An urgent appeal to adjust the nitrate directive

Dear Minister Schouten, dear Carola. It has been two years since we our arable farm have received. The drought was the cause. We were pleasantly surprised with the counter-invitation where our daughter Sterre and I were guests during the celebration of Prinsjesdag.

In the conversations we had in 2019, I got to know you as a knowledgeable minister who knows what she is talking about. The draft 7th Nitrates Directive Action Programme, in which the Ministry of LNV proposes a number of measures to achieve the water quality targets in the Nitrates Directive and the Water Framework Directive, therefore come as a big surprise to me. The proposals for sustainable building plans are very far-reaching for the arable sector, but I think you are missing your target. In this letter I would like to take the opportunity to explain this in more detail.

Water quality
The draft 7th Action Program shows that the standards for groundwater quality from the Nitrates Directive in our region (sandy soils) are approximately at the desired level of 50 mg/l. With colleagues on clay and peat soil, this level is easily achieved under normal circumstances. If there are still areas that do not meet the targets, it is better to tackle this area-specifically and crop specifically, rather than making life difficult for the entire sector.

Sustainable building plans: dormant crops
In 2023, it will be mandatory to grow a dormant crop every four years in the construction plan. From 2027, this will even be mandatory every three years. A measure that will apply to the whole of the Netherlands, while, as mentioned above, the water quality targets are being achieved in most of our country.

More grain in the crop plan is at the expense of the cultivation of financially interesting crops such as potatoes and sugar beet. As a result, I have to deal with a drop in income, even though the costs continue to increase. And does the cultivation of grain (as a rest crop) really make a higher contribution to the prevention of nitrate leaching than other crops?

In recent years we sow catch crops after spring barley, more than the legal obligation. We do this because it is good for the soil. We work this green manure in the soil at the end of December, so that it can digest and we can use it for subsequent cultivation. That will soon no longer be possible. Then we get the same as when tearing grassland. This now has to be done in the spring, with the result that the grass does not digest sufficiently and we have to fertilize extra.

Especially in dry summers, which we have more and more often, the grass remains undigested in the ground. Another disadvantage of a plot of greenery through the winter is that the frost cannot do its job. Frost has a positive effect on the soil structure. And potatoes left behind freeze to pieces. This is not the case with a catch crop, which means that problems with potato diseases such as potato slugs can increase. Something very undesirable.

Sustainable building plans: sowing catch crops
As a second measure, it is proposed that from 20123 60% of the acreage on our sandy soils should be sown with a catch crop before 1 October. At the time of writing this letter, all our potatoes have not yet been harvested and we still have to start lifting the sugar beets. This measure is therefore not feasible. I will not accept the proposal to sow the entire construction plan before October 2027 with rest crops from 1.

This proposal is at odds with practice, as I see it more and more often. The starch potato harvest started here on 2 October this year. My first sugar beets are being harvested around November 22. The last beets do not come out of the ground until the second half of December. So these crops are still growing. Due to the imposed date of October 1, I am forced to harvest early. As a result, I miss a few weeks of growth with my starch potatoes and even a few months with my sugar beets. This means an increase in the environmental impact, a much lower yield and a lower quality product (lower sugar and starch content). But also a lower income for me and my family.

In addition, our cooperatives Avebe and Cosun are experiencing a lot more difficulties, because the quality of the crops is much lower, the storability is reduced and processing has to take place in a shorter time. And that while campaigns have become longer and longer from a cost point of view in recent years. All in all, the competitive position of our cooperatives is coming under pressure and this is at the expense of growers' earning capacity.

Sustainable building plans: buffer strips
Finally, buffer strips, or cultivation-free zones, are imposed from 2 meters along waterways to 5 meters along 'ecologically vulnerable waterways and WFD water bodies'. All land that is being taken out of production. Valuable agricultural land that is no longer cultivated and therefore no longer generated any income. And the income position of agriculture is already under pressure.

During Prinsjesdag 2019 I asked you whether it was still fun to be Minister of Agriculture. You asked me in return whether it was still fun to be a farmer. I confirmed that with a resounding 'YES'. We are now two years further. And sometimes I lose heart. I have a great job and I enjoy working on the farm every day. But when I hear how people talk about us as a sector and how easily certain rules, such as the Nitrates Directive, are imposed, I sometimes lose the fun too. The fact that more and more demands are made on agriculture fits in with contemporary times, but then something has to be paid in return.

In an interview in 2019, you complimented our arable farm on how we are working on sustainability. The measures as mentioned above detract from this. I therefore urgently appeal to you and your ministry to adapt the measures to farmers' practice. So that my company is not unnecessarily restricted in doing business and that effective and more area-oriented and crop-specific measures are introduced instead of generic measures.

Yours faithfully,

Jan Reinier de Jong* 

* Jan Reinier de Jong has a sustainable arable farm in Odoorn (Drenthe)

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