak-proof. All manure pits, silage In 2006, the Bulgarian Action Programme was indicated as being in preparation and including qualified agricultural advisor, establishes that additional nitrogen required may be obtained from stores and waste heaps must have collection channels additional measures to the Code of Good Agricultural Practice. landspreading of these organic fertilisers can be chemical fertiliser. In exceptional cases with to convey all effluent to suitable storage facilities. no reply carried out during this period in accordance with the intensive production the rate of application can go There are specific requirements for solid farmyard The protection of water and soil is regulated under the Water pollution control Laws of 2002 until 2009. The Nitrates Directive was harmonised in the National Legislation with the The time that elapses from the disposal of livestock Regulations 534/2002, issued under the above Laws. Furthermore, 6 areas of the country are waste until it is integrated must be as short as established as NVZ areas according the Decrees 186/2008 and 41/2011. Within these areas, possible, and must not exceed 5 days in any event. Where Waste Disposal Authorisations or General Cyprus CY the Action Program which was issued with the Decree 300/2012 is implemented. The Code of No No information No information No information No information Questionnaire Good Agriculture Practice was issued under the Decree 263/2007. The implementation of Disposal Terms apply, their relevant conditions CGAP within NVZ areas is mandatory. There are terms included in the Action Program as well must be complied with.The permits of IPPC farmers as in the CGAP for spreading of manure in order to minimise emissions. include terms for incorporation of manure within According to the above-mentioned laws, the Minister of Agriculture, Natural Resources and 24 hours from disposal. TheEnvironment following grants pieces Wasteof legislation, Discharge which Permits implement for livestock the Nitrates farmers. Directive, The permits are relevant include to Standards for crop rotations: The Minimum soil cover: The applicant, on manure: applicant, on a land endangered by an arable land block or a part thereof • Act No. 254/2001 Coll. on waters; The applicant using a land block or part thereof bordering on a body of surface erosion, shall ensure that wide-row whose average incline exceeds 7 • Government Regulation No. 262/2012 Coll. on Nitrates Vulnerable Zones (NVZ) and Action water shall establish a buffer strip of unfertilised land of a width of at least 3 metres crops of maize, potatoes, beet, sown degrees, is required to sow the next Ministry of Agriculture (website): Czech from the bank, unless another legal provision stipulates otherwise. The applicant http://eagri.cz/public/web/mze/zivotni- CZ Programme; No information No information No information No information beans, soy and sunflower are not crop after the harvest or to apply at Republic • Act No. 156/1998 Coll. on fertilisers, as amended. shall not implement any agro-technical measures on the land block used by him/her grown. Cereals and rapeseed crops are least one of the following measures: prostredi/ochrana-vody/nitratova- The Government Regulation No. 262/2012 was the last modification of the Action Programme if the land is flooded or waterlogged except actual crop harvest and satisfying the to be planted on such areas using soil a) stubble is to be left on the land block smernice/ (No. III). The Action Programme includes basic measures, in compliance with the Nitrates conditions of GAEC standard 7. protective technologies, especially or part thereof until 30th November at no reply Directive: it therefore takes into account issues related to manure (manure spreading periods, sowing into mulch or sowing without latest, or Relevantrestrictions environmental on use, manure legislation storage, concerning etc.). environmental pollution from agriculture is laid Lange Fogh Christian (2013), Depends on the type of manure and crops: Liquid There are specific recommendations regarding the A maximum of 140 kg N/ha from animal manure 7-9months - Sufficient storage capacity of livestock tillage. In the case of cereals, the b) the soil is to remain ploughed, or at Danish EPA: down in the NPo Action Plan (1985). The Action Plan I for the Aquatic Environment (APAE) was Ammonia abatement in livestock manure and degassed plant biomass shall techniques that have to be used depending on the and 170 kg N/ha for cattle manure and degassed manure will normally correspond to at least nine http://www.mst.dk/English/Agricultur issued in 1987, and dealt mainly with (ground) water protection from leaching of nitrogen. Denmark, April 2013: not be applied to the soil from harvest (no later than type of manure. Only band spreading and injection plant biomass may be applied on agricultural months' supply. This figure, however, is normally at e/nitrates_directive/implementation_i APAE II adopted in 1998 was recognised as implementing the Nitrates Directive. In 2001, the Nitrate : 1 October) to 1 February. From 1 September to 1 There are requirements regarding land with risk of run-offs and slope. The of slurry is allowed (no overall spreading). It is holdings. In case where at least 2/3 of the livestock least seven months supply for cattle farms in which at n_denmark/ application of livestock manure, degassed plant biomass, silage effluent, residue Demands for late crops are mandatory Elaborating fetilization plan is http://ec.europa.eu/environment/gree Denmark DK Ammonia Action Plan was launched, whereas APAE III entered into force in 2004 (covering the • 1985-2003 : Nitrate leaching March, liquid livestock manure may not be applied to mandatory to inject slurry used in grass and on are cattle, livestock manure and degassed plant least 2/3 of the livestock units are cattle and where the period 2005-2015) . The APAE III was midterm evaluated in 2008 and the government reduced with 48 % (Chemical perennial crops that are not harvested annually. water or mineral fertiliser (commercial fertiliser) on land that is saturated, flooded, “bare soil” biomass, a maximum of 230 kg N per hectare per animals are outdoors in the summer grazing season. (grass, beets, catch crops) mandatory. nweek2012/sites/default/files/3- launched the Green Growth Agreement 2009-2015 in particular to ensure to achieve the goals fertiliser (N) 49 %) Solid manure, silage effluent, and mineral fertiliser frozen or snow-covered is not permitted. Solid manure, and degassed plant biomass applied planning period of livestock manure and degassed Where special conditions prevail, such as beef cattle 2_hjort.pdf http://www.mst.dk/English/Agricultur of the APAE III. The agreement includes new standards and specific limits in nature protected • Green Growth (2009) : add. (commercial fertiliser) shall not be applied to the soil to areas without established crops to harvest shall plant biomass may be applied. grazing outdoors for a substantial part of the year, the e/nitrates_directive/action_plan_aqua areas (designated under the Habitats Directive). 19.000 tons reduction (2015) from 15 November to 1 February. be incorporated into the soil without delay and There is also Standards for the use of animal storage capacity must correspond at a minimum to the tic_environment_3/ Main legal acts are: There(WFD) are(30 no%) specific Exemptions are listed in the Code, in particular in case within 6 hours of application. manure: up to 70-75% slurry can be used. period in which the cattle are stalled. Environment Ministry (website): On the whole territory, the maximum amount of Water Act sets down basic rules for use of fertilisers like conditions when spreading of assessments carried out Spreading of fertilisers (organic and minerals) on arable land is prohibited when: http://www.envir.ee/NTA manure nitrogen 170 kg/ha. In NVZ, the average fertilisers (including manure) is prohibited. Water act gives a recommendation to farmers to concerning the impacts of the - the slope of which exceeds 10% Farms over 300 au using liquid manure http://www.ais.unwater.org/ais/aiscm/ allowed amount of nitrogen that is applied to 8 months – The storage capacity for containing the follow the guidelines of Good Agricultural Practice. The decrees under the Water Act specify in legislation. Results of annual 1st November to the 15th March . Where the slope is - the land is covered with snow, frozen or waterlogged, as well as in periodically All farms using fertilisers should record technology must prepare special getprojectdoc.php?docid=29 According to Water Act manure must be arable land with combined organic and mineral manure and dung water of eight months and Estonia EE more detail provisions of the Act. Various NVZs were identified in compliance with the Nitrates ground and surface water 5–10%, surface spreading is not allowed from 1 flooded sanitary protection zones and water protection zones of water bodies. all the use of fertilisers on the field level manure spreading plan for 2 years and http://www.envir.ee/NTA/tegevuskava incorporated into soil within 24 hours. fertilisers is 170 kg per hectare per year. For mandatory for all farm buildings with more than 10 Directive. An Action Plan was adopted with regards to the identified NVZ, covering the period monitoring programs are November to 15 April For lakes, reservoirs, rivers and canals the width of the protection zone is 10 metres in the field book. to get approval from local officer of the https://www.riigiteataja.ee/akt/122122 mineral fertilisers only this amount is 140 kg per animal units. The storage facilities must be water tight. 2004-2008. A new Action Plan was later adopted for the period 2009-2011. The information general source of information from the water’s edge, and 1 metre for artificial recipients of drainage systems until Environmental Board. 012024 hectare per year. Amounts of mineral nitrogen available come from the Action Plan 2004-2008. New NVZ Action Plan until the year 2015 has about water status. they fall into a natural watercourse. http://www.agri.ee/public/juurkataloog passed public consultation and was sent to Government for approving. In addition some projects have exceeding 100 kg must be applied partially. /TRUKISED/Hea_pollumajandustava.pdf Finland adopted Government Decree No. 931/2000 of 9 November 2000 on the restriction of been initiated to assess the 15 October to 15 April 15. Depending on the Organic fertiliser applied in the autumn must 12 months - The manure storage for waste products An unofficial translation of this decree is discharge of nitrates from agriculture into waters , which is based on the Nitrates Directive and environemental conditions and land use, the period Nitrogen fertilisers must not be applied on snow-covered, frozen or water-saturated always immediately, and within 24 hours at the Animal manure may be applied on a field as excreted by animals must be sufficiently large for available at: controls the use of nitrate fertilisers in all farms across the country (whole territory approach). can be modified: ground. latest, be incorporated, or the field must be fertiliser equivalent to up to 170 kg/ha/year of manure accumulated over 12 months, excluding http://www.finlex.fi/fi/laki/kaannokset/ The Decree is currently being revised. - Manure may be applied in the autumn up to Use of nitrogen fertilisers is prohibited on areas closer than five metres to a ploughed. nitrogen. The maximum amounts of manure that manure remaining on pasture during the same grazing 2000/en20000931.pdf watercourse. Along the width of the next five metres, surface application of can be applied in the autumn are 30 tonnes/ha of Finland FI There is also documentation providing guidelines and best available practices: November 15, and application may be started in the season. http://www.ymparisto.fi/download.asp - Guidelines for environmental protection in animal husbandry spring no earlier than April 1, provided the ground is nitrogen fertilisers is prohibited if the field slope exceeds two per cent. The Code provide recommendations on the solid manure, 20 tonnes/ha of cow slurry, 15 Manure storages and manure gutters must be ?contentid=117243&lan=fi - Best available techniques in livestock farming in Finland (published in 2002) not frozen and is sufficiently dry to avoid runoff into Surface application of animal manure is always prohibited on fields whose average maximum amounts of nitrogen that may be used tonnes/ha of pig slurry or 10 tonnes/ha of poultry watertight and no leakage must occurs. Manure heaps http://www.ymparisto.fi/download.asp - Reducing the environmental load from domestic animal production – the costs and watercourses and any danger of subsoil compaction. slope exceeds 10 per cent. on fields as fertiliser, contained in both mineral or fur animal manure. must not be sited in areas that may become flooded or ?contentid=4582&lan=fi functionality of the measures (published in 2004) - Manure may not be applied on grassland after fertiliser and animal manure and organic fertilisers: in groundwater areas. Manure heaps must not be built http://www. September 15. 1) winter cereals up to 200 kg of nitrogen/ha/year, closer than 100 metres to a watercourse ymparisto.fi/download.asp?contentid=2 Depending on their size, agricultural farms are either subject to the Règlement Sanitaire 1st september/ 1st/15 october/15 november to The application of fertilizers is forbidden on waterlogged/water-saturated soil. The http://www.legifrance.gouv.fr/affichTex Départemental (RSD, for small holdings) or to the Classified Installations for the Protection of 15/30 January. The closed period are defined for application on frozen soil is forbidden only for liquid manure and slurry and the The fertilisation must be adapted according the 4-6 months . In NVZ, the legal capacity is at least 4 te.do?cidTexte=JORFTEXT00002582242 A fertilisation plan must be established the Environment regulation (ICPE Law), which defines activities according to a volume or a type of crops (including orchards and market application on snowed soil is forbidden for slurry and mineral fertilizers. crops requirements, taking into account soil months for manure and 6 months for liquid manure. 