Nitrogen & Phosphorus Reporting under the EA’s Environmental Permitting for Intensive Farming

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Harry Edwards (FCG WhiteAvon)

Permitted pig and poultry farming operations in England are now under tighter regulatory expectations regarding nitrogen (N) and phosphorus (P).  These changes arise from updates to the Environmental Permitting Regulations (EPR).  This article explains what the new rules are, what “reporting thresholds” mean in practice, and some issues experienced this year, which resulted in positive change.

What Has Recently Changed / Reporting Requirements

  • From January 2025, all permitted pig and poultry farms were required to retrospectively report for the 2024 calendar year the nitrogen and phosphorus excretion levels from livestock.
  • After the retrospective 2024 data is submitted, annual reporting will be required going forward in line with the current requirements to complete pollution inventories by 28th February annually.
  • The EA has developed a mass-balance calculator tool to aid permit holders to calculate excreted N & P based on data such as: number of animals, diet type, protein and phosphorus levels in diets, feed amounts, and performance figures.

Practical Steps for Permitted Sites bbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbb

To comply fully, intensive farming sites need to do the following:

  1. Gather data
    • Animals: number by type, growth stages etc.
    • Diets: protein and phosphorus content.
    • Feed use, feed source, and any purchased manure or organic material.
  2. Use the EA / AHDB mass balance tool
    • Input your data to calculate N & P excretion from your livestock.
    • Maintain records of how the tool was used, inputs, and outputs.

3. Submit reporting

  • All retrospective reporting should now have been submitted and if it hasn’t the EA will have been in contact to inform of a compliance score which will increase the subsistence charge for the following year.
  • Thereafter, annual reports using the Environment Agency Portal.

Penalties / Enforcement bbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbbb

  • Permit breaches and potential enforcement actions (fines, improvement or prohibition notices) by the EA.
  • The initial action of no submission (likely a Cat 4 breach), and a non-compliant figure (Cat 3 breach).

Issues experienced this year make it essential to begin to record and complete a ‘dry run’ of the mass balance calculations early to see how your farm compares to the reporting threshold.  A number of farms have struggled to meet these thresholds due to varying factors, but a common theme is using biproducts that although economically preferable can have higher than ideal crude protein of Phosphorus level.

What the reporting has highlighted is the varying performance figures and feed conversion ratios even within the same farm between different buildings.  It has led to a number of changes on farms I have been involved with, making practical changes to pig flow, stocking levels and improvements to ventilation which were highlighted when completing what on the face of it seems like just another form.

Should you require any advice or help with complying with your ERP permit or completing any variations or changes, please get in contact with Harry at harryedwards@fcgagric.com or your local FCG Office.

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