Summary proceedings about the foundation of the feed measure

Complete insight into the substantiation of the feed measure of the Ministry of Agriculture is lacking. That is why the Nitrogen Claim and Agrifacts (STAF) foundations will start summary proceedings if the Ministry of LNV continues to refuse to make this substantiation public.

Both organizations have given LNV until 12.00:XNUMX on Friday to provide the information. But according to the foundations, LNV intends to only make the information available with an appeal to the Public Access Act (WOB). Such a procedure takes months.

Business Type Limits Dependent
According to STAF, the Ministry of Agriculture, Nature and Food Quality wants to set limits as of 1 September for the protein contents in concentrates for cows, differentiated by soil type (sand, clay, peat) and farm intensity (<14.000, 14.000-20.000 and >20.000 kg milk/ha). The Ministry of LNV 'derived' the protein limits for the 9 soil type-intensity combinations itself on the basis of samples of dairy farms in the BIN monitoring network. But the LNV calculations are not always consistent with practical figures, according to STAF. These practical figures are figures from the animal feed world and the Kringloopwijzer that are not public.

Advisory document hardly to be found online
According to STAF, the ministry asked the Experts Committee for the Fertilizers Act (CDM) on 28 April to assess the effectiveness and consequences of the feed measure. On April 11, 2020, 3 days later, the CDM sent an extensive advice to the minister, which, however, was not made available to the House of Representatives. It is online somewhere in a 'cave' on the Wageningen UR website, STAF reports. You can only find it if you know exactly what the document is called.

After studying the advice, STAF concludes that LNV itself has calculated protein limits for concentrates on the basis of dairy farms in the Business Information Network (BIN) of Wageningen Economic Research. The foundation has requested this data in order to check LNV's calculations, but the ministry has not yet provided this information.

Samples too small
Furthermore, it appears from the CDM advice that the sample size for intensive and extensive farms on peat and clay consists of only a few farms. Given the large spread between farms, it seems irresponsible to determine feed limits on the basis of such minute samples, according to STAF. According to the foundation, this is also admitted by the CDM. It is not known how accurate the BIN data are and how large the variation is per soil type and intensity. A number of LNV limits also deviate from the practical figures that STAF had access to. 

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