7&dateTexte=&categorieLien=id For 2012, 100% of arable land must be covered during rainy season, including by in NVZ and the practices must be capacity or production. gardening), per type of manure and the previous crop For arable land, the application of slurry and liquid manure and mineral fertilizers is content in nitrogen and other inputs. Every farmer The storage capacity is calculated for each farm by the http://www.legifrance.gouv.fr/affichTex 170 kg N/ ha of utilised agricultural land (previously crop rotation and the use of protein crops and leguminous. The date of the rainy recorded. A list of the elements that France FR For non-ICPE agricultural farms, relevant articles of the Environmental Code on water and the (in particular in case of protein crops and forbidden in land with a slope higher than 7%, except if there are buffer strips near owning more than 3ha must perform a soil DEXEL method (available at: http://www.inst- te.do?cidTexte=JORFTEXT00002500166 per ha of spreadable land). season is determined by each department. should be taken into account in the aquatic environment, and effluents from agricultural farms, include the following: leguminous). water bodies and if the fertilizers are incorporated within 24h. analysis. elevage.asso.fr/IMG/pdf/Dexel_Methode_et_referenti 2&dateTexte=&categorieLien=id Permanent grass strips must be implemented within 5m of water bodies. fertilisation plan is mentioned in the • Article R.211-48 prohibits the direct discharge of agricultural effluents into freshwater, The detailed calendar is available at: The application of mineral fertilizers in NVZ is forbidden at a distance of less than There is no specific requirement regarding el.pdf) and depends on the type of fertilizers. http://www.inst- 2011 Order. groundwater or sea water; http://www.legifrance.gouv.fr/affichTexte.do?cidText 2m for water bodies and on grass strips application techniques. Storage vessels must be waterproof. elevage.asso.fr/IMG/pdf/Dexel_Method • Articles R.211-49 through R.211-53 provides specific rules for the spreading of agricultural http://www.consultations-publiques.developpement-durable.gouv.fr/uploads/tinyMCE/les-consultations-publiques-du-ministere-du-developpement-durable/resume_evaluation_environnementale_programme_action_national.pdfe=JORFTEXT000025001662&dateTexte=&categorieLi For organic fertilizers in NVZ, the application is forbidden within: e_et_referentiel.pdf Theeffluents, Nitrates such Directive as minimum is fully distances transposed from through e.g. riverbanks, the Ordinance beaches, on fertilisers housings… (R.211-52 and SH LAWA: LBV_SH_307_de.pdf en=id - 35m from water bodies The quantity of fertilisers apply must take into The amount of livestock manure applied in any year The Codes of Good Farming Practice go For nitrogen and phosphorus, nutrient (Düngeverordnung ) and the manure container regulations (Dungbehältervorschriften) since SH AGRUM: The minimum distance to water bodies is 3m or 1m in case of precision fertiliser account the nitrogen balance, but also the climate to agriculturally used land on a holding, together beyond these legally binding provisions input/output budgets must be drawn up Ordinance on fertilisers 2008 report to 2007. All federal regions (Laender) have established codes of good farming practice to a certain LBV_SH_336_de.pdf spreader used. and soil conditions, the lime content and humus with that deposited to land by livestock, must not of the Fertiliser Ordinance and which at farm level annually. Nutrient inputs the Commission: degree, which are used mainly for information and advice. DüV-Evaluation: A minimum distance of 3 metres with no exceptions applies to steeply sloping content. Soil analysis for phosphorus is mandatory. exceed 170 kg of nitrogen per hectare. 26 weeks (nearly 6 months) - a minimum storage farmers implement on a voluntary are compared to nutrients removed http://www.bmelv.de/SharedDocs/Dow 1 November to 31 January on arable land, and from Germany DE In addition, immission prevention (Bundesimmissionsschutzgesetz) is addressing individual Bericht_Evaluierung_DüV_201 arable land (ground which has an incline of 10% or more within the first 20 metres Liquid manure, slurry and other liquid fertilisers as On arable land, following the harvest of the main period of 26 weeks for slurry/liquid manure and basis. These codes deal, amongst other from the system. The difference nloads/EN/Agriculture/OrganicFarming 15 November to 31 January on grassland. facilities. The respective standards are also based on EU Directive 2010/75/EU on industrial 21122_BF.pdf from the top of the bank). Fertilisers must be incorporated immediately. well as poultry manure must immediately be crop, a maximum of 40 kg ammonia-N/ha or 80kg storage facilities of sound construction is prescribed. things, with: (nutrient balance) must be established /Nitratbericht- emissions (integrated pollution prevention and control) and European Air pollution policy: 1979 BMVEL-UBA project on NH3: Fertilisers with significant nutrient contents (this includes manure) must not be incorporated into the soil on uncultivated arable total N/ha from liquid manure, slurry or other - Design of the agricultural landscape per plot or area. 2012.pdf?__blob=publicationFile Convention on Long-range Transboundary Air Pollution, and the 1999 Gothenburg Protocol to Endbericht_NH3_UBA- applied to waterlogged, frozen or snow-covered ground. land in order to prevent ammonia volatilisation. liquid organic or organic-mineral fertiliser or - Soil management The following data must be recorded: Abate Acidification, Eutrophication and Ground-level Ozone. According to the Texte_05_2002.pdf Regarding spreading, from 1 January 2010 certain poultry manure may be applied to meet the - Cropping and utilisation of land (incl. - Soil nitrogen content and method of Bundesimmissionsschutzgesetz, for large livestock facilities with > 40 000 places for poultry; > 2 KTBL NH3 measures: NH3- machinery are no longer be permitted. Fertiliser nitrogen demand of the subsequent crop or as design of crop rotations) determination The Nitrates Directive was transposed into national legislation through the Act JMD In order to avoid surface runoff, manure should not be spread when the soil is: Ministry of Environment, Energy and 16190/1335 of 9 June 1997 (Government Gazette B 519/25-6-1997). 1st September – 31 October on sandy or shallow soils flooded; strongly frozen; covered with snow. Climate Change (website): The time in-between spreading in the same area (5- The annual nitrogen quantity that is supplied in the In compliance with Article 4 of the Nitrates Directive, a Code of Good Agricultural Practice was for liquid manure and poultry manure. Application of livestock wastes should not take place in a zone of at least 10 meters http://www.ypeka.gr/Default.aspx?tabi 15 days) depending on the soil type and the local soil through manure spreading should not exceed issued in 2000 , one of its objectives being to set rules for the disposal of livestock waste with The number of days that the producer can spread the away from surface waters (lakes, rivers etc.) d=250&locale=el-GR&language=en-US climate 25 mg/acre for soil covered with vegetation and Greece EL the goal of protecting the environment and public health. liquid manure in the soil depends on the rainy days in For the protection of groundwater, livestock wastes should not be applied in a zone no information available. http://www.gesetze-im- The maximum allowed dosage depending on the 20mg/acre for soil without vegetation. These limits In total, 7 areas have been designated as NVZ and Action Plans have been adopted. Greece was the area and varies between 100 and 300 days per of at least 50 meters away from springs, wells or water drills that are used for internet.de/bundesrecht/d_v/gesamt.p type of soil (10 cm/d up to 50cm/d). include the total amount of organic waste, threaten to be sent to court by the EC for breach of the Nitrates Directive. Information is year. human or livestock consumption. df including manure of animals that graze in the area available at: http://www.minagric.gr/ but few in english Manure should not be spread in steep slopes where the surface runoff is higher and GG B 477/6-4-2000 : is increasing depending on the degree of the slope. There is not a specific slope See OG 1212B/14-9-2001, OG 1132V/6- degree limit above which the spreading of manure and livestock wastes is not 6-2008 and GG B 1843 (Greek official The relevant pieces of legislation are: Manure cannot be applied when slope exceeds 17%. Liquid manure cannot be http://www.complex.hu/jr/gen/hjegy_d In areas with intensive livestock • Governmental Regulation 27/2006 (II.7) on the protection of waters against pollution caused applied over 6% slope, except for sliding tube method and injection technology, After harvesting, easily soluble nitrogen fertilisers, oc.cgi?docid=A0600027.KOR activities, the farmers must keep by nitrates from agricultural sources (known as the Nitrates Regulation) ; which are permitted respectively up to 12% and 17% slope. especially slurry, manure, fertiliser can be applied if In Nitrate Vulnerable Zone, the annual amount of Consultation during AMEC (2012) and 15 November to 15 February. For winter cereals, records on the agricultural activity, in • Regulation 59/2008 (IV.29) FVM on the rules of the action plan on the protection of waters Fertiliser can be applied up to 12% slope or 15% drop in case of actions to protect the interval between fertilization and seeding do nitrogen application rate shall not exceed 170 kg / Environment Ministry (website) : spreading is possible from the 1 February if the soil is 6 months - The manure storage capacity should be at particular regarding fertiliser, tillage Hungary HU against pollution caused by nitrates from agricultural sources and on the rules of data provision soil from erosion. not exceed 15 days and with adequate ground ha. The amount includes grazing animal manure, http://www.nebih.gov.hu/szakteruletek not covered with snow or not frozen or in saturated least 6 months. and livestock management. The and registration; and coverage. Manure must be incorporated and waste waters, sewage sludge and sludge /szakteruletek/noveny_talajvedelmi_ig/ condition. agricultural activity and soil • Governmental decree 219/2004 (VII.21) on the protection of groundwater. Fertiliser cannot be applied closer than 25m to a water source for human or animal immediately. compost. szakteruletek/talaj/talajved/a_talaj.htm conservation plans ‘s records must be VNZ have been established to which the Action Program for good agricultural practices consumption and 20m to lake. The distance can be reduced to 3m in specific cases l#nitrat kept for 5 years. (introduced by Regulation 59/2008) applies. The provisions on good agricultural practice such as for non agricultural land. include rules notably on storage of livestock manure (size of storage, technical parameters) and The intensity of livestock farming activities is limited by the European Communities (Good The Agricultural Catchments Chemical fertilisers cannot be applied from 15 Chemical or organic fertilisers cannot be applied when the land is waterlogged, 1,5 to 6months - The storage capacity varies between Arable land ploughed between 1st July Maximum fertilisation rates of available nitrogen Agricultural Practice for Protection of Waters) Regulations 2010, which implements the Programme, funded by the September to 12/15/31 January, depending on the flooded or likely to flood, snow-covered or frozen, when heavy rain is forecast the type of livestock and the zone. Manure may not be and 30th November MUST have a green and phosphorus for grassland, tillage, vegetable Nitrates Directive (commonly known as the Nitrates Regulations). Ireland applies its action Department of Agriculture, zone. within 48 hours and in specific case of slope. stored in field and within 20m of a watercourse. cover from a sown crop within 6 weeks Literature review (Irish Environment, and fruit crops are set out in the Regulations. The All holdings are subject to a maximum stocking programme to the whole country. The country is devided in 3 zones, depending to the lenght of Food and the Marine and run Organic fertilisers cannot be applied from 15 October Chemical or organic fertilisers cannot be applied when the ground slopes steeply - For pigs and poultry, the storage capacity must be at of ploughing. Records shall be maintain regarding Community and Local Government): soil may be test for phosphorus. intensity equivalent to 170 kg organic nitrogen per Ireland IE the growing season, weather, soil types, etc. by Ireland’s farm advisory to 12/15/31 January, depending on the zone. and, taking into account factors such as proximity to waters, soil condition, ground least 26 weeks (less than 6 months). For holdings with Grassland ploughed between 1st July agricultural activities: manure http://www.environ.ie/en/Environment Organic fertilisers may not be applied with an hectare. Ireland benefits of a special derogation The emphasis on maximising the nitrogen fertiliser replacement value (NFRV) of cattle slurry service Teagasc, works with Farmyard manure cannot be applied from 1st cover and rainfall, there is significant risk of causing water pollution. less than 100 pigs and 2000 poultry places, the storage and 15th October MUST have a green management, soil tests, etc. /Water/WaterQuality/NitratesDirective upward facing splash plate or by use of a sludge from the EC to up this rate to 250 kg/ha. has been to the forefront in Ireland in recent years for a number of reasons. Nitrogen (N) 300 farmers across six November to 12/15/31 January, depending on the capacity must be at least 16 (3,5 months), 18 (4 cover from a sown crop by 1 November. / irrigator. fertiliser prices have increased substantially in recent years, resulting in farmers seeking to catchments to evaluate the zone. Organic fertiliser or soiled water cannot be applied to land within months), 20 (4,5 months), or 22 (5 months) weeks, Grassland MAY not be ploughed make better use of N resources in slurry to offset N fertiliser inputs. This has coincided with the environmental and economic - 200/100/25 metres of any water supply for human consumption (varies depending on the zone. between 16th October and 30th introduction of legislative restrictions in 2006, and updated in 2010, to comply with the EU effects of the Nitrates Action depending on amount of water being supplied or the number of people being - For sheep, deer and goats, the storage capacity is 6 November. Mandatory measures to reduce emissions are currently only in place for surface and ground A study carried