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) APR23
Ymateb gan: Ymateb unigol	Evidence from: Individual response

I appreciate the opportunity to contribute to the review of the Water Quality Regulations.

As a lifetime farmer I wish to present to yourselves my own journey through farming and why the farming system I presently have has been developed. I will endeavour likewise to view what the future holds in respect to the proposed regulations and their impacts to the business.

We have been farming at our present farm since 1963, milking 12 cows, fattening male cattle from the herd and a flock of 120 sheep. I am the ninth generation of our family to be farming. Today there are 500 Pedigree Holstein Cows, all female replacement heifers reared away on contract, all beef cross calves sold to other farmers. There is also a flock of pedigree Texel’s.

Margins in dairying have been challenging for the last four decades since the imposition of milk quotas in 1984. Dairy farmer numbers have fallen from 6400 to the present 1674. Those remaining have strived to stay i business by continually challenging the cost of production and capturing al marginal litres.  Our business has been no different and has had to grow or exit. Every time we have invested in productivity and infrastructure it has entailed milking more cows. Our last investment was in a milking parlour,  the old parlour was struggling to cope but more than that, it was taking its toll on ourselves and farm staff as each milking took four hours. Staff retention was becoming more and more of a problem.

Today, four years after the parlour was installed,  milking takes 2.5 hours, we have people wanting to come and work here as milking is far more pleasurable. Having made the considerable investment,  working with our consultant to safeguard we are keeping to budgets to repay loans, we are working on a further 20 years to repay the investment.

We have worked with our consultant to see what effects the regulations will have on the business.  Slurry storage capacity is presently four months. A new lagoon was constructed in 2013 to fulfil safo requirements.  I personally believe that having adequate storage capacity is essential, but how much is essential is different for each farm depending on rainfall, soil conditions, aspect and climatic favourability.  Being very close to the sea, grass growth continues into mid-December and starts again mid to late January.  The investment made in our lagoon has more than repaid for itself in reduced artificial fertiliser usage. Slurry application is targeted to coincide with grass requirements.  Soil water and temperature sensors linked to the internet have been extremely valuable. In January 2018, temperatures were extremely mild, a light application of slurry was made on the 8th January,  the lagoon was only 60% full. Grass grew very well from mid to late Jan and as the mild conditions persisted through into February,  the contractor was contacted to apply a further dressing. I was told by the contractor I was 12th on his list of farms wishing to apply slurry,  a fact which should be taken into account within the review as there is simply not the capacity amongst Agriculture contractors to cope if many farms wish to apply slurry at the same time.  When eventually the contractor arrived, another 3000 gallons/ acre was applied. When that grass was harvested in early May, only 40 kg artificial N had been applied.

No season is the same as the last which every farmer has to cope with. Farmers have always farmed according to the season and not to a calendar. True enough January 2019 was totally different  but became cold and dry later on. As it turned out, March 2018 was particularly wet and we comforted ourselves for having taken the opportunity in early Jan and Feb, no slurry could be spread in March but just as well the lagoon was not under pressure.

Throughout the grass growing season, an application of slurry is made using a trailing shoe applicator. In total, 265 Kg organic N/ ha is applied through the season, there has been a 40% reduction in artificial N use in the last 10 years, no phosphate or potassium is purchased.

Some slurry and fym is offered to neighbouring farms

The total organic N loading for our farm is 332kg/ha , as I said previously,  some of that N is exported. Under the present regulations, the imposition of a 170Kg/ha organic N limit would entail one of two things, a reduction of 300 cows or the need for an additional 450 acres of land. Granted, some of that land could be accounted for by the local farms taking slurry, but they would be constrained by their own N limit.

The sum of all this means that we would not be able to survive economically,  four full time employees and 12-part timers would lose work as well as other service providers to the farm. I honestly believe there is a better way to deal with Ag pollution incidences than to penalise the whole industry. I trust that you as members of this committee will have the wisdom to recommend a better way, a more targeted approach that does not shackle thousands of farm businesses because of the misdemeanours of a few.

Yours sincerely,
Osian Rhys.