What do you want to know?
Here are some common questions we have had about the NAP Stakeholder Task & Finish Group, the process we followed, and some of the technical detail. Ask us a new question through the contact page, and we’ll add it to this list.
About the Stakeholder Group
What were you (the Stakeholder Task and Finish Group) asked to do?
We were asked by DAERA to review the previous consultation, consider the available evidence and develop a practical, evidence-based package of recommendations that could improve water quality while supporting a productive and sustainable agri-food sector. Those recommendations have now been submitted to the Minister and are the subject of a public consultation on the DAERA website.
Were you a decision-making body?
Rather than making decisions, we were the advisory group responsible for developing and refining proposals, then submitting a final report of recommendations to the Minister. The final decisions on policy and legislation remain with the Minister and DAERA. This ensures that proposals are informed by stakeholders but final decisions will be made by the Minister.
Do you own the final proposals?
We ‘own’ the content in the proposals as we were the co-designers and, as such, the proposals reflect input from stakeholders across Farming, Industry and Environmental organisations. However, we do not have formal decision-making authority, and therefore the Minister reviewed and approved the proposals to go forward for consultation, and final policy responsibility remains with DAERA and Ministers.
Did everyone agree with every proposal?
No. Organisations came to the table with different priorities and viewpoints, so there were robust discussions throughout. The aim was never for everyone to get everything they wanted. The achievement was developing a balanced package that participants felt was a credible basis for public consultation.
Did anyone leave the process because they disagreed?
No. While discussions were often challenging, participants remained committed throughout the process. The willingness of organisations with very different perspectives to stay engaged and continue working together is one of the strengths of the process.
What surprised Group members most about the process?
Many participants commented on the constructive nature of the discussions. Although organisations did not always agree, there was mutual respect around the table and a shared recognition that everyone wanted to find practical solutions to improve water quality while supporting Northern Ireland’s agri-food sector. One participant said they felt there had always been shared goals, just – until now – a lack of trust.
How much work was put into the process?
This has been the most detailed and comprehensive review of the NAP since it was introduced in 2007. Around 70 people contributed through our main Stakeholder Group and its supporting science, technical and economic groups. Over a nine-month period, more than 60 meetings took place, supported by extensive scientific and technical evidence, including five scientific papers and 14 technical papers. The proposals are the product of a significant collaborative effort.
Where were the meetings held?
The meetings took place at a range of locations across Northern Ireland to make participation as accessible as possible. More important than the venue was the way the meetings were run: they were independently chaired and provided a respectful environment where farming, food processing and environmental organisations could work together to develop practical, evidence-based recommendations.
How did the feedback you received change the proposals?
It changed it substantially. Key examples include: refinement of the tiered and phased implementation across the proposals (e.g. LESSE rollout); development of the Nutrient Stewardship Programme; inclusion of voluntary and advisory measures; adoption of a targeted, catchment-based approach. These changes reflect direct responses to stakeholder feedback.
Understanding the proposals
Why do you describe these as balanced proposals?
The recommendations have been developed by organisations representing farming, food processing and environmental interests, supported by scientific, technical and economic expertise. No single organisation got everything it wanted. The package reflects months of collaboration, evidence gathering and practical testing to find solutions that improve water quality while supporting sustainable food production.
Why did you take a more tailored approach?
We deliberately avoided a one-size-fits-all approach. One of the strongest messages from the previous consultation was that the same rules shouldn’t apply to every farm regardless of circumstances. That’s why the proposals are more targeted and proportionate. The changes any individual farmer may need to make will depend on their current practices, farm type and level of environmental risk, and many farmers may already be doing much of what’s proposed. For details of how the proposals could affect individual businesses, we’d encourage people to read the consultation documents and supporting guidance.
Should I read the whole package or pick individual proposals?
Our recommendations have been designed to work together as a package. Looking at individual measures in isolation may not provide the full picture. We encourage everyone to read the proposals in full before responding to the consultation so they can understand the overall approach and the evidence behind it.
How were practical farming realities taken into account?
Practicality was a key consideration throughout the process. Recommendations were reviewed not only against scientific evidence, but also for their feasibility, cost and ability to work on farms in practice. The aim has been to develop measures that deliver better environmental outcomes while supporting sustainable productivity.
How will these proposals affect my farm?
There isn’t a single answer because every farm is different. One of the key principles behind these proposals is that they are more targeted and proportionate than a one-size-fits-all approach. Many farmers are already following good nutrient management practices and may find they are already meeting some of the proposed standards. Others may need to make changes over time, depending on their farming system and current practices. Full details are available in the consultation documents.