out by ENEA 1 November to 31 January. Except for the period of The use of organic and chemical fertilisers is prohibited in surfaces not affected by The amount of manure must not in any case lead to 3 / 4,5 / 6 months - In the NVZ, minimum capacity of Consultation during AMEC (2012) A wide range of good practices, with differences water protection. In April 2006, a new Decree of the Italian Ministry of Agriculture was issued (http://www.enea.it/it) 15 December to 15 January, the provinces may allow farming (except public green area, private areas and areas subject to environmental a supply of nitrogen available to the field more than storage containers should be at least equal to the http://www.ermesagricoltura.it/Sportel region by region, is suggested in the Code of good concerning manure utilisation in Vulnerable and Non Vulnerable Zones. The decree obliges supported by CRPA the spreading on grass meadow with determined dry clean-recovery), in woods and in frozen and snow-covered area, in area with 170 kg per hectare per year (340 kg / ha in area volume produced in 180 days for slurry, and 90 days lo-dell-agricoltore/Come-fare- practices: fast incorporation of the surface spread farmers to achieve in animal manure application to crops 50% of nitrogen efficiency for slurry (www.crpa.it) assessed the matter content manure. aquifer outcrop, with landslides and waterlogged soils, except for the land used for Ordinary). for manure. This capacity for slurry is reduced to 120 per/Produrre-nel-rispetto-dell- manure, band spreading, application of slurry Italy IT and at least 40% for solid manure. This nitrogen efficiency is an obligation for all farms in effects of actual legislation and Provinces can suspend the ban for few weeks but only crops that require submersion. The EC has granted Italy with a derogation for some days for the breeding of dairy cattle, buffaloes, horses, ambiente/Utilizzare-effluenti-di- diluted with irrigation water (e.g. with low pressure NVZs. different scenarios. According for land with meadows, autumn-winter cereals, tree regions which allow farms that request it, the sheep and goats that have cultivated land to grassland allevamento-Programma-d-Azione- sprinklers or drip lines), trailing hoses, shallow and Concerning emissions to air, the IPPC Directive, applying to manure of intensive farming of pig to these scenarios the crops with permanent grass and other crops sown in Spreading is prohibited at distances of more than: application up to 250 kg of nitrogen per hectare per of medium and long duration, or autumn and winter Nitrati/Programma-d-Azione-Nitrati- deep injection, etc. Due to its sustainable costs, fast (more than 2000 fatteners and/or 750 sows) was transposed in national legislation by the implementation of the early spring in good climatic and soil conditions. - 5 meters from the shore of surface water for manure; year from cattle manure and treated pig manure in cereal for at least 1/3 of the total. 2012-2015-Regolamento-Regionale-n.1- Decree 152/2006 and is applied since 2007. It concerns aintensive farming of pig (more than measures under discussion for - 10 meters from the shore of surface water for slurry; incorporation is the more practised technique. NVZ but in the fulfillment of specific conditions. 2011 2000 fatteners and/or 750 sows) and poultry (more than 40,000 heads). Every year (before the revision of the Annex IX of - 30m for other watercourses Livestock manure applied on derogation farms shall The accumulation at the bottom of the field is only http://www.ermesagricoltura.it/conten According to Annex 1 of the Law on Pollution (adopted on 1 July 2001), polluting activities The University of Agriculture of Recommendations of the Code of Good Agriculture 6-7 months – The capacity of manure storage for Consultation during AMEC (2012) and In NVZ, fertiliser shall not be spread on frozen, water-saturated and snow-covered (installations) requiring a Category A permit are farms for the intensive rearing of pigs and Latvia implements findings of practice are providing guidance for farmers using manure must be at least six months and seven months Fertilisation plan for the year and field Ministry of Environmental Protection ground. poultry with places for more than 40 000 poultry; more than 2 000 production pigs whose the scientific research the manure. In particular, The University of for slurry. history must be tracked and and Regional Development (website) : In floodplains and flood-prone areas, fertiliser must be spread only after the flood The amount of organic fertiliser per year must not weight exceeds 30 kg and more than 750 sows. "Determination of maximum 15th November to 1st March , for the use of Agriculture of Latvia had elaborated Liquid manure and slurry storage must be covered to documented where the products http://www.varam.gov.lv/eng/par_mini season. exceed 170 kg of nitrogen per hectare. In the first Latvia LV According to the Law on Pollution several regulations of Cabinet of Ministers stating norms of mineral fertilisers for farmyard manure, slurry and manure in the recomendations: „Manure production and reduce and prevent ammonia volatilization. incorporated 10 ha and more, fruit and striju/ and Fertiliser shall be spread no closer than 50 m from a watercourse or body of water four years of the action program 210 kg nitrogen requirements for farming activities and limitation of pollution caused by such activities has crops". The results will be used vulnerable areas. management ” and „Manure transportation and The amount of manure stored in field must not exceed vegetable farms - three hectares and http://www.varam.gov.lv/files/text/enit shoreline where the slope near the watercourse or body of water is no high than per hectare is allowed. been adopted: for reviewing existing national incorporation”. Fertiliser shall be spread if the field a capacity of one year and shall be covered by straw, more, and records kept for at least rati.zip and 10%. 1. Cabinet Regulation No. 1082 of 30 November 2010 „Procedure by Which Polluting Activities legislation normatives for is covered by vegetation and must be immediately sawdust or peat protection. It shall be located no closer three years http://www.saimnieks.lv/Agrokimija/Mi of Category A, B and C Shall Be Declared and Permits for the Performance of Category A and B mineral fertilisers. incorporated into the soil. After spreading, manure than 50 m from a watercourse or body of water. neralmesli/2747 LithuaniaPolluting Activitiesadopted aShall “whole Be Issued”. territory Cabinet approach” Regulation and therefore prescribes decided the conditions not to designate for the specific shall be incorporated within 24 hours and slurry In farms, having more than 15 ha of All farms having more than 150 ha of NVZs, but to implement an action programme on the whole territory: the 1st Action agricultural land, winter crops should agricultural land should establish To reduce nutrient leaching organic fertiliser (manure, sewage sludge, composts, Programme for Reduction of Nitrates Losses from Agriculture was adopted in 2003. In 2012 From 15 November to 1st April, organic fertilisers cover 50% of the area. fertilization plans for all crop fields. etc.) should be spread from drying up of soil in spring to freezing of soil in autumn The amount of livestock manure applied each year, 6-8 months- The storage capacity for manure from the Action Programme was revised and updated, and adopted together with the Program SHOULD not be spread (on soils that are frozen, water Solid manure should be incorporated into the soil For slopes of less than 5% (included), Fertilization plan should take into See notably when plant is growing. including manure left on fields after grazing, should livestock, horses and sheep is of 6 months. The storage Records on fertiliser use should be kept Lithuania LT Implementation Plan. A Code of Good Agricultural Practice (CGAP) was updated in 2007 no saturated or covered with snow); however in some within 6 hours after application. perennial grass have to cover no less account: soil type, soil conditions, slope, http://www.euracadagri.com/eng/activ When catchment area is less than 10 km2, width of the protective strip at streams not exceed the equivalent of 170 kg of nitrogen per capacity for manure from pigs and poultry is of 8 in farm record book. The CGAP includes all provisions required by the Nitrates Directive. It includes two types of cases, when there is no snow and the soil is not No specific further information. than 35-40% of the total crop rotation climate, crop rotation, desirable yield, ities/yalta_doc_li.php and ditches should be 1 m when stream side slope is less than 5%, 2.5 m slope is hectare of utilised agricultural area. months. rules: mandatory rules and voluntary undertakings. frozen, it is allowed to spread manure in cold season area. nutrient storage in soil, soil pH, The national documents targeted at reducing impacts on emissions to air and/or water in from 5% to 10% and more than 5m when slope is higher than 10%. On 5-7% slopes, perennial grasses have requirements of special land use Lithuania: to cover at least 50% of the total crop conditions. The- Ministerial Nitrates DirectiveOrder of 26was September transposed 2011 into regardingnational law the by approval the Grand-ducal of environmental Regulation of 24 It is forbidden applying nitrogen fertiliser on black, perennial and spontaneous Grassland on which organic fertilisers were applied The quantity of organic fertilisers applied must not rotation area. To protect drinking water, dug well November 2000 on the use of nitrogen fertilisers in agriculture, as amended: fallow and on water-saturated, flooded, snow or frozen soil. from 15 October to 15 February cannot be tilled exceed 170 kg/ha/year, except for protein crops - Article 5 introduces a guide to good agricultural practices, which notably includes the Code of England: until the 15 February. and leguminous for which the limit is 85 kg/ha. Farmers who plan to use more than 500 Good Agricultural Practices and the Action Programme; 1/15 September – 15 January for mineral fertilisers. It is forbidden applying nitrogen fertiliser at a distance of less than 50 meters from The total amount of slurry and liquid sewage sludge During the period from 1st September to 1st kg N per year of organic fertilisers non Grand-ducal Regulation of 24 No dated recommendation for organic fertilisers. You 6 months - Equipments must guarantee the storage of produced in their farm must prepare an November 2000: Luxembourg LU - Article 6 establishes interdictions and restrictions in relation to the use of nitrogen fertilisers in wells, drinking water catchments tanks and 10 meters from watercourses and spread during the period from 1st September to 1st March, the total amount of slurry and liquid agriculture and notably the spreading of such fertilisers on agricultural land (e.g. application should not apply mineral fertilisers to grass between water bodies for organic fertilisers. For inorganic nitrogen fertilisers, the distance is March should not represent more than 80 kg of sewage sludge spread should not represent more slurry for a 6-month period. annual fertilisation plan. They must http://www.legilux.public.lu/leg/a/archi rate, etc.); 15 September and 15 January and to other crops 10 meters from wells, drinking water catchments tanks. There is no distance for nitrogen per hectare. The maximum amount of than 80 kg of nitrogen per hectare. submit it to the Technical Services for ves/2000/0124/a124.pdf#page=2 - Article 8 sets conditions of storage for livestock effluents (e.g. new equipments must between 1 September and 15 January unl watercourses and water bodies but the fertilisers must be applied in opposite fertiliser per crop is indicated in the Regulation. In protected area for drinking water, the amount of Agriculture. no reply guarantee the storage of manure for a minimum period of six consecutive months). direction from the bank of the water body. All discharges of nitrogen fertilisers in organic fertiliser must not exceed 130 kg/ha/year, WithIf a farmer respect does to implementationnot have enough of land the whereNitrates manure Directive, spreading the whole is authorised, of Malta was he mustdesignated ensure as Thethe riverapplication is prohibited. of fertilisers is prohibited in water saturated soils and to soils in AllThere types are of specific mineral and and stricter organic requirements fertilisers shall for be except for protein crops and leguminous for which 5 months - Manure must be stored in leak-proof an NVZ. The Nitrates Action Programme (NAP) therefore applies to the whole territory. The flood-prone areas. distributed uniformly on the field and shall be covered storage clamp connected to a cesspit and the The producer (and contractor, if one is implementation of NAP aims at reducing the impact of nitrates, notably from livestock Fertilisers shall be not be applied: incorporated into the soil as soon as possible. The amount of livestock manure that can be cesspit must also be leak-proof and covered. The employed) is also obliged to keep No fertiliser shall be applied to any crop manures and other fertilisers, but should also have other indirect beneficial effects such as - to any type of natural water courses The application of untreated sewage sludge to the applied to land is also limited by the nitrogen minimum storage capacity for solid manure must be records of slurry and manure transports Literature review (Ministry for 15 October to 15 March . The application of livestock Crop rotation shall be practised where in that year prior to the preparation of a Malta MT reducing nitrous oxide and ammonia levels. - within 5m from natural water courses, springs, galleries, gallery shafts, boreholes fields is prohibited. content, i.e. 210 kg N/ha for the first four years of sufficient to cover the closed period, ie from 15th and disposal, including dates, quantities Resources and Rural Affairs): manure is prohibited during the rainy season. necessary. complete fertiliser plan as required in The Code of Good Agricultural Practice (CoGAP) was adopted in 2004 and covers all aspects of and karst features A fertilisation plan was required for the application the Action Programme (2004-2008) and 170 kg October to 15th March. Field storage of solid manure is and final destination. The regulation http://www.agric.gov.mt/nap terms of this regulation agricultural production, including