The chance that in 2018 additional creaming off the distributed phosphate rights on top of the generic discount of 8,3 percent is certainly not inconceivable. The agricultural organizations ignored the advice of State Secretary Martijn van Dam to do so right now.
This week the Secretary of State made in a letter to the House of Representatives known that there 8,3 percent is skimmed off on the phosphate rights allocated to the approximately 10.500 non-land-based dairy farmers in 2018. The phosphate production of the Dutch dairy farming sector was 2 million kilos of phosphate on 2015 July 89,4 - the reference date for allocating phosphate rights. That is 4,5 million kilograms above the sector ceiling for dairy cattle of 84,9 million kilograms.
Extraordinary situations
Because land-bound companies are completely and partially spared companies with a small phosphate surplus when imposing the generic discount, Van Dam wanted to cut 7,3 percent. But because he will now also spare companies and companies in extraordinary situations started from 1 January 2014, an extra discount of 1 percent will be added. This brings the total discount to 8,3 percent.
Van Dam wanted a 9,8 percent discount
Van Dam actually wanted to go one step further and build in an extra safety margin of 1,5 percent. Phosphate rights are based on fixed production, which means that the actual phosphate production can deviate from the theoretical annually. He therefore proposed to set the total generic discount at 9,8 percent. That margin can come in handy, he says. For example, to compensate for a year with higher phosphorus levels in the roughage. For example, a higher phosphorus content in both silage and fresh grass resulted in 2014 million kilos more phosphate production in 4. But also to absorb setbacks that may arise due to the granting of extra phosphate rights as a result of ongoing objection and appeal procedures.
Industry advice
LTO, NMV and the NAJK advised Van Dam kindly but urgently not to apply the extra discount. They put forward several reasons for this. Dairy farming foreman Kees Romijn of LTO: “The level of phosphate production in dairy farming in itself is not leading for Brussels. The European Commission only looks at the total national phosphate production of 172,9 million kilos, and there is still extra room there. That extra safety margin is actually already there.” But what if all other livestock sectors, where the annual phosphate production also fluctuates, think the same? What then?
No cross to judges
In addition, according to Romijn, Brussels individual outliers in phosphate production due to natural circumstances do not weigh heavily in the final assessment of whether or not to grant a derogation. Romijn provides an additional reason for not applying an extra safety margin in the generic discount. “It is as if we are already taking into account that the judges will agree with the litigant dairy farmers. We are not going to give that pass.”
Extra margin of safety
Also daily driver Bart de Hoog of the NAJK does not want to know anything about an extra safety margin. He states that the combination of phosphate rights, feed track and Kringloopwijzer offers sufficient safeguards: “How the actual dairy cattle phosphate production will develop next year in relation to the phosphate ceiling depends on a number of practical factors. An important factor is the feed track. This had a major impact in 2017. When dairy farmers are allowed to work with the KringloopWijzer next year, a large group of dairy farmers will continue to have the incentive to pay attention to their phosphate efficiency. In my experience, phosphate production will always be lower than the dairy cattle phosphate ceiling of 84,9 million kilos.”
Doubts about Recycling Guide
That is precisely the crux of the matter: It is by no means certain that dairy farmers will be able to use the efficiency benefits from the Kringloopwijzer in 2018. Brussels will have to accept the Kringloopwijzer as a measuring method. The ministry has serious doubts about whether this will work. Kees Romijn, however, is confident that it will all work out. "Because all the necessary information from farmers is now entered automatically, the guarantee has become almost watertight. I am therefore confident that they will accept this."
Risks
For example, despite the arrival of phosphate rights, there are still the necessary risks of exceeding the phosphate ceiling and thus the goodwill for the derogation of Brussels. The question therefore arises as to whether agricultural organizations should not take the pain of an extra margin of safety right away. If dairy farmers are again confronted with extra discounts on phosphate rights in 2018, you will have the dolls dancing again.
Warned
The agricultural organizations can then not come up with the argument that there was no warning. In his letter to the House of Representatives, Van Dam writes: "I pointed out to them that if the total phosphate production still appears to be higher than the sector ceiling, an additional generic discount is necessary next year. The sector organizations understand the consequence of not doing so. -use a margin of safety."