ANNEX B: EVIDENCE ON THE EFFECTIVENESS OF DIFFERENT MEASURES IN CONTROLLING NITRATE LOSSES

1. The loss of nitrogen from land to water is a complex process controlled by natural and man-made factors. In terms of natural processes,
the effects of climate (particularly temperature and rainfall) and soil type are critical to the rate and nature of losses. In addition to crop
type, amount and timing of fertiliser application will influence the amount of N potentially available for leaching as nitrate from the soil. This
Annex considers these issues in the context of the Nitrate Vulnerable Zones in Scotland, and makes use of information extracted from
scientific evidence provided by DEFRA. The Defra 2006 research, referenced to in this Annex and in paragraph 6 of the summary
consultation document, is not yet published. Information is also taken from the SAC Report entitled 'The Assessment of Benefits and Costs
of Changes to the Nitrate Vulnerable Zones Action Programme in Scotland' (2006), and SAC's ' Proposed Organic Manure and Nitrogen
Chemical Fertilisers Closed Periods For The Proposed Surface Water And Groundwater Nitrate Vulnerable Zones' (2001).
Background
The Nitrogen Cycle - Nitrate Generation
2. Nitrogen (N) is naturally present in the environment in many forms. The N cycle is a complex ongoing process, which includes transfers
of N from land to water and air (Fig. 1).
Figure 1 The N cycle (source: DEFRA, 2006)

3. Most N (78% of the atmosphere) is present as gaseous N2. Most organisms cannot break the powerful triple bond of the N2 molecule's
atoms. For plants to grow and animals to thrive, they need the element in a reactive, fixed form that is bonded to carbon, hydrogen, or
oxygen, most often as organic nitrogen compounds (such as amino acids), ammonium (NH4 +), or nitrate (NO3 -). Animals obtain their
reactive N from eating plants and other animals in the food chain, plants obtain their reactive N from the soil or water.
4. On a global scale, N is conserved. However, the agricultural N cycle disturbs this balanced state through added inputs of reactive mineral
N (Nmin3 ), to produce food.. Since the start of the 20th Century, mankind has produced increasingly more reactive N, intentionally as
fertiliser (and unintentionally as a by-product of combusting fossil fuels).
N Mineralisation
5. Breakdown of organic N (from manure, soil organic matter, plant residues) by the soil microflora ('mineralisation') releases ammonium
ions (NH4 +) that can then be nitrified to nitrate via nitrite (NO2 -) (Fig. 2). The nitrate and ammonium ions make up the pool of N that is
immediately available for plant uptake.

Figure 2. The N mineralisation/immobilisation process (source: DEFRA, 2006)

6. The amount of mineral N released for crop uptake (or leaching) depends upon the balance between the release of these N forms by the
soil microflora and their re-use by other microflora (Fig. 1). Under conditions where re-use is greater than release, N immobilisation can
occur ( e.g. when straw - as a carbon source - is incorporated into the soil).
7. Release of mineral N can most simply be considered as a slow, background release from the stable organic matter, plus quicker 'pulses'
when fresh residues are added. Factors that influence mineral N release include:-