What kind of changes could I see?
The impact will vary depending on your farm type, size and current practices. In general, the proposals aim to: improve how nutrient applications are planned and used on farms; encourage more efficient use of organic manures and fertiliser; introduce some new requirements over time, particularly for higher-risk or higher-intensity farms; and provide more support through advice, training and (where available) financial schemes. Many farms may already be meeting some of the proposed standards. The intention is to build on existing good practice while giving time and support to adapt where changes are needed. The overall approach is designed to support implementation in practice, not just introduce regulation, recognising the realities facing different types of farms.
What is meant by a targeted approach to water quality?
The targeted approach we have taken focuses actions in high-risk catchments where pollution pressures are greatest, ensuring that measures deliver the maximum environmental benefit.
What support is available now to help prepare for these changes?
The potential support requirements we have anticipated include advisory services, training and potential financial assistance. The aim is to support farmers in adapting to changes while maintaining viable farm businesses. Support currently available includes: DAERA guidance and workbooks; CAFRE advisory services and nutrient tools; Soil Nutrient Health Scheme; catchment-based advisory programmes, including the recently announced Shared Island Lough Neagh water quality programme; and industry and supply chain support. Farmers are encouraged to seek advice early to understand how the proposals may affect them.
Why are both regulatory and voluntary measures used?
We identified that a balanced approach was required. Regulation is used where risks are highest and consistency is essential, while voluntary and advisory measures can be more effective in supporting behavioural change and improving uptake on farms. This balanced approach is intended to support practical delivery and encourage behavioural change, while ensuring regulation is applied where it is most needed.
Will the same rules apply to all farms?
No. The proposals are designed to be: proportionate – reflecting the level of environmental risk; flexible – recognising differences in farm systems, size and location; and targeted – focusing more on higher-risk areas and practices. This approach avoids a “one size fits all” system while still delivering environmental improvements.
How is fairness considered in the design of measures?
The measures we proposed are designed to be proportionate, phased over time and supported through advice and engagement, helping ensure they are achievable while still delivering environmental outcomes. This ensures the approach is targeted, proportionate and deliverable in practice, rather than a one-size-fits-all system.
Nitrogen & phosphorous management
What is the proposal for Phosphorus Balance?
If your farm is operating below 170 kg Nitrogen production per hectare per year, you don’t need to take action regarding the Phosphorus Balance measure. If your farm is operating at or over 170 kg Nitrogen production per hectare per year, you will need to follow the rules that apply to your farm sector. Approximately 2,500 farms or 10% of all farms are in this category and will need to take action on the Phosphorus Balance measure.
You can choose to either: join the Nutrient Stewardship Programme and reduce your phosphorus balance by 10% over a four year period or below 10kg/ha; or reduce nitrogen loading to below 170 kg per hectare and reduce the farm’s phosphorus balance by 15% over a four year period or below 10kg/ha.
Where farms have been unable to make the required reduction in P Balance they may follow the Soil P Protocol. If you use the Soil P Protocol, you must show by the end of the four-year period that weighted average soil phosphorus levels are stable or falling. There are also P Protocols for Pig and Poultry farms to follow to show that phosphorus is being managed efficiently and that risks to water quality have been minimised so far as possible.
Why are you looking at Nitrogen limits if you are worried about Phosphorus?
We opted to use nitrogen loading limits so that the farms potentially posing the greatest risk to water quality can be identified, because they show the farms with the greatest number of animals per unit of area derived from DAERA information. If appropriate mitigation measures are not taken on these farms to reduce the amount of animal manure remaining on farm, there is a real risk to waterways of diffuse pollution from phosphorus if too much of this manure is spread on land over the season.
What can I do if I find my farm exceeds the proposed limits for Nitrogen loading?
We haven’t focused on reducing animal numbers. Instead, for some farmers, the proposals might mean treating livestock slurries with new separation technologies to reduce both Nitrogen and Phosphorus on the farm, with the separated high Phosphorus solids leaving the farm for further processing and recycling. For others it may be simply identifying a neighbouring extensive farm with low stocking density close by and entering into an amicable arrangement to transfer excess nutrients to that farm, also replacing the need for imported fertilisers on the receiving farm in the process. Where farms are close to each other and within a specified distance, the transfer process may be simpler, with fewer requirements than for manure moved over longer distances.
I have a dairy farm and even with slurry processing and transfer to my neighbours I cannot meet the 170 Nitrogen loading value; what can I do?