notably animal husbandry and manure handling, and - within 30m any borehole used for public water supply of mineral and organic fertilisers (including N/ha thereafter. allowed during the dry season, with a maximum of 6 also provide a list of the documents that fertilisation practices. These measures constituted the first NAP for the period from 2004 to - within 100m from the coast. livestock manure) with the aim of achieving months, if the dry matter content is at least 30% and farmers shall record. no reply 2007. The CoGAP measures related to the Nitrates Directive were implemented through the A minimum distance from watercourses and from the shoreline was specified for nutrient balance. All types of mineral and organic with requriements regarding the distance from water Rural Development Plan (RDP) for the years 2004 to 2006 and in the current RDP which covers the application of mineral and organic fertilisers. Furthermore fertilisers cannot be fertilisers shall be distributed uniformly on the field bodies.Cesspits must have sufficient capacity to collect According to Alterra (2007), the Environmental Management Act (Wet Milieubeheer, 2005) In 2009, Planbureau voor de 1st August/1st September/15 September to 31 Organic fertilisers cannot be applied when the ground is frozen or covered by snow, The application of phosphorus is limited to an On natural land (land with wood, sand, marsh, bog, Alterra (2007) provides general binding rules regarding livestock farming which are relevant to manure, Leefomgeving (PBL January/15 February. The period depends on the type except if it concerns the application of solid manure into managed grassland and in amount of 95 kg per year for pasture. etc. ), the use of fertiliser is forbidden. For managed http://wetten.overheid.nl/BWBR00040 among which: Netherlands Environmental of soil, the type of fertilisers and land use. case of the application of nitrogen fertilisers on clay soil of crop land with For arable land, the limit amount is 80kg in 2010, or protected natural land, fertiliser can be used if 54/geldigheidsdatum_13-05-2013 - To reduce emissions of ammonia and odour, farmers are obliged to cover their outdoor slurry Assessment Agency) has For grassland, the spreading of solid manure is temperature between 0 and 5°C. 75 kg in 2011, 70 kg in 2012 and 65 kg in 2013. the amount of manure applied do not exceed 20 kg http://wetten.overheid.nl/BWBR00090 Netherlands NL storage facilities (Activiteitenbesluit milieubeheer and Activiteitenregeling milieubeheer) executed an evaluation of the prohibited from 1st September to 31 January if soil is The application is prohibited when the soil is saturated with water. This amount can be slightly modified according the Phosphate/ha/yr or in the case of grassland 70 kg 66/geldigheidsdatum_29-03-2013#i1 . - To reduce emissions of ammonia from animal houses, emission limit values for housing Dutch policy/legislation on low- irrigated or infiltrated (through pipes in the ground) It is forbidden to spread in land with more than 18% slope. Above 7% slope, there crop, the agricultural practices, the excess from the Phosphate and 170 kg Nitrogen/ha/yr. For http://www.drloket.nl/onderwerpen/m systems are laid down (Besluit Ammoniakemissie Huisvesting Veehouderij, 2005). emission application of and on sandy and loess soil. On clay and peat soil the are restrictions: manure may not be used on non-cultivated land and when there is previous year, etc. agricultural land (grassland or arable land), the est/dossiers/dossier/gebruik-en- Based on the Soil Protection Act (Wet Bodembescherming) and later the Fertiliser Act, there manure. The report (in Dutch period is from the 15 September to 31 January. The high risk of erosion. The general rule for the application of manure is amount of fertilisers shall not exceed 85 kg uitrijden-meststoffen/dierlijke- sdt are general binding rules in force that oblige farmers to apply slurry to grassland and arable with short abstract in english) spreading of slurry is prohibited from 1st September that low emission techniques have to be used with Phosphate and 170 kg Nitrogen/ha/yr. There is also mest/emissiearm-gebruik-dierlijke- Thoseland with farms low that emission do not techniques. fall under the scope of IED requirements are obliged to obtain so called can be found here: to 15 February. the effect that: requirements for land other than natural or Consultationmeststoffen during AMEC (2012) and single-media permits. Permit for emission to air is required for intensive rearing of animals Alterra (2007) with more than 210 DJP (factor used in general for purposes of environmental impact The Code of Good Agricultural Practices contains a National Water Management Authority Spreading is forbidden on waterlogged soils, frozen, snow covered soil surface and part regarding agricultural practices to protect Farmers may practice crop rotation and assessment issues). For farms below this threshold but above 60 DJP, only notification to the 1st December to 29 February. Natural and inorganic : on land with slope above 10%. Manure cannot be spread at a distance higher than water. It provide advices to elaborate a fertilisation The annual amount that can be spread is 170 kg 6 months - The capacity of storage should provide the incorporation of straw. Poland PL competent authority is required. This requirement is a general rule and should be applied to fertilisers should not be applied between 1st http://www.kzgw.gov.pl/files/file/Mate 20m from a water body. Slurry may only be used when the level of underground plan in particular on dose and timing application of N/ha/year possibility of storing manure during 6 months. Recommendations are provided in the any rearing activity where the number of animals exceeds 5 m3. December to 29 February. rialy_i_Informacje/Dyrektywy_Unijne/A As part of the implementation of the Nitrates Directive, Poland adopted a Code of Good water is below 2 m. fertilisers and the most appropriate application Code. zotowa/kodeks_dobrej_praktyki_rolnicz Agricultural Practice in 2004 . The same year, it designated 21 VNZ (covering 2% of its techniques). ej.pdf no reply territory) and therefore developed 21 action programmes (for the period from 2004 to 2008) http://www.kzgw.gov.pl/Dyrektywa- applicable to each of the NVZ, which became the local law following official publication in the Azotanowa.html The requirements related to the spreading of manure are the result of the Nitrates Directive Portuguese Environment Agency – APA, 1st November to 1st/15 February. The period Fertiliser SHOULD not be applied in flooded soil, saturated soil and frozen soil (when The Code of good practices contains very detailed Restrictions in quantitative terms, dependent on contained in the program of action for the vulnerable areas of mainland Portugal (Decree nº 3-6 months - The storage capacity must by 3-4 months I.P. and national Water Institute: depends on the type of manure and land use. it happens more than few hours) method to elaborate a fertilization plan, calculate the particular crop needs nitrogen and phosphorus 259/2012 of 28 August) and the Code of Good Agricultural Practices. for manure and 5-6 months for slurry. http://www.inag.pt/inag2004/port/r_e For inorganic fertiliser, the application is possible in Fertilisers should be applied at a distance of at least 5 m of groundwater for the requirements, timing and application and maximum values of heavy metals and The Nitrates Directive was transposed into national law by Decree-Law No. 235/97 of 3 The Code of good practices contains advices regarding Crop rotation are encourage. Advices The records that the farmers should xternas/ue/nitratos/DL235_97.pdf and arable land during the prohibition period if the irrigation, 20m for groundwater for other use, 10m of non-navigable watercourses, techniques. The maximum amount of nitrogen pathogenic microorganisms. The maximum amount Elements to elaborate a fertilization Portugal PT September 1997, as amended by Decree-Law No. 68/99 of 11 March 1999 and Regional manure storage in a view to reduce the risk of are provided in the Code of good keep are indicated in the Code of Good http://www.inag.pt/index.php?option=c amount applied do not exceed 30 kg N/ha/yr. For 30m from navigable waterways and 100m from drinking water abstraction point. fertiliser for each crop is indicated in the regulation. of applied organic fertiliser is 170 kg N/ha/yr. The plan are communicated to farmers. Legislative Decree No. 6/2005/A of 17 May 2005 (for the Azores autonomous region). pollution: coverage, ventilation, tans characteristics, agricultural practices Practices. om_content&view=article&id=178 horticultural crops, application is possible until two There is no specific threshold for the application on slope. The recommendations In particular, incorporation of manure into the soil amount of heavy metal should be taken into There are currently 9 designated NVZs on mainland Portugal, and 8 in the Azores autonomous etc. http://www.drapc.min- days before sowing or planting. indicate that the run-off risks should be taken into account and the fertilisers should or manure, respectively, up to four hours or twenty- account, and for poultry manure, salinity and as region. Action Programmes were developed and adopted through legislation, and are agricultura.pt/base/documentos/portar not be applied when heavy rainfall is foreseen. four hours after its application. well as their alkalinity levels of copper and zinc applicable to all NVZs: they include measures provided in the Code of Good Agricultural ia_259_2012.pdf Practice and other specific measures. In compliance with Article 4 of the Nitrates Directive, Romania adopted a Code of Good The period of ban depends on the land type. Fertiliser must not be applied if land is covered by snow and if the temperature is http://www.mmediu.ro/beta/wp- Agricultural Practice in 2002, according to the Governmental Decision (GD) 964 of 13 October Spreading is forbidden on non-cultivated area. higher than 40°C during more than two consecutive days and lower than 0°C for content/uploads/2012/05/2012-05- 2000, Annex 3, concerning the approval of the Action Plan for Water Protection from Nitrate For fall crops, spreading is forbidden from 1st the next 3 days. 29_02_PR-ACT-OCTfinal2010.pdf Pollution from Agricultural Sources. November to 7/31 January. The minimum width of the slope is 1 m for land slope up to 12% and 3 m for land Within 24 hours of taking on such land, organic 6 months - The storage capacity for manure must be 1 The Regulations provide mandatory BSNN (NGO): The maximum quantity of organic fertiliser over a Romania RO The Nitrates Directive was transposed into Romanian legislation through GD 964/2000 For spring crops, spreading is forbidden from 1st July with a slope of more than 12%. Arable land with slopes less than 8% is fertilisers are incorporated into the soil. No specific month higher than the longest period of ban for documents to record regarding http://www.bsnn.org/pdf/GoodAgricult year is 170 kg/ha. approving the Action Plan for the protection waters against pollution caused by nitrates from to 1st January. recommended to maintain the proportion of winter crops and / or crop cover over other information. fertiliser spreading. agricultural activities. uralPractice-DRPII-21728.pdf agricultural sources. NVZs were designated and the Action Plan applies to these NVZs. The For grassland, spreading is forbidden from 1st 20% of the arable farm. Arable land with slopes between 8-12% is recommended to Ministry of Environment and Forests Interministerial Commission for the implementation of the Action Plan approved the September/1st November to 7/31 January. increase the proportion of winter crops and / or cover crops to 25% of the arable (webpage): no reply designation of NVZs by Decision No. 21130/DC/14.10.2010. farmer. Land with slopes greater than 12% is required to maintain the weight of http://www.mmediu.ro/beta/domenii/ Water protection from livestock emissions is dealt with in Act No. 364/2004 Coll. on Waters winter crops and / or crop cover over 30% of arable farm. Mineral fertilisers are applied longer the single Nitrogen from manure and other farm fertilisers managementul-apelor- and on Amendment of Act No. 372/1990 Coll. on offences as amended (Waters Act). Spreading is forbidden when agricultural land is frozen to a depth of 8 cm or more dose should not exceed 60 kg N/ha. not exceed an average of 170 kg N/ha agricultural Air protection from livestock emissions is dealt with in Act No. 137/2010 Coll. on air. below the layer of snow 5 cm, when land is waterlogged or temporarily In establishing hop fields, vineyards, orchards and land per year in vulnerable areas. In the first year of Farmers have an obligation to adhere to the Code of Good Agricultural Practice, which waterlogged continuous layer of water and in land annually threatened by flooding. vegetables, the amount of nitrogen fertilisers apply a four-year period, it is possible to use the batch 6 months - The capacity of storage tanks for farm Slovakia SK contains: 15 November to 15 February in vulnerable area. Spreading is possible at a distance of at least 10m from surface water source and can be up to: containing up to 210 kg N/ha. fertilisers must be ensured for the six months of Consultation during AMEC (2012) • Code of good agricultural practice – water protection against nitrate pollution from 10m from the boundary of the protection zone for drinking water. - 350 kg N/ha on farmland with low restrictions The application manure shall not exceed mineral production. agricultural sources; Spreading is allowed in arable land with slope up to 10%. For land with slope - 250 kg N/ha of farmland with medium and high fertilisers, i.e.: • Cod of good agricultural practice on soil protection; between 7% and 10%, measures to protect from erosion must be carried out. degree of restriction - 50 kg N/ha per year on agricultural land with low no reply • Code of good application of manures. At the time of harvesting, up to 40 kg N/ha of limits application of fertilisers containing nitrogen AgriculturalSlovenia designated land in NVZ the wholeare divided territory into as 3 groupsa NVZ. are concerned by low, medium or high Incorporation of animal 15 November / 1st December to 15 February / 15 mineralThe maximum fertilisers amount and 80 of kgfertiliser N/ha of per organic crop is - 40 kg N/ha per year on agricultural land with http://www.uradni- In 2004, Slovenia adopted Rules for the implementation of good agricultural practices in manures into soil and other March. The period of ban depends on the type of mentioned in the regulation. 