On course to safeguard the single payment


A NEW YEAR, a new rule book: Cross-compliance kicks in from Jan 1, 2005. Peak District farmer Andrew Critchlow is reasonably confident that his farm business, set in the picturesque moorland west of Sheffield, will be compliant.

“As a small family farm, we couldn’t afford to lose any part of the single farm payment in penalties, so it’s crucial that we don’t break any of the rules.”

Having scrutinised DEFRA’s Cross- Compliance Handbook, sent out in December, his main worry is whether he might be falling foul of the Nitrate Vulnerable Zone (NVZ) regulations. These regulations are listed as one of the eight Statutory Management Requirements (SMR) – see box. His land lies in the outermost reaches of the River Trent catchment area which, since November 2002, has been designated an NVZ. This area is classed as “medium risk”, which is a higher rating than might be expected were it an arable holding. That’s because of the risk of non-compliance from farmers with livestock enterprises, explains Bob Marsden, policy adviser with the Environment Agency.

Manure, largely slurry, from the 45-cow dairy herd and followers is collected, stored and then spread. “What I am unsure of is whether I”m breaching the nitrogen limits, even though we”re not an intensive business,” says Mr Critchlow.

I ‘ ve already been influenced by the single farm payment. I”ve cut down the number of sheep bought in last autumn, from 230 to 170, as I don’t need the numbers to maintain my sheep quota.”

 Mr Marsden checks out the figures. It’s not a difficult calculation. “You’re well below the limits,” he confirms. Crop need for first cut silage is 120kg N/ha; Mr Critchlow applies 80kg N/ha as inorganic fertiliser plus 24kg N/ha as manure, and only 60% of this is available N to the crop. “This is well within crop need, and the upper grass field limit of 250kg N/ha total nitrogen from organic manure, and the farm complies with the whole farm organic manure loading limit.

 What you are falling down on is record keeping. So you won’t have to change any of your practices, but you will have to start recording manure applications.” Stocking rates can be averaged out over the farm including the moorland. Mr Critchlow”s animals produce on average 27kg N/ha in total, well within the limit for whole farm organic manure loading.


“My record keeping hasn’t been very good up to now,” admits Mr Critchlow. This issue is crucial, says Mr Marsden. “I can’t stress it too strongly. You must keep good records of manure and fertiliser applications, as well as meeting the environmental requirements of SMRs, or your single farm payment could be penalised.”

A certain percentage of farms will be inspected every year, and farmers must be able to demonstrate appropriate record keeping as part of compliance.

But there’s help at hand, says Mr Marsden. For example, Planning Land Applications of Nutrients for Efficiency and the Environment (PLANET), effectively a computerised version of the DEFRA Fertiliser Recommendations book RB209, is freely available, as CD or as a downloadable program from www.planet4farmers.co.uk. Using this, farmers can record all their individual fields, soil types etc and the manure applications, and it will give inorganic fertiliser recommendations which automatically ensure that farmers are within the regulatory limit for crop need, as well as serving as a record-keeping tool. “It’s a complete nutrient management system, which produces a nutrient management plan for the farm. There are points awarded for this in the Entry Level Scheme, helping farmers qualify for the 30/ha,” says Mr Marsden.


The NVZ Manure Planning Booklet – England (PB5504) is also helpful. This was sent out to all farmers in NVZs and can also be downloaded on the DEFRA website.

In terms of manure application practices, Mr Critchlow is awarded full marks. He only applies manures when conditions are right – avoiding wet and freezing weather. No manure is spread within 10m of a water course, 2m of a hedgerow, or on steep slopes. Manure is not applied to moorland.

So regarding the new Good Agricultural and Environmental Condition (GAEC) standards, Mr Critchlow is fairly confident that he”s compliant. The only field operation which might breach GAEC 3, on waterlogged soil, would be manure spreading, and this is always done when conditions are right.

The farm has adequate storage facilities – providing capacity for four months, which eases pressure on spreading. Because the farm does not have shallow or sandy soils, there is no closed period for manure spreading. He complies with GAEC 14, which protects hedgerows and watercourses, by not spreading manures or fertilisers within 2m of the centre of a hedgerow or watercourse.

GAEC9, covering overgrazing and possible damage due to supplementary feeding, was initially a concern. Poaching around feeders can be unavoidable, for example, says Mr Critchlow. But with common sense, damage can be minimised, he agreed. “I’ m relaxed about that now.”

The farm does have stone walls, and these are protected under GAEC 13. That’s not a problem for Mr Critchlow. “We maintain walls on the farm. It’s nothing new for us.”


With the Pennine Way starting on his land, he has taken careful note of GAEC 8, covering public rights of way. But again, there is nothing new in the regulations; he’s lived with the fact that many walkers cross his land throughout the year and does not have any problem with dealing with tourist traffic. “The Peak Park has flagged some of the paths, particularly the Pennine Way, which had gullied so deeply due to walkers that I couldn’t cross them with the tractor.”

Soil management is a new issue with GAEC 1. For the moment, all that’s required is that Mr Critchlow reads and “takes account” of the guidance for soil management, which will be sent out as a booklet to all farmers shortly. But in 2006, he will have to draw up a soil management plan. “I do wonder why there’s a need for this here. It”s a sledgehammer to crack a nut, surely?” Mr Marsden agrees that it may seem so in this case. “But this is a permanent pasture farm. In some places soil management is a big issue.” A soil management plan for Mr Critchlow’s holding would be straightforward, he adds. “It would need to state, for example, that cows would be brought in when soil was waterlogged, to protect against poaching.”

SMR 2 – dealing with groundwater – does affect the sheep enterprise. Spent sheep dip can be disposed of on the farm because Mr Critchlow has obtained the required groundwater authorisation from the Environment Agency. This was granted on a section of suitable land where there is minimal risk to groundwater. “It was a straightforward process,” he says.

“Beware,” says Mr Marsden. “Changes to legislation under the Landfill Directive and forthcoming Agricultural Waste regulations mean that it will be more difficult for contractors to take the spent sheep dip away with them. As a result, more farmers will need to dispose of used dip on their own land. This includes used dip from sheep showers.

 “Any farmers disposing of used dip on their land must make sure they have a Groundwater Authorisation from the Environment Agency in place in time for dipping operations this summer,” says Mr Marsden. “The penalties are likely to be severe, under cross-compliance, for disposing without a permit.”

As well as used dip, farmers disposing of pesticides, sprayer washdown and biocides such as disinfectants from foot baths need to check now to ensure they have an appropriate permit; contact the local EA office, he advises.


Sewage sludge is not spread on the farm, so SMR 3 is not applicable. But it should be noted that new rules on sludge are scheduled for later in 2005, and SMR 3 will be updated. With most of his moorland grazing designated SSSI, Mr Critchlow already complies with habitat and wild bird regulations, so SMR 1, 5 and GAEC 5, 6, 15, 16 and 17 are covered. With no arable production, there’s no set-aside on the farm, so GAEC 12 is not applicable. SMR 6, 7 and 8, covering animal identification and registration, are complied with already. With all the farm in permanent pasture, there is no set-aside requirement.

“So most of the GAEC and SMR requirements are things that we”re doing anyway,” says Mr Critchlow. He’s keeping a keen eye on the new Environmental Stewardship agri-environment schemes due to be introduced in 2005. He plans to enter the Entry Level Scheme and, eventually, hopes to be in the Higher Level Scheme.