To enable transition to more sustainable nutrient levels, we proposed developing a novel Nutrient Efficiency Stewardship scheme to replace the existing derogation for dairy farms in NI. Farms currently in derogation already demonstrate that although the farm has a high N loading, this N is utilised in the production of large volumes of high energy grass and poses no additional risk to the environment. This production in turn allows milk production from less imported concentrate feed. All farms choosing to enter the scheme will have the choice of Tier 1 scheme for those able to meet the environmental requirements straight away; or Tier 2 scheme for farms that are keen to reduce impact but need a slightly longer trajectory to meet compliance standards. Tier 2 farms will be required to undertake training and an enhanced inspection package designed to help them meet their environmental targets of the scheme.
Why are there so many production bands for dairy cows and options to calculate my P balance on top of this rather than a single value?
The proposed new system is more complex that the single figure N loading in the old system, which illustrates the tailored approach we have taken. At the heart of the proposal is the aim to be fair to everyone. The new values are calculated from robust science and for many farms that are not at high production levels, the system rightly reflects their reduced risk of overproduction of manure waste and nutrients. Simply put, those farms with the greatest outputs of milk are producing the highest levels of excess nutrients and if they do not have the available land base to take this manure waste, then the Stakeholder Group proposals are that they should address this issue directly themselves. DAERA acknowledges that there are some further improvements in dietary rations fed to high performing herds that can further reduce the Phosphorus levels in animal excreta, and if these technologies are adopted and evidenced, reductions in the standard N banding values for a given annual yield can be achieved. Before implementation of any new proposals, comprehensive training and documentation would be provided by DAERA to ensure all farms understand the principles behind the proposal.
How can I meet the proposed Phosphorus Balance targets proposals?
We recognised that this is challenging and will require everyone within the industry to work together. Based on feedback to the previous consultation, this proposal was revised, with the aim now to reduce the national average phosphorus surplus rather than an individual farm gate phosphorus balance. In order to achieve this reduction, it will require collective action with each farm contributing in different ways. DAERA’s consultation document sets out the ways in which we can achieve this reduction.
Will I still be able to use phosphorus fertiliser on my farm?
Yes, but only where there is a demonstrated crop need. We propose that soil testing and nutrient management plans will be required to demonstrate the need to use phosphorus fertiliser.
Can I use unprotected Granular Urea?
Our proposals permit the use of unprotected granular urea only between 1 February and 31 March, with protected granular urea required for the rest of the growing season. This is to reduce ammonia emissions while still allowing some flexibility for early season applications.
Why do we have to report the movement of nutrients more frequently?
There were concerns raised from analysis of slurry movements records that they might have been created retrospectively, with evidence of very large volumes of slurry moving and long distance movements being increasingly recorded. Therefore, more frequent reporting and verification is proposed to assess compliance with nitrogen limits and to focus inspections where risks are highest. DAERA is planning an App to improve access to the current online system, and there will also be a phone line alternative to the online system and App.
Why do we have to report the movement of nutrients more frequently?
There were concerns raised from analysis of slurry movements records that they might have been created retrospectively, with evidence of very large volumes of slurry moving and long distance movements being increasingly recorded. Therefore, more frequent reporting and verification is proposed to assess compliance with nitrogen limits and to focus inspections where risks are highest. DAERA is planning an App to improve access to the current online system, and there will also be a phone line alternative to the online system and App.
Nutrient Stewardship Programme & Derogation
What is the Nutrient Stewardship Programme?
The Nutrient Stewardship Programme is a revised approach we have developed to replace the current Derogation process under the existing Regulations. It aims to better reflect the higher standards of nutrient management required and the environmental benefits it can deliver. The revised approach aims to identify and remove barriers that discourage farmers from participating in existing derogation provisions, while maintaining environmental protection. The DAERA consultation documents provide more information on how this proposed approach will work.
I have been granted a Derogation – Will I still be able to do this under the revised proposals?
Yes, if you are already operating under the existing derogation and meeting all the requirements you will be eligible to apply to the Nutrient Stewardship Programme. You will fall within the Tier 1 category of the programme, recognising the high levels of nutrient management already implemented on farm. Our proposals include some additional requirements and safeguards under the Nutrient Stewardship Programme – see the DAERA consultation document.
What happens if I don’t apply to the Nutrient Stewardship Programme?