4-6 months - The capacity storage must be sufficient list.si/1/content?id=52337 fertilisation (Official Journal No. 130/2004). These include specific rules regarding manure, low emission techniques are manure, the geographical condition and the previous Spreading of mineral and organic fertiliser is prohibited in soil saturated with water, The regulation provides spreading techniques for 6 months in the continental area and 4 months in http://www.uradni- such as rules regarding manure storage facilities, annual fertilisation plan (covering fertilisation recommended. Generally agricultural practices. flooded, covered with snow and frozen. allowed for the application to each type of fertiliser The annual input of nitrogen from livestock manure the coastal area. In the case of livestock that graze list.si/1/content?id=95719 and manure storage), measures to avoid volatilisation of ammonia (through rapid farmers respect the advice to The spreading of slurry is prohibited from 15 In case of steep land, the dose of liquid organic fertiliser must be reduced (80 kg (mineral fertilisers, slurry and manure). The mineral must not exceed 170 kg N / ha and 0.46 kg/ha per eight months or more, the capacity muts be at least 4 In case of use of liquid (organic or Ministry of the Environment and Spatial incorporation of manure into the soil). The Rules were repealed by a Decree amending the apply manures at favourable November to 15 February. The spreading of slurry on N/ha per application) and several practices are imposed such as land coverage (see fertilization is allowed to use wide spreaders, day. months. mineral) fertilisers, 15m between field Planning (website): Decree concerning the protection of waters against pollution caused by nitrates from weather conditions. Generally, land with green cover is prohibited from 1st options) spreaders with metal rotating single or double plate On steep land, where there is a risk of leakage into Manure can be stored in field but no longer than 2 and water bodies must be covered by http://www.arhiv.mop.gov.si/en/areas agricultural sources (Official Journal No. 5/2013). The same decree has also amended a Decree but to lower degree, they also December to 31 January. The spreading of slurry on The application of fertilisers is prohibited at a distance of less than 100m from an (centrifugal spreader plate), metal spreaders with surface waters, the amount of liquid organic months and with specific requirements, in particular grass, the fertiliser application must be _of_work/water/nitratna_direktiva/ concerning the protection of waters against pollution caused by nitrates from agricultural respect the advice to land over 800m of altitude is prohibited from 15 abstraction source of drinking water. swivel hose, pneumatic spreaders, spreader worm fertiliser must be divided into several parts so that regarding the distance to watercourses. at the right angle to the slope and the http://www.mko.gov.si/fileadmin/mko. Slovenia SI sources (Official Journal No. 113/2009). The latter provides rules regarding (i) levels of nitrogen incorporate manures on arable November to 1st March. It’s possible to reduce the conveyor and equipment for liquid fertiliser. For a single dose should not exceed 80 kg N / ha. field must be winter covered. gov.si/pageuploads/zakonodaja/varstvo The Nitrates Directive was implemented in Spanish law through the Royal Decree 261/1996. In Manure spreading is forbidden in flooded, snowed or frozen soils. Restrictions For all regions, there are mandatory specific 3 / 4 / 5 months, depending on the regions. Consultation during AMEC (2012), addition to this Decree, every autonomous community has identified the NVZ and establishes during rainy seasons depend on the regions: spreading should be minimised in fertilisers doses and maximum total incorporation In Extremadura, storage should be big enough to replies (for Extremadura, Andalucia, an action plan. The application ban depends on the region, land use Extremadura, spreading is forbidden in Andalucía and there is no specific of N for the most common crops. Non-mandatory collect manure during the longest period of time when Castilla y Leon and Navarra) and In Aragon, there is an obligation to The Spanish regional authorities require farmers to establish a manure management plan prior and the type of fertiliser. In Andalucia, periods are not requirement in Navarra and Castilla y Leon. extra recommendations are also included for The limit amount of fertiliser from manure is 170 kg spread is forbidden (never less than 5 months in NSA, 3 literature review: submit a fertilisation management plan Spain ES to commencing activities. They have different mechanisms to control the application of clearly indicated, while in Navarra for example, there Regarding distance from watercourses, for Extremadura, fertilisers should not be Andalucia. N/ha. In the first four-year period, it is possible to in other areas). There is no mention of temporary http://www.navarraagraria.com/n193/ for livestock farmers subject to an manure in agriculture, along with voluntary systems for improved feeding systems and the is a very detail calendar. (ex: see: spread within 10m from any water course. Manure cannot be used within 100m Regarding application techniques, specific use the batch containing up to 210 kg N/ha. storage. It has to be waterproof and able to collect arvulne7.pdf integrated environmental permit. codes of good practices in the application of manure to agriculture. http://www.navarraagraria.com/n193/arvulne7.pdf) from any well or fountain to be used for human consumption (other fertilisers can). mandatory fertiliser application techniques are effluent liquids. It cannot be located closer than 100m http://pagina.jccm.es/medioambiente/ The Autonomous Community of Aragon adopted a Code of Good Agricultural Practices in 1997, For Andalucia, only manure cannot be applied within 50m from water courses. For described depending on the type of fertiliser and from any water course. publicaciones/guias/BPA%20Nitratos.p partial reply which was amended in 2005 to impose the obligation to keep a registry of applications of Castilla y Leon, manure cannot be spread within 200m from urban areas. No crop for Extremadura and Andalucia. In particular, In Andalucía, storage should be big enough to collect df Infertilisers 1988, Sweden in farms launched included a in Action NVZs. Plan The against current Plant NVZs Nutrient were designated Losses from in an Agriculture. Order of 11 The Model calculations of nutrient Insidefertiliser NVZs, can thebe used following within precautionary 10m from a water measures course. apply: Provides detailed specific Withinmanure NVZs, should the be supply buried. of While nitrogen there via is manure no specific and The spreading of manure is limited by its content of 8-10manure months during - Thethe longestCode of periodGood Agricultural of time when Practices spread Replieshttp://www.boa.aragon.es/cgi- and Action Plan was subsequently revised to take into account provisions of the Nitrates Directive, losses from agriculture are • Manure may not be spread on water-saturated or flooded ground. fertilisers may not exceed the quantities considered phosphorus. The supply of phosphorus from stipulates that any farm with more than 10 livestock http://www.jordbruksverket.se/amneso the IPPC Directive and the UNECE-CLTRAP. This Action Programme has expanded to include made regularly. It is however • Manure may not be spread on frozen or snow-covered ground. necessary for the crop in the site in question. manure and other organic fertilisers may not units (LU) in an NVZ must have manure storage Within NVZ, 60 % of arable land shall be mraden/odling/vaxtnaring/spridagodsel measures for reducing losses of notably ammonia from agriculture. not always possible to attribute 1 December to 28 February in NVZ. There is also • Manure may not be spread on agricultural land closer than 2 meters from an During the period August 1 – October 31, manure exceed 22 kg per hectare available land, counted as facilities for at least 8 months (for cattle, horses, sheep under vegetative cover during the medel/spridagodselmedelhelalandet.4. Sweden SE Provisions applicable to manure include rules regarding e.g. manure storage and spreading. As changes in emissions or losses specific application requirement from 1st August to edge adjacent to a watercourse or a lake. Manure may not be spread on may only be spread on growing crops or before a five-year average. and goats) or 10 months (for other animals). These autumn and winter, in the rest of 207049b811dd8a513dc80002742.html to manure spreading, Sweden has rules that apply on its whole territory (e.g. on application of to a specific legislation or 31 October. agricultural land adjacent to a watercourse or a lake where the slope exceeds 10 %. autumn sowing. Spreading in catch crops is not Within NVZs, there are also regulations limiting the requirements also apply to farms with more than 100 southern Sweden, the requirement is 50 http://www.jordbruksverket.se/amneso manure in winter, maximum quantity that may be spread, etc.), and additional rules that apply action. Model calculations are Manure provided from animals themselves when outdoors should not be counted allowed. Solid manure (except from poultry) may application of manure based on its content of LU outside this area. Farms outside of NVZs must have %. mraden/odling/vaxtnaring/spridagodsel only to NVZs. regularly made of impacts of in the term spreading however be spread on bare soil during the period nitrogen. Within these areas, manure may not be storage facilities equivalent to 6 months manure medel/spridagodselmedelikansligaomra Pursuant to the Nitrates Directive, Sweden initially designated 9% of its territory as NVZ. In improved nitrogen efficiency, Outside NVZ, manure should not be spread on snow covered ground, or during October 1 – October 31, even if the land is not applied in quantities larger than the equivalent of production. Farms with less than 10 LU are obliged to den.4.207049b811dd8a513dc8000276 June 2002, the European Commission demanded that Sweden enlarge the area of designated distribution of crops, conditions where there is a risk that the manure pollutes surface- or groundwater. about to be sown. In NVZ, manure that is spread on 170 kg nitrogen per hectare available land and have storage facilities for 6 months. 5.html NVZs have been designated in England (currently 62%, but will be 58% once the new In accordance with Article 10 England: England: England: England: England: England: Consultation during AMEC (2012), delimitation comes into effect), Wales (3%), Scotland (14%) and Northern Ireland (100%). All of the Nitrates Directive the UK 1/15 September – 15 January for mineral fertilisers. Farmers should not apply fertilisers when the soil is waterlogged, flooded, frozen Farmers should spread organic manures as Farmers should not apply more than 250 kg of total 4-6 months - 6 months in case of farms in a NVZ and at On suitable soils, farmers should sow a Scotland: Alterra (2007) and literature review: farms within NVZs have to comply with an Action Programme (that implements the Nitrates produces a report on the No dated recommendation for organic fertilisers. You hard or snow-covered. accurately as practically possible. They should apply nitrogen in organic manures to any given hectare in least 4 months in others cases, unless the farmer can temporary cover or catch crop in early There is specific requirements recording http://www.defra.gov.uk/food- Directive). implementation of the should not apply mineral fertilisers to grass between They should not apply organic manures within 10 metres of surface waters, and these in late winter or spring when crops can use any 12 month period. All organic farmers certified demonstrate to the Environment Agency that the has a autumn when an early harvested crop is records, in particular concerning farm/land-manage/nitrates- United UK Wales: Directive and results of water 15 September and 15 January and to other crops mineral fertilisers within 2m, including field ditches; or 50 metres of a spring, well the nitrogen efficiently and should use spreading according to Council Regulation (EC) No 834/2007 safe year-round management and field application to be followed by a spring-sown crop. fertiliser application and soil sampling. watercourses/ and Kingdom In Wales revised regulations (The Nitrate Pollution Prevention (Wales) Regulations 2013) are monitoring programmes in the between 1 September and 15 January unless there is or borehole. equipment with a low spreading trajectory when must be within an overall farm limit of 170 kg N per system. All constructed stores should be impermeable There is also advice on the crop to use They also advise to incorporate crop http://www.environment- due to come into force at the end of July. Wales has adopted a CoGAP in addition to The UK. The latest report (for 2008- a specific crop requirement at this time. For organic They should be particularly careful when applying organic manures to steeply spreading slurries to avoid causing atomisation ha per year from livestock manures including and not allow liquids to escape. and the timing. They also advise to residues. agency.gov.uk/business/sectors/13594 Nitrate Pollution Prevention (Wales) Regulations 2013, this is available at: 2011) was completed in 2012. fertilisers, farmers should not apply them in the sloping land close to surface waters, without specific figures. (small droplets) and subsequent drift. nitrogen deposited during grazing Wales: incorporate crop residues. 1.aspx http://wales.gov.uk/topics/environmentcountryside/farmingandcountryside/farming/codesofg The impact of technological autumn and early winter months. This is particularly Wales: Farmers should incorporate into the soil any slurry Wales: 5-6 months. The storage capacity required is 5 months http://wales.gov.uk/topics/environmen oodagripractice/?lang=en development in manure important on sandy and shallow soils where the risk Idem as England. that has been surface broadcast (spread by splash Farmers should not apply more than 250 kg of total storage for cattle slurry and 6 months in the case of pig tcountryside/farmingandcountryside/fa

