Major changes in legislation and regulations are imminent for the Dutch arable farmer. The new CAP is being rolled out and the 7th Program of Action (7th AP) is taking shape. Much still needs to be worked out in more detail - much too late since most arable farmers have already largely completed the cropping plan for the coming season and the first crops are already in the ground - but a few measures are already causing a lot of controversy.
The fact that the government wants to encourage farmers to produce responsibly is a positive starting point. Yet the plans presented in recent weeks by the Ministry of Agriculture, Nature and Food Quality have caused a lot of unrest. This is partly due to the run-up to the new CAP and the 7th AP. A long cabinet formation with an outgoing Minister of Agriculture who did not want to get in the way of the successor and then a minister in the new cabinet who did not act decisively, did not do any good to the sector's confidence in the government. The slow decision-making process in Brussels has also not helped farmers to win over the policy reforms.
Heard it, but didn't do much with it
There is also a lot of criticism from the sector that the ministry has done little to address the objections expressed by sounding board groups, consultation tables and lobbyists in the run-up to the new legislation. Farmers are also aware that production must be carried out in a responsible manner. There is quite a difference between the ministry and the farmer between what is responsible and how you put it into practice. What is particularly striking is that many proposals have been made from the sector, but almost all of them have been discarded. There are reports from the sector that the package for both the CAP and the 7th AP that is now on the table lacks support and is based on a paper reality that is not in line with current agricultural practice.
Although the plans had been in the air for some time, the mood among farmers for a long time was 'we'll see, if it is unworkable we will no longer participate in the CAP and the soup will not be eaten as hot as it is'. is served'. Now that the introduction is getting very close, fear is spreading.
It would take us too far to review all the measures and much still needs to be worked out in more detail, but we can highlight a few.
Mandatory early harvesting
One of the most drastic measures is the mandatory sowing of a catch crop no later than October 1 on sandy and loess soils after non-winter cultivation. The mandatory harvest before October 1 is stimulated by a discount on the nitrogen space for the next crop if the catch crop is sown later. This measure results from the 7th AP and the Minister of Agriculture bases it on the advice of the Fertilizer Act Experts Committee (CDM).
According to the definition of the Ministry of Agriculture, Nature and Food Quality, a crop falls under winter cultivation if the harvest only takes place after November 1. The list of winter crops has been determined by the CDM. For example, beets in the late harvest and starch potatoes of earliness class 6,5 have been given an exception and fall under winter crops. No exception has been made for ware potatoes and corn, for example. This means that those crops must be harvested before October 1, or there will be a reduction in the nitrogen user standard for the next crop. The ministry easily ignores the practical implementation. From an agricultural point of view, it is no problem to grow early potatoes on sandy soil. That's happening now too. From a practical point of view, it is unrealistic to expect that only early potatoes will be grown. The farmer cannot harvest everything at once and the industry cannot process all the potatoes at the same time. Early harvested potatoes are generally less suitable for storage. Another problem is: how does the nitrogen discount work out for arable farmers who rent or exchange a lot of land for one growing season? Will the grower who uses the land again the following year receive the discount or will the nitrogen space of the grower who harvested too late be cut?
Effect questionable
Apart from the practical problems, support could still be created for the proposal of the early harvest of non-winter crops if it would actually contribute to the reduction of nitrogen leaching. However, there is little evidence to support the effect of timely sowing of catch crops. The calculations are based on publications from 1996 on the effect of green manures after silage maize and from 1997 on green manures as a source of nitrogen. The research underlying the publications was conducted in the period 1988 to 1993. Wageningen University & Research (WUR) is conducting further research into nitrogen uptake and nitrate leaching in the cultivation of catch crops after ware potatoes (three years of research with one trial each year ) and with catch crops after maize (four years of research with one trial each year). The results of this study have yet to be published. That will happen later this year. The CDM itself also admits that the substantiation of the standard that a catch crop sown on October 1 takes up 40 kilos of nitrogen is poor: "It should be noted that the test was only carried out at one location (this also applies to the research by Schröder et al. al., 1996; 1997) and that no possible corrections for variations in weather conditions (e.g. average temperature) have been made."
Buffer lanes only announced in October
Good agricultural and environmental conditions (GMLCs) are central to the new CAP. Ten GMLCs have been formulated that every agricultural company must comply with in order to be entitled to land-related funds from Brussels. Perhaps the most striking thing for arable farming in the coming season are the buffer strips (crop rotation does not yet apply in 2023). From 2023, a buffer strip of at least 3 meters must in principle be used along all waters. An exception is if the buffer strip covers more than 4% of the area of the plot. Then the buffer strip may be narrowed to 1 meter. The other exception is the ecologically sensitive waterways. There must always be a buffer strip of 5 meters.
This measure was only announced in a letter to Parliament on October 3, when rapeseed, part of the winter wheat and tulips, for example, were already in the ground. The RVO's existing ICT still needs to be adapted to the new situation of the buffer strips and that takes a lot of time, according to the minister. It will probably take until February before the necessary adjustments are implemented.
Simulation tool GLB not ready yet
The simulation tool for practicing with the new CAP is also not ready yet. Depending on the measures they take, companies can achieve bronze, silver or gold status. This valuation determines the amount of the hectare premium that a farmer can claim. According to various sources, it is difficult for arable farming to achieve gold status. An additional hurdle this season is that the simulation tool will not be ready until February. Arable farmers already have to make choices for the coming season and the first crops are already in the ground. February may prove too late for many companies to make the necessary adjustments. And if the costs of meeting the conditions are higher than the subsidy, a large group of companies may drop out.