Amount of organic N returned to the soil,

Its 'quality' or degradability, crudely related to its C:N ratio 6,
Environmental conditions - moisture, aeration and temperature,
Access by the soil microflora to the organic material ( e.g. affected by soil texture).
Mineral N Forms and Susceptibility to Leaching
8. As described above, forms of soluble N in the soil include nitrate, ammonium and nitrite, but also small organic molecules. The main loss
of N in drainage is by leaching 7 of nitrate. This is because most soluble N exists as nitrate, it is completely soluble in water and it is not
held in the bulk of the soil (soil matrix). Measurements of soil mineral N in the autumn are a good indication of nitrate leaching risk. Over
90% of Nmin exists in soils as nitrate.
9. In the soluble phase, ammonium will move down through the soil profile but, because of its positive charge, it is attracted and adsorbed
to soil particles and, hence, will be retained within the soil. This provides an opportunity for it to be nitrified (Fig. 2) and, therefore, the slow
through-flow 'leaching' losses and drain flow losses of ammonium tend to be small (Watson et al., 2000 8; Hatch et al., 2004 9). Other
'incidental' losses (see paragraph 16 below for definition) of ammonium can occur when heavy rainfall occurs soon after the application of
NH4 + in fertiliser or manure, leading to their 'washing' from the surface of the soil and through drains into nearby water courses (Hatch et
al., 2004). Other forms of incidental transfer of ammonium to surface waters can occur through the direct urination of livestock into
streams and rivers which are being used for their watering or through the misapplication of managed manure and dirty water to land
(Hatch et al., 2004).
10. Nitrite is not applied to soils, but is generated during nitrification (Fig. 2). A large amount of NO2 - is actually produced, although it has
a very limited life span. Because of this, although nitrite is as mobile as nitrate, losses to water are small.
The Factors that Influence Nitrate Leaching
The process

11. Nitrate leaching occurs when drainage water moves through the soil and takes with it nitrate. Drainage most commonly occurs when
water use by the crop is small and evapotranspiration 10 is exceeded by rainfall. Fig 3 shows a representation of the interaction between
crop N uptake and soil mineral N level for winter wheat. The general picture holds for all arable crops and grass, with a rapid uptake of N in
spring/summer and a corresponding decline in soil nitrate, followed by an increase in soil nitrate towards autumn as crop N uptake slows
(grass) or stops (harvest of annual crops).

Figure 3. Leaching risk - synchronicity between N supply and crop uptake (source DEFRA, 2006)
12. Leaching risk can therefore be characterised in terms of the likelihood of drainage occurring and the size of the soil nitrate pool at that
time (Table 1):
Table 1. Risks of losses of NO3 through leaching (source: DEFRA, 2006)

Period

Risk of water flow

Size of soil nitrate pool

AutumnWinter

PROBABLE Soil often bare and crop water use is small.

Leached NO3 most likely to be removed from the crop's
final rooting zone and lost to the wider environment.

MEDIUM Ranges from low to high depending

on soil and crop management

Spring

POSSIBLE

HIGH

If fertiliser (or manure) has been

applied.

LOW

Actively growing crops using the

soil NO3pool.

In wet springs.
Spring sown crops at greatest risk.
Leached NO3 may be moved down the soil profile but
some may be recovered as deep roots develop.

Summer

UNLIKELY Well developed crops will have developed a large soil

moisture deficit, acting as a buffer to subsequent rain.
Likelihood increases if the crop has recently been
irrigated.

13. To understand loss processes and to make it easier to identify measures to decrease nitrate loss, nitrate leaching can be considered as
either a 'loss of soil nitrate' or an 'incidental loss', depending on how and when nitrate is leached.
14. By loss of soil nitrate, we mean the soil nitrate pool that is sitting within the soil matrix and is leached out when drainage occurs in
autumn/winter. Therefore, it is the autumn soil nitrate pool that is most susceptible. Many factors influence the size of the autumn nitrate
pool, mainly relating to:-

how the previous crop was managed ( e.g. N fertiliser rate versus N uptake, irrigation on drought prone soils);
N mineralised from crop residue: (depends on nature of residue especially N content, C:N ratio and rate of decomposition;
whether incorporated or removed from the field);

N mineralised from soil after harvest (depends on previous history; and type and timing of cultivation); and

