Senedd Cymru	Welsh Parliament
Pwyllgor yr Economi, Masnach a Materion Gwledig	Economy, Trade, and Rural Affairs Committee
Rheoliadau Llygredd Amaethyddol	Agricultural Pollution Regulations
Economy(6) APR02
Ymateb gan: Ymateb unigol	Evidence from: Individual response

I have an objection to the all Wales NVZ rules based on local climatic conditions and on being an organic dairy/arable farmer.

Before I give my argument I would like to state that I do not want to see pollution of our waterways any more than you all do, also I am very keen on nature conservation, especially bumblebee conservation.

I am farming in a rain shadow area with a low rainfall (762.2mm per year)compared to the all Wales average (1460.3mm/yr) metoffice.gov.uk. All figures quoted are from the last 30yr period available 1981-2010.They compare Hawarden airport to all Wales averages .We also have higher max temps of 14 degrees Celsius compared to all Wales of 12.6degrees Celsius.

This means that the way we farm is considerably different to those who have a different climate. We farm on fast drying alluvial silts ,left from the river Dee reclamation in the late 1700s.This means our crop growing conditions our considerably different from other parts of Wales. With average temps between 1 and 2 degrees higher in July and august and rainfall averages of 56.5mmjuly,57mm august compared to all Wales averages of 92.6mm July ,107.4mm august .metoffice.gov.uk1981/2010.

In fact we find grass growth is much more on the shoulders of the year than it is in June, July and august, for the reasons of climate. This means we can grow grass better in March ,April , November and December than July and august. In fact we are able to grow grass right up to mid-December in most years ,admittedly at a reducing rate. The crop still needs feeding and a shortage of nitrogen will reduce grass growth. We test slurry for nitrogen ,and apply through dribble bar at a rate appropriate to the growth rate. Note :At this time of year we have less rainfall ((November 75.5mm)metoffice.gov.uk1981/2010 Hawarden Airport )than the all Wales average has in any summer month((example May 85.9mm)metoffice.gov.uk1981/2010 all Wales.)

It is important to our business to grow this grass ,so that on turnout in mid-February we have grass to graze.

I am producing evidence from my own farm and the main point I would like to make is that spreading dates are inappropriate to encompass all Wales. They certainly do not take into account my own climate and organic farm management processes. I accept we can all make improvements to our farms in terms of slurry management and I am investing in yard covering presently.