Appendix D Assessment of Wider Environmental Impacts

Manure Storage: Capacity

The Nitrates Directive requires that the storage capacity exceed the longest period during which land application in the vulnerable zone is prohibited, reproduced in all three options. During storage, the nutrients contained in organic fertilisers can be easily lost due to the solubility of nutrient in water. Hence, the storage of manure in an appropriate container as required by the Directive avoids the potential risk of leaching of nutrient and potentially heavy metals and chemicals in soils. The storage capacity mainly depends on supply, i.e. the number of livestock, the type of livestock, the time during which the animals are annually kept indoors (which also depends on the weather), the quantity of excretion (linked to the production level) and the housing type.

The requirements under the options proposed are similar in nature but different in scope of application. In particular, the options range from the requirements being set as mandatory within the NVZ and as voluntary outside these areas (i.e. the same scope as in the Nitrates Directive), to being mandatory within the NVZ and on farms above a certain size threshold outside the NVZ, up to requirements being mandatory across the whole territory of a country.

Impacts on water It is estimated that about 3% of total N would be lost in leachate in the case of manure stored in the field (cattle/pig farm yard manure and poultry manure), compared to 0.2 to 0.6% in waterproof vessels.(ADAS and Rothamsted Research, 2011). In addition, it is estimated that a one month extension of the close period would reduce nitrate leaching by a further 0.2 to 0.4% of baseline loss, and reduce P loss by 0.3 to 1% compared to the current baseline (ADAS, 2011). This is especially important in NVZs as the water bodies within these areas are considered vulnerable, and would result in low impacts in terms of water pollution outside of NVZs. Increasing requirements about manure storage will not impact water acidification. However, the costs associated with a further one month storage requirement may be disproportionately high.

Impacts on biodiversity and ecosystem services The small impacts in terms of water pollution reduction and thus lower risk of eutrophication may have some impacts on biodiversity with benefits for reaching the good ecological status required in the Water Framework Directive, and on human health in relation to bacteria and nitrates that could contaminate surface water or drinking water. These impacts are however expected to be low.

Impacts on soils As for water, the leaching of N and P may lead to eutrophication in soil (see above for estimated leachage rates).

Impacts on landscape Manure storage facilities may have an impact on landscapes depending on their size and location. The impacts may be reduced by planning controls, particularly for new build units covered by the Environmental Impact Assessment Directive.

Impacts per ambition of the options  Option C (low): this option corresponds to the current requirements of the Nitrates Directive;

 Option B (medium): the proposition of including farms above a threshold based on animal numbers or LSUs seems relevant and appropriate, especially to tackle air emissions. The magnitude of the risks for the environment are higher in the case of larger intensive rearing livestock farms as subsequently they produce a greater quantity of manure quantity to handle, thus requiring careful management. No information was however found on how many of such intensive farms are outside of NVZ, so impacts on water and biodiversity are difficult to evaluate;

 Option A (high): Areas outside NVZ are supposed to be less sensitive than NVZ to risk of leaching of N and P and water pollution. The benefits, in terms of reducing water pollution, of extending the perimeter to the whole country are therefore expected to be low. In addition, extending the perimeter to the whole territory induces consequent implications in terms of infrastructure construction, especially for small farms that may be disproportionate relative to the effective reduction of impacts compared to business as usual (investments in manure storage infrastructures are reported to be high and are one of the main non-compliances with the Nitrates Directive within NVZ already, see European Commission, 2011). However, it would provide a level playing field for all farmers.

Manure storage: cover

There are no specific requirements in the Nitrates Directives regarding the need to cover manure stores but it indicates that storage must be constructed to avoid nutrient losses. The options proposed target the reduction of ammonia emissions to air with different types of cover resulting in different emission reduction levels during storage. The options vary in terms of what level of emission reductions are targeted and thus which techniques for cover are proposed.

Impacts on water The coverage may have positive effects on water pollution. Appropriate water-tight vessels, and in particular coverage, limits ammonia (NH3) emissions and hence potential water acidification. It also reduces nitrification reactions and hence the production of nitrates that could lead to eutrophication.

The coverage is also necessary to limit the amount of rainfall entering the vessel since it could negatively affect the storage capacity and induce spillages of manure.

