First a brief intro to the EA EA involved with various environmental areas, including…. I work in EM, which is all about pollution and more importantly prevention of pollution, and improving the environment. Part of our work is with sites that have permits or authorisations with conditions to protect the environment, such as a waste site permit to operate, a farm may have a licence to abstract groundwater for use, and a water company would have a permit to discharge treated sewage effluent. We also enforce pollution prevention regulations applicable to farms or other businesses. We advise on complying with these and preventing pollution. And as pollution is an offence, we investigate and enforce where incidents occur. 7 regions to EA. Here in South East, your local area contacts are based in the Wallingford office
Content
Farm selection How we regulate The farm inspection What if we find something wrong..
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What I am going to cover in this presentation
Farm Selection Water Framework Directive
Known issues and incident reports
High risk crops
Other evidence of risk
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WFD failing water bodies Proximity to rivers Slopes Risk practices Known issues
Incident Response and Follow up
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We received 2585 slurry store related incident reports between 2001 and 2012
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We have an objective (KPI) to reduce the number of Cat 1 and 2 incidents we have. Concern persists that as farm infrastructure gets older we may see more incidents.
How we Regulate Cross Compliance now done by RPA We target farms based on evidence Pragmatic approach to reduce pollution Farm visits
Discuss issues that impact the environment Identify legislative requirements which are not being met Give advice and guidance to address these Work with you to agree an action plan
Enforcement action
Post visit letter with action plan
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Target farms based on evidence – e.g. WFD (evidence based targeting in each catchment), incidents etc. We don't like to use enforcement action – we would much rather work with you to achieve a good environmental outcome. We understand that there are numerous pressures on farmers, however we need to make sure that the environment is kept clean and regulate effectively against the legislation in place to protect the environment.
Post- visit letter with action plan
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Example action plan – clearly set out into issue, action and time scale.
UNCLASSIFIED
‘Conventional’ regulation
Nitrate Pollution Prevention Regulations 2008 (NVZ) Sludge Use in Agriculture Regulations 1989 SSAFO, as amended 2010 etc. EPR 2010
IPPC Pigs and Poultry Former Groundwater Authorisations Waste Management (Exemptions, Mobile Plant) Hazardous Waste Water Abstractions (especially Spray Irrigation)
Radioactive Substances Act 1993 9
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Illustrates the scope of our regulatory role and why EOs destined for on-farm work need additional training. RSA is included for anecdotal purposes (radioactive crop flow measurement devices on Massey-Ferguson combines). We remain a Competent Authority for XC SMRs 2 - 4 in spite of no longer undertaking targeted inspections.
What might you be asked to discuss during a visit?
Nutrient management and efficiency Farm infrastructure Soil management and structure Yard drainage Connectivity to Rivers Farm tracks Vehicle wash areas Pesticide storage and handling
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Nutrient management and efficiency Farm infrastructure Soil management and structure Yard drainage Connectivity to Rivers Farm tracks Vehicle wash areas Ditch management
A Nitrate Vulnerable Zone (NVZ) is designated on all land draining to and contributing to the nitrate pollution in “polluted” waters. Polluted waters include: Surface or ground waters that contain at least 50mg per litre (mg/l) nitrate Surface or ground waters that are likely to contain at least 50mg/l nitrate if no action is taken Waters which are eutrophic, or are likely to become eutrophic if no action is taken
New changes Must provide 5/6 months storage of slurries
Tougher response to lack of storage No records No risk map
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I am just going to pull out some key messages in relation to NVZ New changes Came into force May 2013 Revised NVZ areas From 17 May 2013 the following new allowances apply: If you grow grass for production of chlorophyll or high protein fodder, you can now apply more nitrogen – see Chapter 7. You can now use compost containing up to 1,000 kg nitrogen in any four year period as a mulch in top fruit orchards – see Chapter 8. You can now use compost containing up to 500 kg nitrogen in any two year period either as a mulch or worked into the soil – see Chapter 8. If you use precision spreading equipment, you can now spread manure to within 6m of watercourses – see Chapter 8. • If you operate a low intensity farm you do not need to keep certain fertilisation records – see Chapter 5. Must provide 5/6 months storage of slurries. – 5 months for cattle slurry and 6 months for pig slurry. Tougher response to lack of storage – 50% of farms in NVZs (England) do not have the required storage capacity (6 months storage capacity for pig slurry, 5 months for cattle slurry). Farms designated since 2009 should have had the required slurry storage by 1st Jan 2012. Why it matters - The extreme wet weather of 2012 has reinforced the need for adequate slurry storage. Those farmers with the legal minimum storage volume (or more) were able to manage better in this difficult period, and so reduce their adverse impacts on soils and water. Adequate storage will help you to - maximise the N, P and K value of slurry; spread at the right time to maximise yields; spread less often and in better conditions to protect soils and save fuel; reduce the risk of prosecution for causing pollution; reduce the risk of an uninsured environmental liability claim against you. Adequate storage is necessary because - stores that are too small are more likely to overtop; when your store is full you may be forced to spread in unsuitable conditions; diffuse pollution from agriculture is contributing to damage of the water environment in up to 25% of rivers in England; poor water quality affects biodiversity and impacts on communities and businesses. No records No risk map Risk map must be present and have on it colour coding to identify the risks; Each field and its area in hectares Surface waters Any springs, wells or boreholes on holding or within 50m of the holding boundary Areas with shallow or sandy soils Land with a slope more than 12 degrees Land within 10 meters of surface water and within 50meters of a spring well or borehole (no spread zones) Land drains other than sealed impermeable pipes Temporary field heap sites (dated!) Land which has low run off risk (that you intend to spread on) This is ongoing – must update it within 3 months of change in circumstances – mark new field heaps on etc.
