Urged on by the EU proposed changes to the Nitrate Vulnerable Zone (NVZ) Action Programme are likely to present the biggest regulatory challenge for dairy farmers over the next two years.

With the need to increase on farm storage of muck and slurry for up to 22 weeks at a time and only to be able to apply it to the land at a set level, and over certain periods of the year, mean that many dairy farmers could face substantial increased costs.

Currently 55% of England (45% of milk quota) and 3% of Wales is designated as NVZ. The consultation proposes an increase in the area currently designated as NVZ to at least 70% and maybe even 100% of England.

Defra has now launched the long awaited NVZ consultation covering the revision of NVZ designations and a part of Pembrokeshire is expected to be the first area of Wales to come within a zone. Fears are that further extensions to these NVZ's could be introduced sooner rather than later.

The implications are a whole farm manure loading limit –the maximum whole farm loading limit will reduce to 170 Kg manure N/ha for all NVZ land and the current grassland derogation of 250 kg N/ha will cease to apply.

To comply with this limit the options are to move manure off the farm, buy more land or decrease the size of the present dairy herds.

The NFU is pushing hard for a new derogation to be sought and Defra has, in fairness, committed to pressing the case for this with the EU Commission.

Farmer Chris James who runs two dairy units on tenanted land in a family partnership at Stackpole fears that, in order to come within the proposed limits to reduce stocking density, he would have to reduce the number of their cows by up to 20%.

"This new legislation is likely to be introduced despite all reports showing that nitrate levels on land, and in our water courses, is consistently falling, and, with increased fertiliser prices, likely to fall much faster" he says.

The Defra consultation period has been extended to December 13.