We have agreed that if your farm is operating below 170 kg Nitrogen per hectare per year you are not required to apply to the Nutrient Stewardship Programme. If your farm is operating over 170 kg Nitrogen per hectare per year, you are in breach of the Nutrients Action Programme Regulations. If your farm produces livestock manure at or above 170kg nitrogen per hectare per year, we have proposed that you must follow the rules that apply to your farm sector, and you will need to choose to either join the Nutrient Stewardship Programme; not join the Nutrient Stewardship Programme, but reduce nitrogen loading to below 170 kg per hectare and reduce the farm’s phosphorus balance by 15%; do not join the Nutrient Stewardship Programme, but reduce nitrogen loading to below 170 kg per hectare and follow the Soil P Protocol. If you use the Soil P Protocol, you must show by the end of the four-year period that weighted average soil phosphorus levels are stable or falling. More details are available in DAERA’s consultation document.
Could voluntary measures become mandatory in future?
Voluntary and advisory measures are being introduced where they are considered effective in supporting behavioural change. Their uptake and impact will be monitored, and future decisions will be based on evidence, engagement and outcomes.
Will the same rules apply to all farms?
No. The proposals are designed to be: proportionate – reflecting the level of environmental risk; flexible – recognising differences in farm systems, size and location; and targeted – focusing more on higher-risk areas and practices. This approach avoids a “one size fits all” system while still delivering environmental improvements.
Environmental Protection & Water Quality
Why are you focusing only on the Agricultural Sector?
DAERA recognises that agriculture is one of several contributors to water pollution, and while the NAP focuses on agricultural sources – which was our brief – improving water quality will require action across multiple sectors. This reflects a shared responsibility approach to delivering water quality improvements. However, action from other sectors is outside the scope of this particular plan.
What about pollution from wastewater / NI Water?
Other sources of pollution, such as wastewater and urban drainage, are being addressed through separate programmes and legislation.
How does the NAP address the impact of nutrients on habitats?
Our proposals help to address the impact of excess nutrients on habitats through a combination of proposed targeted measuresandenhanced nutrient management approaches, designed to reduce nutrient losses to the environment. A key element is thefocused (catchment-based) approach, which concentrates additional support and measures in areas where water quality and sensitive habitats are most at risk. This approach does the following: targets high-risk catchments where nutrient pressures are greatest; provides tailored advice and support to farmers in those areas; encourages voluntary actions to reduce nutrient losses; helps deliver the greatest environmental benefit where it is most needed.
In addition, the NAP promotes higher standards of nutrient management on farms, particularly those with more intensive systems. It aims to: improve how nutrient applications are planned, used, and recorded; encourage more efficient use of organic manures and fertilisers; reduce nutrient surpluses that can impact water bodies and habitats; and build on existing good practice while supporting further improvements.
Together, these approaches support atargeted and proportionate response, focusing action where it will have the greatest impact, while helping farms adopt more sustainable nutrient practices over time. While these measures may not provide immediate solutions, they represent a meaningful step forward to lasting improvement. These measures will help establish the groundwork for sustained progress, ensuring positive outcomes over time. This targeted and practical approach is designed to deliver measurable environmental improvements over time, while remaining achievable at farm level.
How do these proposals relate to issues such as Lough Neagh?
Nutrient enrichment has been identified as one of the key contributing factors to water quality issues in Lough Neagh and other water bodies, along with zebra mussels and climate change. The proposed measures we have developed collectively aim to reduce nutrient losses from agriculture and contribute to wider actions being taken across all sectors.
What is meant by a targeted approach to water quality?
The targeted approach we have taken focuses actions in high-risk catchments where pollution pressures are greatest, ensuring that measures deliver the maximum environmental benefit.
Given the proven benefits that buffer zones can have on water quality, why is the use of buffer strips/ zones on farms voluntary rather than mandatory?
For some measures, such as the use of buffer strips, we recognised that an overly prescriptive solution was not the best option. Helping farm businesses recognise identify where risk is highest and select the best solution has the potential to provide a much better outcome.
Given the importance of protecting our most precious and vulnerable areas, why is the focused approach voluntary rather than mandatory?
Other programmes with similar objectives have had good levels of success through a voluntary approach, where community and peer learning have developed to deliver the desired results and more. As with all measures, outcomes will be monitored and reviewed, with the option to strengthen and change measures as needed.
The Office of Environmental Protection’s (OEP’s) review of the 2019 NAP recommended that the NAP set nutrient balance targets. Although there are measures relating to P balance, why is there no discussion in the NAP proposals about setting an N balance target?
Guidance is already provided on optimal use of Nitrogen through the RB209 fertiliser manual, backed by local research by AFBI as well as limits on organic Nitrogen loading set by the NAP regulations. We decided that setting Nitrogen balance targets would provide limited additional benefit.