Nutrient Management Planning Nitrogen use – the four stage plan
Proof of assessing soil nitrogen supply (SNS) Assessment of crop need Calculate available N from organic manure applications Calculate amount of bagged N needed
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Planning N use Must show evidence of this and hold records. Even if agronomist does this part you must keep a copy Check nutrient sampling – advised every 3-5 years for arable crops. Check indices are at target levels. Check target levels against nutrient applicaiton to check this is appropriate. E.g. P indicies 3 and above for arable and forrage crops should mean zero P requirement.
Nutrient Management Nutrient sampling
Are P and K at target
indices (2-2+)?
Options for storage of FYM Field heaps: no more than 12 months, No return for 2
years, Not with 10m of water course or field drains. Mark on risk map. In yard storage: On concrete (not cracked) with run off contained. Runoff may be low in N but is still high BOD. Minimise surface area of the field heap.
Dirty water – Mostly water with some sediment/dung contamination from lightly contaminated yards. Low in N and P. No closed periods but is still contaminating. Do not allow cattle feeding areas (Slurry) to wash to soakaways.
Dirty water
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Dirty water – as defined under NVZ. Run of a yard manure pile is not dirty water but slurry under NVZ due to higher levels of contamination than ‘light’. Must contain run off and comply with storage requirements.
Control of Pollution (Silage, Slurry and Agricultural Fuel Oils) Regs 1991 (SSAFO)
Control building and design of Storage facilities. Applies to all structures post-1991
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Change to notification requirement; The new requirement is for you to notify the EA at least 14 days before starting work on new stores or refurbishment of existing storage The new notification arrangements will apply to any silo, slurry or fuel oil storage system whose construction starts on or after 15th June 2013
SSAFO
A fifth of slurry stores inspected by the EA in 2012/early 2013 were deemed non complaint with the SSAFO storage volume (4 months), of which 36% were judged to be causing environmental harm
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SAFFO Requirements for construction of silage containment, slurry containment and Ag fuel oil Pre 1991 structures are exempt – unless risk to the environment Slurry storage requirement = 4 months (if inside NVZ then NVZ more stringent standard of 5 months for cattle and 6 months for slurry)
Impermeable surface resistant to acidic conditions
Drainage channel to contain any leachate
Impermeable walls with no gaps strong enough to take weight
Silage made at >30% DM to reduce leachate
Rain running through the silage after silage is unwrapped is dirty water.
SSAFO - Silage
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Silage Clamp requirements Mention labels Also mention perimeter drains outside the clamp and requirement for a tank of a certain size.
SSAFO - Silage
No perimeter drains to collect effluent
No effluent collection tank
Bunded fuel tank in good condition
Location out of the way so it cannot be knocked over
All pipe work inside the bund and locked away
Impermeable base to prevent ground contamination
SSAFO – Fuel oil
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About £2000 for a tank, clean up cost can be much higher than this
No bund
Pipework is out side of a bund
Surface water drain
Rusting fit for purpose?
No lock to prevent unauthorised access
Dripping tap will soak into the ground
SSAFO – Fuel oil
This surface water drain is directly below the fuel filling area. Move it or have emergency covers.
SSAFFO – Fuel oil
Reception pit. Must be 2 days capacity and have cut off valves
Tank must be built to 20 year standard
Must be able to contain 4 months storage
SSAFO - Slurry storage
SSAFO - Slurry storage
Not within 10m of watercourse Suitable soil – 20-30%
clay
Impermeable soil - <0.000001mm per second.