N uptake during autumn: presence of well-developed crop ( e.g. grass, cover crop; oil seed rape but not in general winter
cereals).
15. The aim for minimising nitrate leaching, therefore, should be to minimise the size of this autumn nitrate pool.
16. By incidental loss, we mean the leaching of nitrate derived from recently applied N sources before it can be taken up by a crop. These
losses can be minimised by minimising the quantity of N that is applied to soils at inappropriate times. For example, autumn applied slurry
or N fertiliser is at risk of incidental loss during the autumn/winter. Heavy rainfall in spring will also put some manure and fertiliser
applications at risk. Simple steps can be taken to minimise this risk.
Effect of soil type
17. The quantity of N leached will be determined by rainfall and by the soil texture. In Scotland, because of the soil composition, wetter
areas will tend to lose more nitrate - but the concentrations are lower.
18. For a given agricultural system, losses from sandy soils will generally be more rapid ( i.e. less water is required for the nitrate to leach
from the soil profile) and hence at a greater concentration. However, the role of the soil's hydrology needs also to be considered. Whereas
sandy soils and shallow soils overlying rock are considered to be at greatest risk of nitrate loss, drained clay soils may also present
considerable risk, especially for loss of surface applied N. Much depends on whether the nitrate is held in the soil matrix and therefore

protected to some extent from leaching, or whether the nitrate is able to move quickly down cracks, fissures or macropores within the soil
or to drains. Thus, the connectivity between soil surface and the drains will be an important factor.
19. The mechanism for drainage through permeable soils such as sandy and loamy soils is relatively straightforward: incoming water
displaces soil water downwards, carrying nitrate in the soil profile downwards and towards the groundwater. This process can be described
as 'piston flow' - combined with dispersion as nitrate moves downwards, it results in generally smooth nitrate leaching curves (Fig. 4(a)).
Concentration of nitrate in leachate reflects the concentration in the soil water.
20. However, the mechanism for nitrate movement to surface waters is more complex and variable (Armstrong et al., 1999 11). In heavier
textured, structured soils (clays and clay loams), the bulk of the soil cannot transmit water fast, and water cannot percolate to depth. After
a rainfall event, surplus water is transmitted either downwards via cracks in the soil or over the surface ('surface run-off'). There is a
limited capacity for infiltration, unless lateral movement can occur in the soil. For this reason these soils often have drains installed,
especially under arable cropping, to carry surplus water away laterally to ditches - 'soil water drainage'. This rapid water flow does not
equilibrate fully with the soil profile - in winter, storm events are characterised by reduced nitrate concentrations. However it can carry
nitrate and other pollutants from the surface, and therefore act as a vector for losses from freshly applied manures which would in more
permeable soils be delayed by movement through the soil matrix. Most of this rapid water flow occurs when the soil is fully wetted up, but
some may also occur, in heavy storms, when there is a soil moisture deficit.
21. Water (and nitrate) movement through clay soils can therefore occur as:-

Rapid movement through cracks, macropores (bypass flow) etc;

Slow movement through the bulk of the soil.
The concentration of nitrate in the drainage water (and therefore how much N is leached) will depend on how much contact the water has
with sources of nitrate. This results in more complex nitrate leaching profiles from drained soils (Fig. 4 (b)), compared with the nitrate
leaching curve from permeable soils, described in paragraph 20 (Fig. 4(a)). For example, if most of the soil nitrate is held within the bulk of
the soil, water moving rapidly through cracks, so not mixing with the soil, will be low in N. However if, for example, heavy rain falls after a
recent fertiliser or manure application, water can pick up N before transferring to cracks.
22. Structured soils can be considered retentive of N when the nitrate is protected in the bulk of the soil and only moves downwards with
slowly mobile water. However, if rapidly moving water (bypass flow) has access to substantial N ( e.g. N at the soil surface), then losses
will increase.
23. The contribution of surface run-off to N losses varies depending on the susceptibility of that soil to water loss across the surface, but is
generally less compared with drainage losses. For example, at Brimstone, N loss through the drains on ploughed land averaged 32
kg/ha/year over 7 years: average N loss via surface runoff and plough layer flow was 3 kg/ha for the same period (Harris & Catt, 1999) 12.
On undrained, ploughed land, surface runoff increased to 4 kg/ha (8 kg/ha on direct drilled land). This is due to the fact that nitrate
concentrations in surface runoff and drainage are not very different, but the bulk of the water passes through the drains.
4(a) sandy soil

