RABDF has expressed grave concerns about Defra’s Clean Air Strategy, which was published last week, particularly the failure to acknowledge the impact productivity and system type can have on emission levels and opportunity to mitigate.

The organisation says that despite submitting substantiated, evidence-based comments, almost none of its points have been considered or incorporated into the new strategy.

With dairy cattle being held responsible for 28% of ammonia emissions in 2016 (31%: 2015) RABDF says it is clear some changes are required by the industry to allow Government reduction targets to be met by 2030.

However, it has emphasised the importance of looking at the proposals in the context of unintended consequences or lack of suitability.

For example, while environmental permits work for the pig and poultry sector, the dairy industry is less intensive and does not fall into defined production systems such as ‘all continuously housed’ or ‘all continuously grazed’.

With no threshold outlined in the proposal, RABDF has expressed hope that the Government’s final emission limits will not be prohibitive to farms that have smaller herds, as these could be forced out of business, contributing to the already declining UK dairy producer numbers.

The commitment to contribute towards the costs of measures such as the adoption of low emission spreading equipment and mandatory slurry store coverage has been welcomed, but other measures appear unrealistic and have not been amended from the draft version of the strategy.

For example, mandatory housing designs will be a challenge due to the range of systems and lack of standardisation throughout the sector.

The requirement for solid manure and digestate to be incorporated within 12 hours is impractical given the reliance of many farms on favourable weather or contractors. The introduction of nitrogen limits also doesn’t differentiate between bought-in sources, and those produced on-farm where farmers can maximise ‘home-grown’ nutrients and contribute to the proposed National Good Code of Practice outlined in the strategy.

A panel of experts will examine the burning question ‘can we deliver on the Clean Air Strategy?’ at Dairy-Tech on February 6.

Joining the panel will be Nigel Penlington, AHDB; Paul Tomkins, NFU; Paul Galama, Wageningen University and Liam Sinclair, Harper Adams University.

Tickets are free for RABDF members, £17 in advance and £20 on the gate. Further information on the event can be found at www.dairy-tech.uk.

The full response submitted by RABDF to the Clean Air consultation can be viewed online at www.rabdf.co.uk/lobbying-consultations-1/