Available online at www.sciencedirect.

com

Geoderma 144 (2008) 418 – 425

www.elsevier.com/locate/geoderma

Discussion paper
Nutrient management regulations in The Netherlands
J.J. Schröder ⁎, J.J. Neeteson
Agrosystems Research, Plant Research International, Wageningen University and Research Centre, PO Box 16, 6700 AA Wageningen, The Netherlands
Received 7 May 2007; received in revised form 7 September 2007; accepted 19 December 2007
Available online 29 January 2008

Abstract

The application of nutrients affect the quality of the environment which justifies the consideration of regulations regarding their use in
agriculture. In the early 1990s The Netherlands decided to use the indicator ‘nutrient surplus at farm level’ as the basis for a regulation which was
called the mineral accounting system (MINAS). Exceedance of specified nitrogen (N) and phosphorus (P) surpluses (‘N and P loss standards’),
resulted in a financial levy per kg exceedance. This NP surplus approach is a ‘goal-oriented regulation’ rather than a ‘means-oriented regulation’,
giving farmers maximum freedom to stop nutrient leaks where they considered measures to be most effective in their specific situation. In 2003,
however, the European Court of Justice ruled that The Netherlands Action Programme, of which MINAS was part, was in conflict with the EU
Nitrates Directive. Important consideration here was that the legislation in The Netherlands contained as yet no specified application rates for N.
The Netherlands was also reproached for implicitly allowing application rates of more than 170 kg N in the form of animal manure per ha per year
without possessing formal permission by the European Commission to deviate from this threshold, a so-called ‘derogation’. A new, and
meanwhile by the European Commission accepted Netherlands Action Programme defines the required N application rates, N fertilizer
replacement values of various organic manure types, and periods in which the use of fertilizers and manures is forbidden. All these aspects will be
sharpened in the years after 2006.
© 2007 Elsevier B.V. All rights reserved.

Keywords: Derogation; Nitrates directive; Nitrogen fertilization; Nutrient legislation; Nutrient management; Nutrient emissions; Phosphorus fertilization