Nonetheless, reducing nitrogen losses to air (30-40% of the initially N can be lost (Alterra, 2011)) also increases the nitrogen content of manure, and consequently its nitrogen fertiliser replacement value (NFRV). This parameter must be taken into account in order to avoid overdosing while spreading, which otherwise can lead to leaching.

Impacts on biodiversity and ecosystem services As a knock-on effect of reduced water and air pollution, covering of manure stores may have positive effects on biodiversity and ecosystem services. Reduced pollution of water will notably be beneficial to aquatic species. However, an inefficient aeration during storage can induce anaerobic fermentation which results in methane emissions and thus results in odour emissions.

Impacts on soils The impacts on soil are similar to the impacts on water, i.e. risks of acidification in particular.

Impacts on landscape There are no impacts regarding landscape.

Impacts per ambition of the options The options C (low) to A (high) require increasing impermeability therefore allowing farms and subsequently Member States to meet increasingly stringent emission reduction targets. The more waterproof the cover is, the more it decreases NH3 emissions. However, the anaerobic conditions are the most favourable to denitrification reactions that results in the emissions of N2O with a higher production rate than nitrification.

 Option C (low): this option proposes use of a partially sealed cover. It limits ammonia emissions but it may result in air emissions through nitrification reactions, leading to the emissions of nitric oxide (N2O), and some trade-off with risks to water eutrophication due to N remaining in manure;

 Option B (medium): this option proposes the use of plastic sheeting that is a more waterproof than in option C. As for C, this results in a trade-off as more nitrate is conserved in manure, resulting in higher risks when it is spread, thus reinforcing the importance of further mitigation measures when spreading;

 Option A (high): the option proposes a tight lid, which is waterproof. This measure drastically reduces ammonia emissions to air. Nonetheless, it may results in trade-off by creating anaerobic conditions, adequate for bacteria to generate methane and thus induce methane emissions which enhance the denitrification process and subsequently inducing the production of nitric oxide. The trade-off with risks of leaching is higher than in option B.

Manure spreading technique and incorporation

The Nitrates Directive requires that the fertilisers are uniformly spread although it does not set any specific requirements regarding the application techniques. The measures considered in this study aim at reducing volatilisation and, in particular, ammonia emissions during spreading. The three options set targets regarding ammonia emissions reduction and techniques to be applied depending on the type of manure.

Impacts on water

Application techniques, such as injection and trailing shoe, decrease NH3 emissions to air. They also increase the

Nitrogen Fertiliser Replacement Value (NFRV), not only due to the decrease of NH3 losses by volatilisation and

denitrification but also due to a better uptake of N by crops. Indeed, the greater the slurry is in contact with the soil, the higher the immobilisation of N will be, especially in fine-textured soils (AEA, 2010). This should be carefully integrated in the fertilisation plan in order to prevent over-fertilisation that may increase the risk of nutrient leaching, with the risk to cause eutrophication.

A study found that compared with surface spreading, incorporating the broiler litter increased leaching losses from 4.2 % to 13.7 % of N (Sagoo et al., 2004).

Impacts on biodiversity and ecosystem services This option may have an indirect positive impact on biodiversity, in particular in soil. Incorporation may provide better conditions for a range of micro-organisms. The timing of incorporation does not seem to have any influence regarding this benefit.

Impacts on soils The deeper the fertiliser is incorporated, the lower is the risk of volatilisation. Nonetheless, this may have negative effects on the availability of nutrient for crops after their incorporation unless remediating measures are taken such as balance fertilisation, in particular on young crops with an insufficiently developed root system.

The incorporation of manure and slurry, in addition to crop residues, may also have positive impacts on soil in terms of carbon sequestration, soil structure and soil organic matter. Thus, it may have indirect positive impacts on soil biodiversity by providing better conditions for a range of micro-organisms and on soil water retention. However, it can also have negative impacts. Indeed, contractors are often used to apply the low-emissions techniques who tend to use large/heavy equipment (Alterra, 2011), and not necessarily be available when conditions are optimal for spreading. Consequently, damage may be done to the soil structure through compaction, with negative effects on water percolation and retention and soil biodiversity. These impacts are not expected to differ according to the level of ambition (A, B, C).

Impacts on landscape No specific impacts on landscape are foreseen.

Impacts per ambition of the options  Option C (low): the techniques identified in the proposed options do not seem to increase manure N efficiency (AEA, 2010), so the risk of transfer between air and water/soil emissions is limited. The potential of NH3 emissions reduction is lower than for the other options;

 Options B (medium): The ammonia emissions reduction target is similar to option C but the technique proposed is different and proven to be more efficient. The nitrogen content of manure when it is spread must be taken into account to avoid nitrogen surplus and thus risk of leaching to water;

 Option A (high): This option has the most important impacts on NH3 emissions since the injection technique is considered the most effective to reduce these emissions. The reduction target is therefore

higher. As mentioned above, the nitrogen content must be taken into account to avoid nitrogen surplus and thus transfers when spreading. The incorporation timing has no effect on the risk of leaching.

Quantity thresholds (absolute)

The Nitrates Directive requires that the amount of manure applied (including during grazing) in NVZs does not exceed 170 kg N / ha / yr. The Directive, however, allows for other limits to be set under specific circumstances and subject to the approval by the Commission. In practice, some Member States have applied derogations, allowing, for instance, application of up to 250 kg/ha on grasslands. Since there is a positive relationship between livestock density and the N and P concentration in ground and surface water, such measures aim at avoiding nutrient surplus and thus limiting leaching risks. The least ambitious option (C) reproduces this requirement. Option B (medium) proposes to support the application within the NVZ with active support provided outside the NVZ to boost the voluntary uptake rate. . Option A (high) extend the geographical perimeter of the requirements to the whole territory

Impacts on water These measures with level A and B will have little impact as they already apply within NVZ, and zones outside of NVZ are less sensitive to eutrophication. It is unclear to what extent the most intensive livestock farms are already within NVZ, but it is also expected that outside of NVZ the threshold is already met in many cases. Figure 3.9 shows that manure inputs above 170 kgN/ha only occur in the regions of the Low Countries (Belgium/ Netherlands/ Northern Germany), in small parts of Western Ireland, Portugal, Northern Spain, Northern Italy and some parts of Greece (for EU15). In those areas the impact on water quality will be positive.

Impacts on biodiversity and ecosystem services These measures may have some indirect impacts on biodiversity through the slight reduction of potential eutrophication. It may also decrease the contamination by microbes present in manure and thus reduce potential risks for human health.

Impacts on soils These measures will have some beneficial effects on soil by reducing soil eutrophication. Specific attention must be paid to the amount of organic fertiliser applied: the nitrogen present in manure is mainly in a form that is stable and progressively mobilised. This parameter must be taken into account to optimise the timing of spreading, so that nutrients are available to crops at the right time and to avoid nutrient deficiency or over-supply. Indirect impacts may also occur as such thresholds may reduce the total amount of manure spread on land, with knock-on negative effects on soil carbon, soil structure, and soil water retention. This may in turn result in lower soil biodiversity.

Impacts on landscape No impacts on landscape are foreseen.

Impacts per ambition of the options  Option C (low): this option corresponds to the current requirements of the Nitrates Directive. It will not further decrease environmental impacts103;

 Option B (medium): provision of support is essential for boosting the voluntary uptake rate of the application thresholds outside the NVZ. The effect of the measure may have slight positive impacts regarding environmental impacts on water, biodiversity and soil as it is expected to increase the number of farmers applying the measure. The effects, however, are expected to be relatively small as the sensitivity of water bodies outside of NVZ is lower and not all farms would uptake the measure in practice;

 Option A (high): the effect of the extension of the perimeter may have slight positive impacts regarding environmental impacts on water, biodiversity and soil. The effects are expected to be relatively small as the sensitivity of water bodies outside of NVZ is lower.

Quantity thresholds (variable)

Limiting the source of pollution is one of the principal measures to reduce pollution. The Nitrates Directive requires the application to be based on crop needs, which is common to all three options. To calculate the right balance of nutrient to be provided to crops, at the right time requires the following to be taken into account:

 The crop needs (which depends on the type of crop, growing conditions, the expected yield/output and its development stage);

 The nitrogen residue (and more broadly the nutrient residue) from the previous crops, considering the soil nutrient content (nitrogen and phosphorus, but also the carbon content); and

 The nitrogen content of the organic fertiliser (Nitrogen Fertiliser Replacement Value, NFRV).

This results in an optimisation of the input of (organic and mineral) fertilisers, avoiding nutrient surpluses and therefore reduces the source of potential pollution to air, water, soil and other environmental impacts. Balancing the nutrients needs also ensure that crops always have sufficient nutrients for optimal growth. In particular, it decreases the risk of leaching, by avoiding over-fertilisation. The difference between different options proposed is in the scope, varying from NVZ and voluntary (same scope as the Nitrates Directive) to NVZ and voluntary with active support.

According to the AEA study (2010), at a farm-scale, applying manures at moderate rates and applying N fertiliser at times of the year when the apparent N recovery of manure may be limited, may give a greater NFRV than concentrating purely on means to avoid nitrogen losses. Such a strategy will differ from region to region within the EU and also within farming systems. In parts of the EU such as in the Netherlands, Northern Germany, Portugal, or

103 As highlighted in Section 4.5.3 for some elements, e.g. requirements of the Nitrate Directive, Option C corresponds to the baseline and no additional costs or environmental benefits are anticipated. Other elements set out under the Option C correspond to requirements over and above the baseline, e.g. requirements regarding manure storage and manure spreading techniques. Therefore, the option as a whole includes a range of additional requirements to the baseline that are considered in other Section 5 sub-sections.

French Brittany, livestock farming is already so concentrated that the amounts of N applied as manure may be at the limits of application required to comply with the Nitrates Directive (AEA, 2010).

Impacts on water Considering that 30% of the nitrogen inputs are leached as nitrates, balancing fertilisation has a high positive impact, reducing water pollution, in particular eutrophication (IPCC Guidelines for National Greenhouse Gas

Inventories, 2006). Balancing fertilisation may also have positive effects on NH3 emissions, consequently reducing water acidification.

Impacts on biodiversity and ecosystem services These measures may have indirect impacts on biodiversity through the reduction of water and soil pollution.

Impacts on soils The measures will have beneficial effects on soil by reducing soil eutrophication and acidification.

Impacts on landscape No impacts on landscape are foreseen.

Impacts per ambition of the options  Option C (low): not considered;

 Option B (medium): this option corresponds to the current requirements of the Nitrates Directive. It will not further decrease environmental impacts;

 Option A (high): Support is essential for the uptake, and efficient application of the measures proposed by the maximum number of farmers. Calculations are not necessarily easily performed, and may require guidelines and/or software that must be communicated. In addition, soil sampling may be required for precise calculations, so accessibility of services and their costs will be important for uptake. This measure would increase the effect at territory level since it is expected to increase the number of farmers applying the measure, but uptake is very difficult to predict. Communication that shows the benefits for farmers in terms of fertiliser costs saved may also increase uptake.