4(b) drained clay soil

Figure 4 Examples of the different nitrate concentration profiles for water draining downwards-(a) a smooth curve in a sandy soil and (b)
the more complex profile of water moving through the drains of a clay soil. (source: DEFRA, 2006)
Proposed Measures for Reducing Losses of Nitrate
24. In deriving the proposed closed periods for organic manure with high available N we have taken account of both leaching risks and the
potential risk of surface run-off. Timing of application, soil type and type of crop all affect the losses of N that can be expected. Losses
occur either directly, if slurries are applied in the autumn at the end of the growing season, or indirectly, if insufficient account is taken of
their N supply when calculating a fertiliser recommendation. Although effective manure management can minimise nitrate loss from the
field, fields receiving regular applications of manure will inevitably leach more nitrate, simply because of the amount of N in the soil-crop
system.
Impact of timing of manure applications on nitrate leaching
25. SAC/ ADAS investigated the effect of the date of manure application on the proportion of the applied N which is leached using
the MANNERprogram (Chambers et al., 1999 13), as recently modified to take account of recent research findings under the DEFRA project
KT0106. The model estimates:

ammonia volatilisation, modified according to the delay before incorporation;

effect of incorporation on the location of manure N;

delay before the manure ammonium or uric acid N is nitrified and therefore at risk of leaching; and

leaching as a function of soil properties and excess rainfall between application date and end of drainage.
Table 2 Manure N composition data (source: SAC 2006)

Type Total N % of N which is Ammonium plus Uric acid N

Dairy slurry 6% DM 3 kg/m 3

50

Pig slurry 4% DM 4 kg/m 3

60

Broiler litter

30 kg/t

40

Table 3 Calculated quantity of N at risk of leaching (kg/ha ) after allowance for ammonia volatilisation, assuming total N applied as manure
was 170 kg/ha N. (source: SAC 2006)

Type Incorporated 4h Incorporated 14 days Not incorporated

Dairy slurry 6% DM

74

54

54

Pig slurry 4% DM

93

76

76

Broiler litter

67

49

41

26. An annual quantity of Hydrologically Effective Rainfall 14 ( HER) of 450 mm was deemed to be typical of the NVZs in Scotland. This value
is consistent with that used in Oglethorpe et al., 2002 15. Rainfall data from the UKCIPS database for the Borders NVZ area was used, and
modified marginally to give exactly 450 mm of HER. The monthly distribution of rainfall and HER which was used is shown below (Table 4).
Table 4 Water balance data assumed in the study (source: SAC 2006)

Month Rainfall Evapotranspiration HER

(mm)
(mm) (mm)
January

83.1

10.7

72.2

February

59.8

12.7

49.5

March

67.7

22.5

54.3

April

49.8

44.1

24.0

May

65.3

65.6

16.3

June

58.9

74.7

0.0

July

64.7

51.2

0.0

August

78.6

35.0

12.5

September

77.9

21.2

51.6

October

77.1

19.7

54.5

November

72.1

11.8

52.2

December

75.3

10.8

62.6

Total

830.3

380.0 449.7

27. The soil types used in the simulations were sandy (sandy loam over loamy sand) and a medium loamy soil. These soil types were
chosen as typical respectively of the 'sandy and shallow' class of soils within the Action Programme, and the remainder of Scottish
agricultural soils. Estimates were made for soil of 100 cm depth; and for shallower soils (60 cm). The values of total volumetric water
content at field capacity to 100 cm (60 cm) were 224 (136) and 338 (205) mm respectively.
28. Model runs were carried out for dairy slurry, pig slurry and broiler litter. The differences in quantity of N leached at a given date of
application are due to differences in the proportion of N in these manures which is present as ammonium or uric acid N, and therefore
rapidly converted to nitrate; and also due to differences in the volatilisation losses. The pattern of leaching of the residual nitrate is similar
for all the manure types.
29. The data are for nitrate leaching to below 100 cm at the end of the winter leaching period. It is assumed that in most soils, nitrate
which is within 1m will be recovered by the crop during the growing season. Under average rainfall conditions, very little manurederived nitrate will leach below 1m from applications made after the end of December and especially after mid January, even
on sandy soils. (Table 5). These conclusions are supported by extensive experimental data.
Table 5 Percentage of total N applied as manure , which is leached before the next growing season, for different application timings,
incorporation delays, and soils. Total winter drainage ( HER) 450 mm. Leaching below 100 cm. (source: SAC, 2006)