Impermeable soil at least 1m thick at base
Yard Drainage
Surface and foul water separation Concrete condition Sediment trapping Vehicle wash areas
Pesticides storage and handling
Spraying operations Buffer zones Management of pesticide washings Certification Pesticides are high risk for watercourses
Biobed
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Spraying operations – check weather conditions before spraying (wind = spray drift), use nozzles to reduce spray drift where possible (precision equipment), use deflection plates to protect watercourses from drift, watercourse buffers, take care when spraying uneven corners, keep tyres clean as sprayed soil can transport pesticide, are field drains running? Management of pesticide washings – wash out in field, biobed. Certification – Neroso Pesticides are high risk for watercourses – aquatic environment very sensitive, invertibrates. E.g. Recent kennet chloropyphos pollution. Kilometers of the kennet were wiped out in terms of invert life. Analysis think only 1 teaspoon of product caused this effect.
Connectivity to water courses
High risk activities
Pathways for sediments
Soil management and slope
Soil Management
Soil Protection review Farm tracks Poaching River banks Compaction Run-off
Track before
Track after
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Only mention this as there is a more detailed talk on SPR I am going to speak more specifically about one particular issue that – cattle and livestock access to the watercourse.
Livestock access to watercourses
Damage to bank Sediment released into watercourse Faeces in watercourse Poaching Run off
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May cause collapse of banks and loss of productive land Sediment released is damaging to fish and invertebrate habitat Animal wastes are deposited directly into the water. Risk of pathogens. Poaching of soil causes compaction and increased runoff risk
Benefits to restricting livestock access to watercourses
Complies with GAEC1- soil protection review so no loss of SFP In line with code of good agricultural practice Reduce risk of erosion Reduced risk to livestock of waterborne diseases and injury
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GAEC 1 is a required under cross compliance – you need to highlight soil risks in SPR and address these. Restricting livestock access to watercourse demonstrates compliance with this so no loss of single farm payment.
Potential Solutions
Pasture pump
Mains water trough
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Mains water trough. Need to site away from watercourse and ensure doesn’t become poached with runoff to watercourse. Not always possible as cost an issue and not all fields will have access to mains water. Alternative is pasture pump as once installed still get free water and no environmental issues. Main things to consider are they need to be checked daily and not suitable for use throughout winter as may freeze. Successfully used at Chimney Meadows a Wildlife Trust farm for years. May need more than one. One suitable for about 30 cattle. Practical tips from the farmer are things like putting the tube in a small bucket with a filter. About £300 to buy.
Cattle drinking bay •Post and rail fencing;
• Access ramps with max. 1:4 slope;
• Drinking bays at least 3m wide;
• Stone or hardcore base.
Potential Solutions
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These are only a partial solution but better than nothing. Bear in mind that will need a Flood Defence Consent. These can be applied for at the Environment Agency. We can help you with the forms and the paperwork for this. In a number of cases we have helped the farmer with the form and method statement so that the consent has been granted. If we hadn’t helped the farmers wouldn’t have stuck with it.
Sludge regulations and land spreading
Control of the PTEs. Be aware it is your responsibility to know what nutrients are in the soil and if you can take the waste. We permit land spreading of waste to land (e.g. Food, compost). Permit SR2010No4 and exemptionU10/U11 required.
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PTE = potentially toxic elements Sludge regs – cover the spreading of sewage sludge to land. You must not apply above crop need, so be aware of all the nutrients that this applies to. Landspreading – covers that spreading of waste materials to land for agriculture benefit. Must be carried out under a permit, and each spreading operation is done under a ‘deployment’. A statement of Ag benefit must be completed for each deployment.
EPR waste exemptions
New exemption system Need to check the criteria of the new exemption Register online for free Should be done 1st Oct 2013
What happens if we find non compliant issues
We want to raise awareness of pollution risks. Will work with you to find a solution. We may point you to sources of support. We can take enforcement action/RPA. Please take any advice that is given.
Any Questions? Useful info •Nitrate Vulnerable Zones in England: guidance on complying with the rules for 2013 to 2016 https://www.gov.uk/government/publications/nitrate-vulnerable-zones-in-england-guidance-on-complying-with-the-rules-for-2013-to-2016 •Registering waste exemptions online http://www.environment-agency.gov.uk/business/sectors/32779.aspx •Any questions in the future – pick up the phone or email us, come and see me for my contact card