Farm management & compliance
I have a small farm and I will not be able to use low emission slurry spreading equipment (LESSE). How will I meet the regulations?
We recognised the challenges for small and medium sized farms, and took on board the feedback from the consultation in 2025 with a revision to this proposal – which is that the tiered implementation will apply to farm businesses over 50 livestock units. These are proposals and DAERA is keen to hear your feedback and understand alternative ways of managing slurry spreading for these farms.
What are the proposed changes for pre-notification of slurry and or silage stores?
We propose that any new, substantially enlarged or reconstructed stores must be notified to the Department prior to construction starting, rather than prior to use. Where such a system must comply with British Standard 5502, this must be signed off by a Chartered Structural or Civil Engineer.
The new reporting and verification system for slurry movements is a good idea, but why does this rule only apply to some and not all slurry movements?
It was recognised by the stakeholder group that where slurry movements have been reported over long distances, this increased the risk of transfers or volumes transferred may be inaccurate. For this reason, a distance of 15 miles was chosen as a reasonable distance, beyond which a shorter notification period would apply to allow for follow up inspections based on risk.
Is the Nutrient Stewardship Programme just allowing more farms to operate at higher nutrient loading – ie, it’s just derogation by another name?
The Nutrient Stewardship Programme has been developed to help more farm businesses develop their nutrient management planning and is structured to recognise and encourage higher standards of management of both nutrients and the environment.
The OEP have also highlighted the need to address nutrient inputs from animal feeds – was this considered as part of the development of the proposals?
The main imports of Phosphorous onto farms is through Feed and Fertiliser. Both of these have been addressed in our NAP proposals, through use of P balance within the Nutrient Stewardship Programme and through changes in the rules relating to chemical fertilisers containing Phosphorous. It was also recognised that the Pig and Poultry sectors have significantly reduced the amount of phosphorous in feed in recent years.
What if my farm already follows good nutrient management practices?
Many farmers are already taking positive steps to manage nutrients efficiently. Our proposals are designed to build on this progress. Farms already meeting high standards are likely to: experience fewer changes; be better placed to meet new requirements; potentially benefit from schemes such as the Nutrient Stewardship Programme.
The consultation
Why is there both a DAERA website and a stakeholder website?
The two websites have different purposes. DAERA’s consultation pages contain the formal consultation documents and explain how to respond. This website explains how the stakeholder recommendations were developed, why organisations chose to work together, and provides additional background on the collaborative process behind the proposals. Please click here to access the consultation.
Can these proposals change following consultation?
The consultation process is ‘owned’ by DAERA and the Minister, and is an important part of the policy-making process as the feed back can result in changes. For example, the response to the consultation on the NAP proposals last year led to the formation of the stakeholder group. Everyone is encouraged to read the proposals and submit their views, and the Minister will consider all consultation responses before making decisions on the final NAP. Please click here to access the consultation.
Why should I take part in the consultation?
The consultation is an opportunity for anyone with an interest in Northern Ireland’s water quality, farming and food production to help shape the final programme. We encourage people to consider the proposals carefully and provide constructive feedback. Please click here to access the consultation.
Are meetings being held to provide more information?
Yes – all stakeholders involved are holding meetings and information events during the consultation period. DAERA will also be setting up events with the stakeholders involved in this plan to answer questions in more details. Contact your membership body for more information or watch out for meeting dates on this site.
Looking ahead
Will the Stakeholder Group continue after the consultation?
The Stakeholder Task and Finish Group has completed the work it was established to do. However, ongoing stakeholder engagement is proposed through new governance arrangements that will monitor implementation, review emerging evidence and identify practical issues as measures are introduced. It is likely that this new governance group will be formed with some of the members of the original Stakeholder Group.
How will you know whether the programme is working?
The proposals include arrangements for monitoring progress, reviewing evidence and assessing the effectiveness of selected measures over time. This reflects a commitment to continuous improvement and ensuring that the programme delivers better environmental outcomes while supporting sustainable agri-food production.
What does success look like?
Success means making measurable progress towards better water quality through practical, evidence-based farming practices, while maintaining a productive and sustainable agri-food sector. It also means continuing to work collaboratively, reviewing progress and adapting where evidence shows improvements can be made.
What message would you like people to take away from this process?
This process showed that organisations with very different perspectives can work together to tackle complex challenges, and the Stakeholder Group welcomed the opportunity the Minister and DAERA gave it to do this. The result is a practical, evidence-based set of recommendations that aims to improve water quality while sustaining Northern Ireland’s agri-food sector. We encourage everyone to read the proposals and take part in the consultation.