Date applied

Delay before incorporation

4h

14 days Grass, not incorporated

Soil type medium sandy medium sandy

medium

sandy

A. Dairy slurry
15-Sep

35

43

26

32

19

15-Oct

26

41

19

30

15

15-Nov

13

32

24

15-Dec

12

15-Jan

15-Feb

B. Pig slurry
15-Sep

44

55

36

45

17

31

15-Oct

32

52

26

42

26

15-Nov

16

41

13

33

13

15-Dec

15

12

15-Jan

15-Feb

C. Broiler Litter
15-Sep

32

39

23

29

11

15-Oct

23

37

17

27

15-Nov

12

29

21

15-Dec

11

15-Jan

15-Feb

30. The model runs were repeated for shallow soils, where roots may make poor recovery of N below about 60 cm. The majority of these
soils are of medium texture - sandy soils tend to be deeper. The runs were carried out for both medium and sandy textures for
completeness. It will be seen that the results for medium shallow soils are broadly similar to those for sandy soils of normal depth. (Table
6)
Table 6. Percentage of total N applied as manure, which is leached before the next growing season, for different application timings,
incorporation delays, on shallow soils. Total winter drainage ( HER) 450 mm. Leaching below 60 cm. (source: SAC, 2006)

Date applied

Delay before incorporation

4h

14 days Grass, not incorporated

Soil type medium sandy medium sandy

medium

sandy

A. Dairy slurry
15-Sep

44

44

32

32

20

20

15-Oct

43

44

32

32

17

20

15-Nov

40

44

29

32

19

15-Dec

22

39

16

29

15-Jan

15-Feb

B. Pig slurry
15-Sep

55

55

45

45

32

33

15-Oct

55

55

45

45

28

33

15-Nov

50

55

41

45

18

31

15-Dec

28

49

23

40

16

15-Jan

12

15-Feb

C. Broiler Litter
15-Sep

39

39

29

29

12

12

15-Oct

39

39

29

29

10

12

15-Nov

36

39

26

29

11

15-Dec

20

35

15

26

15-Jan

15-Feb

Impact of a change in the closed period on nitrate leaching.

31. The data indicate that extending the closed period from late autumn to 31 December will prevent all or most nitrate leaching
associated with the manure applied in the current season, for soils where N is recovered to a depth of 100 cm. Losses of 5-10% of total
applied N may occur on sandy soils in arable cropping following applications of manure in early January. For soils where N is recovered to a
depth of only 60 cm, nitrate leaching may be expected on light sandy soils under arable cropping. Losses from medium soils and from
grassland would be very small or zero. For a closed period ending on 28 February, no nitrate leaching losses would be expected, under the
ascribed climatic conditions and soil types, from subsequent applications of manure whether to arable or grass crops.
32. The proportion of total N which is potentially available to the crop from these manures is 40 - 60%. After allowing for volatilisation, this
falls, to about 24-50% depending on conditions. When the manure is applied in the autumn, on sandy soil, all of the available N ( i.e. N
convertible to nitrate) is leached. On the medium soil, about 80% of the N at risk of leaching is actually leached from an autumn application
to arable land, or 64% from an application to typical grassland (assuming the grass crop takes up some of the manure N). When the
manure is applied in spring, or indeed from mid January onwards, these losses are prevented. The N is available for uptake by the growing
crop.
33. These calculations assume that the management of manure is not affected by the change in timing i.e. it is assumed that manures
applied in late winter/ early spring will be incorporated. If this is not the case, volatilisation losses may be greater for manures applied in
spring, thereby reducing the N available to the crop compared to the calculated value.
Run-off potential
34. In addition to direct leaching losses, we must also consider losses by way of surface run-off. Although rainfall and climate vary across
Scotland the broad patterns are similar. Figure 5 shows that the annual distribution of water balances in the Borders and NE Scotland NVZs
have a similar pattern.
Annual Water Balance
a) Borders NVZ

