Cross-compliance: How arable farmers can watch out for possible pitfalls

SMR 4 – NVZs

The main area growers are falling down on is Nitrate Vulnerable Zones, according to Frontier adviser Alistair Bell. “Growers must ensure they do not exceed crop requirement when applying nitrogen fertilisers and they take into account their manure when calculating total nitrogen requirement.”

In certain situations the soil nitrogen supply index in DEFRA’s fertiliser bible, RB209, does not allow growers to apply as much nitrogen as they may have thought, he notes. For example, following set aside the SNS can be as high as four depending on soil type and annual rainfall. It’s why a system such as DEFRA’s PLANET programme or similar balance sheet approach is required, he says, along with guidance from a FACTS-qualified adviser. Growers can then show how their nitrogen values have been calculated and, most importantly, justify the crop requirement.

Growers are also failing to keep the required five-year records of cropping, livestock numbers, nitrogen fertiliser and manure usage, he says. “This is especially with respect to manure. An inspector would expect to see records in an easily digestible form, ideally on computer or in a written format that demonstrates exactly how much has been applied and when to individual fields.”

On densely stocked farms many are getting close to the stocking limit specified in the NVZ handbook, adds colleague Andrew Havergal. In this case growers must ensure that records tally if exporting manure to other farms.

GAEC 14 – Protection of hedgerows and watercourses

An area causing some confusion is the maintenance of green cover, restriction on cultivating, applying fertilisers and pesticides within 2m of the centre of a hedgerow or watercourse, or 1m from the top of the watercourse bank. This 2m restriction is not an average, says Mr Bell. “I see a lot of farmers who are non-compliant because they have between 1m and 3m alongside hedgerows.”

Similarly on ditch banks many growers are making a rough guess and taking a line down the field when it comes to cultivations thinking that it is going to be OK, says Mr Havergal. He advises growers to leave a strip wider than 2m to be on the safe side.

GAEC 8 – Public rights of way

Obstructing rights of way or not reinstating footpaths quickly enough after drilling is an area where not only the RPA will penalise growers but also local authorities can intervene, warns Mr Havergal. He suggests growers build up a relationship with local county footpath officers and ask for advice rather than waiting for a problem to arise.

GAEC 1 – General requirements for soil management and protection

A small percentage of growers have yet to fill in their Soil Protection Review, which should have been completed by 1 September 2006.

Retention of literature

Although farmers rarely throw anything away relating to DEFRA, laying their hands on it can be a different matter. Growers will be non-compliant if they don’t, for example, retain their copy of the Cross Compliance Guidance for Soil Management 2006. So having this and all other required literature to hand quickly is important, says Mr Bell.

Maintaining good records

Crop protection records must be maintained throughout the season. RPA inspectors have the authority to check all records relating to the purchase and use of plant protection products, says Mr Havergal, so taking extra care to ensure all applications are within the label is crucial. Keeping a copy of the newly published Pesticides Code of Practice for Using Plant Protection Products (formerly the “Green Code”) is the easiest way to demonstrate compliance.

And don’t forget

The whole farm organic manure loading limit, for any arable areas on their farm, dropped from 210kg/ha of N a year to 170kg/ha a year on 19 December 2006.

This applies to all farms in England and Wales designated in 2002 and using organic manures, whether producing or receiving them.


Frontier’s Whole Farm Advisory Service is a flexible package of services for growers, completed on farm by in-house agronomists.

The components include detailed advice on all of the current cross-compliance legislation, specific on-farm advice to help growers get the most out of the ELS and a Health and Safety Audit.

For more information contact Frontier’s arable development manager, Edward Downing, on 01603 814 263.

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