Timing of application

Definition of the closed periods and the prohibition of manure application on water-saturated, flooded, frozen or snow-covered ground are elements required in the Nitrates Directive and reproduced in all three options. The main objective from such measures is to reduce risks of leaching by increasing crop nutrient uptake, and to avoid conditions in which manure is applied when the leaching and/or run-off risk is high. The difference is the scope, varying from NVZ and voluntary (same scope as the Nitrates Directive), to NVZ and voluntary with active support, and to whole territory.

Impacts on water Setting closed periods and requiring that application in certain conditions is prohibited will reduce the risk of nutrient run-off (Moncrief, et al., 1999). This is specifically important in NVZ, where, by definition, water bodies are considered vulnerable. In other areas, the environmental benefits would be smaller. Indeed, in zones not considered vulnerable, the pedology and/or hydrogeology and the condition of water bodies will lead to low resulting impacts from reduced leaching. This option will not impact water acidification.

Impacts on biodiversity and ecosystem services Since impacts on eutrophication are expected to be small, its impacts on biodiversity are expected to be low. This policy option also indirectly impacts on biodiversity through the effect on soil management practices, causing less disturbance in winter. However, it is not expected to have important impacts on biodiversity or ecosystem services.

Impacts on soils Similar to biodiversity, the impacts on soils and landscape will mostly be indirect and are not expected to be high. Soil eutrophication may be a risk, and pollution by heavy metals may be reduced during prohibition periods (although heavy metals are more of an issue linked to accumulation over time). Reduced application of manure may also indirectly reduce the carbon content of soils, with negative impacts on soil water retention and soil structure, potentially increasing soil erosion.

Impacts on landscape No impacts on landscape are foreseen.

Impacts per ambition of the options  Option C (low): this option corresponds to the current requirements of the Nitrate Directives. It will not further decrease environmental impacts on water, biodiversity or soils104;

 Option B (medium): Active support is expected to increase the uptake in zones where it is not mandatory (i.e. outside NVZ). This would have relatively small benefits for water, biodiversity and soil;

 Option A (high): As the impacts are relatively small in zones not vulnerable to nitrate pollution, it is not expected that the extension to the whole territory will have important impacts for water, biodiversity or soil.

104 As highlighted in Section 4.5.3 for some elements, e.g. requirements of the Nitrate Directive, Option C corresponds to the baseline and no additional costs or environmental benefits are anticipated. Other elements set out under the Option C correspond to requirements over and above the baseline, e.g. requirements regarding manure storage and manure spreading techniques. Therefore, the option as a whole includes a range of additional requirements to the baseline that are considered in other Section 5 sub-sections.

Areas of application

The prohibition of application on steeply sloping ground or areas near water courses are elements required in the Nitrates Directive and reproduced in all three options. The main objective from such measures is to reduce risks of leaching and/or run-off by avoiding conditions in which the risk is high, and the receiving area (water) sensitive. The difference is the scope, varying from NVZ and voluntary (same scope as the Nitrates Directive), to NVZ and voluntary with active support, and to whole territory.

Impacts on water As in the case of the option „Timing of application‟, the fact that the option is applied outside of NVZs is expected to have relatively low impacts with regards to water.

Impacts on biodiversity and ecosystem services The impacts are expected to be similar to those of the option „Timing of application‟, i.e. relatively low.

Impacts on soils The impacts are expected to be similar to those of the option „Timing of application‟, i.e. relatively low, but with potential benefits in reducing pollution by heavy metals, and reducing negative impacts on soil carbon, soil eutrophication, soil water retention and soil erosion.

Impacts on landscape No impacts on landscape are foreseen.

Impacts per ambition of the options  Option C (low): this option corresponds to the current requirements of the Nitrates Directive. It will not further decrease environmental impacts to water, biodiversity or soil105;

 Option B (medium): Active support is expected to increase the uptake in zones where it is not mandatory (i.e. outside NVZs). This would have relatively small benefit for water, biodiversity and soil;

 Option A (high): As the impacts are little in zones not vulnerable to nitrate pollution, it is expected that the extension to the whole territory will have slightly beneficial impacts for water, biodiversity or soil.

105 As highlighted in Section 4.5.3 for some elements, e.g. requirements of the Nitrate Directive, Option C corresponds to the baseline and no additional costs or environmental benefits are anticipated. Other elements set out under the Option C correspond to requirements over and above the baseline, e.g. requirements regarding manure storage and manure spreading techniques. Therefore, the option as a whole includes a range of additional requirements to the baseline that are considered in other Section 5 sub-sections.

Fertiliser plans

Fertiliser plans require that farmers take into account the expected crop needs for nutrients, and the nutrient supply from soil (resulting from remaining nutrients from previous season, mineralisation, manure additions, and other fertiliser inputs), in order to calculate the additional inputs of nutrients required by the crop and avoid surpluses. The balance may be done taking into account the previous year only, or several years (the latter having additional benefits in terms of reducing environmental impacts). The plan may take into account nitrates, phosphates, potassium, but also agricultural additives such as lime. For nitrates, this is required in the Nitrates Directive within NVZ as part of the Action Plans, and is an optional measure to take into account in Codes of Good Agricultural Practices. Taking into account such a plan may have positive environmental impacts, by reducing surpluses that would otherwise be emitted to air, soil or water.

Impacts on water Fertiliser plans would contribute to reducing surpluses of nutrients (depending on the scope, e.g. which of N, P and/or K are taken into account) ultimately reducing the risk of leaching to water and subsequent eutrophication. The requirement would be the most beneficial in NVZ assuming P use was to be taken into account.

Impacts on biodiversity and ecosystem services By reducing the risk of leaching, eutrophication is reduced, and consequently its impacts on biodiversity.

Impacts on soils The option will also have positive impacts on soils, through reduced soil eutrophication, and more effective fertiliser use taking into account crop needs. Impacts on soil carbon and soil water retention will depend on how fertiliser plans will affect how much organic matter is spread on land as a result, in part depending on whether carbon is taken into account in fertiliser plans.

Impacts on soils and landscape No impacts on landscape are foreseen.

Impacts per ambition of the options  Option C (low): not considered;

 Option B (medium): fertiliser plans should already be considered in Action Plans within NVZ, and are considered in some MS within the voluntary Codes of Good Agricultural Practice. Some additional benefits could arise from implementation in other MS, but as this measure would remain voluntary, benefits would be highly uncertain;

 Option A (high): The uptake is expected to increase with active support of the measures, but remains very difficult to evaluate. In case of wide uptake of the option, this would increase the efficient use of

nutrient resources, with beneficial effects on pollution reduction, but also on crop yields, reduction of fertilisation costs etc.

Farm management

Farm management decisions can influence levels of pollution. For example, high input/high output farms may be more likely to pollute than low input/low output farms, simply because of the higher level of inputs used. Furthermore, high input farms will, by definition, rely more heavily on nutrients (whether as fertiliser or feed) imported onto the farm. In the case of purchased feed, a portion of it will ultimately become manure or slurry and will need to be processed or spread. For grazing livestock, stocking rate is the usual indicator of farming intensity, so farms with higher stocking rates will pose a greater risk than those with lower stocking rates. However, larger, more heavily stocked farms may also be better managed, and so the risks may also be better controlled.

Within a farm system, there is further scope to apply management techniques that will help reduce pollution risk, in particular by balancing nutrients and pesticides budget:

 Rotating crops on arable farms is standard practice to help control pests and diseases, thus promoting crop vigour. Healthy crops will be more likely to take up nutrients than an unhealthy crop;

 It is standard practice to follow leguminous crops with the more demanding (in terms of N) non- leguminous crops (such as winter wheat), so that the nutrients are used most cost-effectively;

 There may be opportunities for the use of catch/cover crops to minimise risk of leaching during the winter, rather than leave ground bare (although this may be detrimental to some over-wintering brids);

 For grassland farms, permanent pasture will present a lower risk of nitrogen loss than temporary grass leys (although the ploughing out of long-term leys can produce a surge in N leaching).

Following crop rotations is an agricultural practice with many benefits, but one that require more work from farmers than mono-cropping. The integration of manure applications across a whole rotation is a more effective means of reducing nitrate leaching than considering only the single crop to which the manure is applied even when the current rules on application timing and rate were followed. Crop rotations associated with protein and leguminous crops may help immobilise nitrogen and reduce risks of emissions to air or water. Moreover, the rooting system of the leguminous crop, the permanent crops and the winter coverage may help increase soil organic matter, carbon sequestration, stabilisation and soil structuring, hence decreasing the risk of erosion. Indirectly, it may have positive effects on water retention and nitrogen uptake by plants, preventing leaching risks. It may also have positive effects on biodiversity, providing habitats and food for animals such as insects (in particular, bees) although this will of course depend on the crops grown.

Permanent crops reduce the amount of bare land which increase risks of leaching as a result of rain, and reduced tillage will reduce N2O emissions (in certain soils) and also reduce risks of leaching. Similarly, minimum vegetation cover will avoid leaching due to rain.

Crop rotations, areas with permanent crop and winter cover crops are already options proposed by the Nitrates Directive to be included in the Codes of Good Agricultural Practice. In addition, the proposition for a future CAP

includes elements such as GAEC 4 on minimum soil cover. The latest agreed reform of CAP includes requirements for arable farmers to grow more than one type of crop (requirements for number and proportions of different crops depend on cropped area).

Impacts on water Such measures will increase crop vigour and so uptake of nutrients, and reduce the risk of leaching (with appropriate incorporation management). A study found that the use of catch crops reduced N leaching loss by 23% to 38% (Olesen et al., 2004), while another estimated the establishment of cover crops on all land with spring cropping would reduce nitrate leaching from agricultural land within NVZ by 4-7% (ADAS, 2011). This will have most benefits in NVZ, reducing eutrophication. In addition, cover crops would help reduce losses to water of P (0 to 1%) and sediments (0 to 2%) (ADAS, 2011). Indirect benefits will arise from crop rotations, reduced tillage and vegetation cover on soil water retention. Uptake of phosphates and other potential pollutants will also increase.

Impacts on biodiversity and ecosystem services By reducing the risk of leaching, eutrophication is reduced, and consequently its impacts on biodiversity. Indirect benefits will arise from crop rotations, reduced tillage and vegetation cover on providing habitats to species, in particular soil biodiversity, and insects (depending on the crops used for vegetation cover), with knock-on benefits to other species. Vegetation cover will also reduce soil erosion risks by water and wind.

Impacts on soils The option will also have beneficial impacts on soils, through reduced soil eutrophication, beneficial impacts on soil structure through rooting systems in the rotation, increased carbon sequestration and storage, water retention, as well as soil biodiversity benefits.

Impacts on landscape A variety of different crops will add variety to the appearance of the countryside.

Impacts per ambition of the options  Option C (low): no low level considered;

 Option B (medium): such measures are considered in some MS within the voluntary Codes of Agricultural Good Practices. Additional benefits would arise from making them required in NVZ and voluntary elsewhere, as for the moment it is mostly voluntary;

 Option A (high): The uptake is expected to increase with active support of the measures, but remains very difficult to evaluate. In case of wide uptake, the measures would have many benefits in terms of their environmental impacts, as they are widely recognised as not only reducing pollution, but also increasing carbon sequestration and storage, water storage, supporting biodiversity, etc.