Annual Water Balance

b) NE Scotland NVZ

Figure 5. Monthly histograms of water balance for a) the Borders NVZ (data taken from ADAS report Table 5.10) and b) the North east
Scotland NVZ (data provided by SEPA). This show levels of rainfall, evapotranspiration ( ET) and the resulting soil moisture deficit ( SMD)
or hydrologically effective rainfall (HER). The (a) SMD and (b) HER are, respectively, an expression of the relative dryness of a soil, and the
portion of incoming rainfall that contributes to stream flow or recharging groundwater.
35. Figure 6 shows that higher run-off (termed "run-off potential") is expected from September to March, with the highest risk occurring
from October to January inclusive.
Figure 6. Monthly variations in run-off potential in a) Borders NVZ and b) the North east Scotland NVZ.
Run-off Potential
a) Borders NVZ

Run-off Potential
b) NE Scotland NVZ

36. The run-off potential indicates the extent to which rainfall is considered likely to enter surface waters via field drains or actual surface
run-off rather than remaining stored within the soil. Figure 7 shows that river flow does indeed increase during periods of higher run-off
potential. If most of the soil nitrate is held within the soil matrix, then water moving through cracks and drains will not be mixing with soil
and will therefore be low in N. However, if for example, rain falls after a recent slurry application, water can pick up N before transferring to
cracks and drains. Based on the run-off potential, such risks remain high until the end of January, particularly on heavier soils with effective
drainage systems.
River flow vs Run-off potential NE Scotland NVZ

Figure 7. Relationship between river flow and run-off potential in the NE Scotland NVZ.
Effect of crop
37. Crop cover during autumn/winter is an important factor determining the fate of the nitrate present in soil in autumn. An early-sown and
well-established autumn crop can take up a substantial amount of N ( e.g. 20-80 kg/ha) during autumn and early winter and thus decrease
the amount left in soil and available for leaching. In MAFF trials there was at least 20 kg N/ha less nitrate leaching in a winter cereal sown
in mid-September compared to bare fallow land. Autumn sowing is not effective in decreasing leaching if emergence or sowing is late
( e.g. in October) due to limited crop cover and growth. Leaching losses following slurry applications to grass in September are also
reported to be slightly lower than in October, reflecting greater slurry N uptake by the grass crop at the earlier application.
38. The actual N uptake of winter-sown crops or grass in the NVZs during the autumn to winter period will vary greatly depending on crop
type, weather, soil conditions, sowing date and other agronomic factors. SAC (2001) shows that typical N uptake rates during the
autumn/winter for early sown and well growing crops are estimated to be:

Typical N uptake rates during the autumn/winter

winter oilseed rape

50-100 kg N/ha

winter barley

20-30 kg N/ha

winter wheat

5-10 kg N/ha

grass

20-30 kg N/ha

Proposed closed period for organic manures with high available N

39. From the available evidence, a closed period running from early autumn to 31 December will prevent most nitrate leaching losses.
However, we also have to consider the risks of drainage / surface run-off and as discussed above this risk is highest up until the end of
January. The options presented in the main consultation document take these factors into account and also recognise that there can be
significant uptake from early sown arable crops. Option1 in the main report also takes account of the different risks associated with
sandy /shallow soils and 'other' soils.
Why farm yard manure has been excluded from the closed period
40. Farm yard manure ( FYM) contains only 5-25% available N. Therefore, losses due to fresh applications of straw-based FYM are smaller
than from slurries or solid poultry manures (for an equivalent input of total N).
41. In terms of risks of emission of gaseous ammonia, incorporation of FYM is preferable to surface application. FYM cannot be applied by
low-emission techniques such as injection or band spreading. Application to growing arable crops, or to grassland in late spring, is
problematic because of crop damage and herbage contamination. In terms of P loss (and therefore also pathogens and BOD), incorporation
is also preferable to top-dressing. For these pollutants, the worst situation is application to the surface of soils just prior to or during rain
events when the risk of surface run-off occurs.
42. Autumn applications of cattle FYM will usually be of stored manure with a low proportion of ammonium nitrogen (typically 5-10%
compared to 50-60% for slurries). On grassland and early-autumn drilled arable crops, this smaller quantity of additional N will be taken up
by the crop. The DEFRAreport found that experiments (Chambers et al., 2000 16) and modelling both confirm very small or zero losses
where FYM is applied in early autumn to grassland and winter cropped arable land. The benefits in terms of reduced nitrate leaching of
extending the closed period to straw-based manures would be small. The current restrictions on the use of fertilisers close to water courses,
and during adverse weather and/or soil conditions apply to FYM. It is therefore considered that, balancing all risks and practicalities, it is
not necessary or desirable to impose closed periods on the application of straw-based manures.
Conclusion
43. From the information above, it is clear that the loss of nitrate to water will depend on a number of variables - soil type, weather and
temperature, plant growth, land use and crop rotation, and be particularly influenced by farm management practices including the
frequency and timing of the application of fertilisers. While there is a risk of loss at any time of the year, there needs to be a balance of
measures between the use of fertilisers for the benefit of soil structure and crop yield, and the reduction of unnecessary damage to the
water environment.
44. We know that the opportunities for losses of nitrate increase with soil permeability. Whereas the current Action Programme contain
measures to combat situation of highest risk (leaching from shallow and sandy soils), we now also consider that there can be high and
moderate risks associated with all soil types. The circumstances of these risks arising were not previously identified, but include the risk of
run-off and drainage channels in winter months. With that in mind, and based upon the evidence considered, changes to the Action
Programme are required.
45. While autumn N applications are economically and environmentally inadvisable for most crops, nevertheless a few early-sown crops
( e.g. winter oilseed rape and fodder catch crops) give an economic response to a small amount of autumn N. For organic manures, a
closed period covering the whole of the autumn and early winter would present difficulties on clay soils, and could cause increased losses

due to the inability to incorporate rather than top-dress these manures. However, early autumn applications of manures to grass and to
early-sown arable crops carry little risk of leaching. Straw-based manures ( FYM), especially stored cattle FYM, have very low crop-available
N, and therefore it is not necessary for the closed period to apply to them in addition to the general restrictions concerning adverse weather
and soil conditions that already apply.
46. The main inputs of N and P on to farms are as fertiliser and feedstuffs for stock. It is important for farmers to assess crop needs, the
risks of nutrient loss and to keep records of fertiliser applications in order to balance the beneficial use which fertilisers can bring to
production and impacts that overuse can have on the water environment. Though not part of this Annex, these issues will be addressed by
the formulation and implementation of revised Action Programme measures concerning the manure and fertiliser plan, and the
introduction of risk assessment procedures will improve adjustment of fertiliser inputs for local/ annual circumstances.
47. Overall, it is important that the Action Programme requirements seek to minimise the situations that we know lead to nitrate losses.
However, we also know that these processes are subject to variations which we cannot fully predict, such as periods of wet weather. Some
of the risks of losses result from these variations, and therefore the revised Action Programme measures take account of the need to
ensure that reasonable steps are also taken to prevent problems from arising when such changes occur.