1. Introduction Assessment of the environmental quality requires meaningful

The application of nutrients, phosphorus (P) and nitrogen
(N) in particular, affect the quality of the local, regional and
global environment via e.g. eutrophication of aquatic and
terrestrial ecosystems and via the emission of greenhouse gases.
These environmental effects of nutrient use are beyond doubt
(Carton and Jarvis, 2001) and justify the consideration of
regulations regarding their use in agriculture. Nitrogen may also
have harmful effects on human health. It is a misunderstanding
to think that N application regulations are no longer required
because these effects are questioned from time to time (Van
Grinsven et al., 2006).
⁎ Corresponding author. Tel.: +31 317 475965; fax: +31 317 423110.
E-mail address: jaap.schroder@wur.nl (J.J. Schröder).
0016-7061/$ - see front matter © 2007 Elsevier B.V. All rights reserved.
doi:10.1016/j.geoderma.2007.12.012
indicators (‘yardsticks’) to which reference values (‘thresholds’)
must be attached. The ideal indicator is effective (says something
about the ultimate goal), responsive (reacts to changing
agricultural activities), attributive (can be ascribed to an
accountable legal body), integrative (preferably includes several
goals at the same time to avoid the need of a separate indicator for
each separate target) and efficient (cheap to measure in relation to
the desired accuracy). Unfortunately, an indicator with an
excellent score on all five criteria does not exist (Schröder et al.,
2004a). The various candidate indicators are hierarchically related
(Fig. 1) from which can be derived that some indicators show a
good score for effectiveness but are not attributive (e.g. nitrate
content of deeper groundwater, phosphorus content of surface
water). Other indicators are efficient but have a limited indicative
value as regards the ultimate goal (e.g. stocking density) or they
are integrative but do not indicate the precise nature and
magnitude of the emission (e.g. N surplus at farm level).
 J.J. Schröder, J.J. Neeteson / Geoderma 144 (2008) 418–425
2. MINAS and the European Court
In the early 1990s The Netherlands decided to use the
indicator ‘nutrient surplus at farm level’. As of that moment
crop growers and livestock farmers had to keep accounts of the
N and P input and output, which had to be reported annually: the
MINeral Accounting System (MINAS). The difference between
inputs and outputs results in N and P surpluses (expressed in kg
per ha per year). MINAS considered surpluses environmentally
acceptable up to a certain level. These levels (‘the N and P loss
standards’) differed per crop and soil type (Table 1) and their
exceedance resulted in a financial levy per kg exceedance. This
farm-gate balance approach, which showed a reasonable score
for each of the five criteria above, was appreciated in The
Fig. 1 Hierarchy of indicators to determine and check the effects of nutrient
losses from agriculture on the quality of drinking water and environment
(Schröder et al., 2004a).
419
Table 1
The (levy-free) nitrogen and phosphorous loss standards as they would have
been applying from 2008 under MINAS (nutrient balance based on flows
through the farm gate, thus excluding deposition)
Crop N loss standards P loss standards
(kg N ha− 1 year− 1) (kg P2O5ha− 1 year− 1)
Dry sandy soil Other soils
Grassland 140 180 20
Arable crops 60 100 20
Netherlands, as well as abroad. MINAS is a ‘goal-oriented
regulation’ rather than a ‘means-oriented regulation’, giving
farmers maximum freedom to stop nutrient leaks where they
considered measures to be most effective in their specific
situation. This approach meant that ample use of fertilizers and
manures was not forbidden a priori as long as the farmer
demonstrated that high application rates went together with a
high annual nutrient export in the form of crops, animals, or
products of animal origin (Schröder et al., 2003).
On 2 October 2003 the European Court of Justice ruled that
The Netherlands Action Programme, of which MINAS was
part, was – for certain aspects – in conflict with the EU Nitrates
Directive. Important consideration here was that the act – as
applied at that time – contained no specified application rates
for N, which should have been based on a balance between the
expected N demand of a crop and the N supply from soil and
fertilization. The Netherlands was also reproached for implicitly
allowing an application rate of more than 170 kg N in the form
of animal manure per ha per year without possessing formal
permission by the European Commission to exceed this manure
application threshold, a so-called ‘derogation’. That MINAS
was in fact a retrospective check rather than an a priori control
system at the start of the season, as a system of specified
application rates would be, was an additional consideration of
the Court.
In The Netherlands the Court ruling was received with
amazement. How could it be that a balance approach, scientifi-
cally superior to a one-sided input approach (e.g. Schröder et al.,
2003), was put to the sward? It cannot be ruled out that in the
background and certainly in the corridors, other factors also
played a role in the ruling. These factors are elaborated below.
Over the years MINAS had become the result of practical and
political considerations and had, consequently, in a way turned
from a good idea into a paper tiger. Growers of arable and
horticultural crops, for instance, were permitted to use a high
default value for their export, amounting to 65 kg P2O5 and 165 kg
N per ha per year, regardless of their actually achieved yield. In
addition, an extra amount of 40 kg N per ha was permitted
annually when two crops were grown within 1year (double
cropping). Furthermore, mineral fertilizer P did not need to be
counted as an input to avoid discouragement of arable farmers
purchasing manure. Dairy farmers in turn were permitted to
discard possible N fixation by white clover as input as well as the
N supply resulting from the continuing mineralization of settling
peat. In addition, livestock farmers could apply a discount for
gaseous N losses (‘the animal correction’) on the thus calculated
420 J.J. Schröder, J.J. Neeteson / Geoderma 144 (2008) 418–425
surplus. This animal correction quite easily ran up to more than
35 kg N per ha per year on intensive dairy farms with maize
(Schröder and Corré, 2000). Deduction of this NH3 loss was not
balanced by adding NH3 deposition because this was already
taken into account in the permitted N loss standard. If only from a
communication point of view this was not a strong act.
As a consequence of these gestures the surpluses calculated
on paper (legally permitted and levy-free) were smaller than the
actual surpluses (Schröder et al., 2003). Apart from that, the
Court considered the permitted (calculated) surpluses to be very
high and the penalties in case of exceedance very low. To make
matters worse, The Netherlands could not provide convincing
evidence that water quality had meanwhile sufficiently
improved as a result of the praised balance approach.
Although the Nitrates Directive formally only covers N, all
delaying tactics resulted in the Water Framework Directive
(Anonymous, 2000) catching the eye of the European evaluators.
The inevitable consequence was that between late 2003 and mid
2005 The Netherlands not only had to legally define crop-specific
application rates for N but also for P to enable timely
implementation of such standards, i.e., per 1 January 2006.
3. New Fertilizer Policy
3.1. Science on its own
Upon assignment by The Netherlands Ministry of Agricul-
ture, Nature and Food Quality (LNV) and the Ministry for
Housing, Spatial Planning and the Environment (VROM) a
group of scientists from various research organizations was set
free at the end of 2003 to formulate a basis for the New Fertilizer
Policy. First, this required actualization of the existing knowl-
edge on the relationships between animal feeding, excretion and
gaseous losses from housing and storage, and about the N
fertilizer replacement value of manures. Next, soil surpluses
needed to be calculated on the basis of relationships between the
input of nutrients in the form of – inter alia – fertilizers and
manure, and the output in the form of – inter alia – harvested
crops. Finally, actualized relationships needed to be established
between soil surpluses and the quality of groundwater and
surface water.
These studies formed the building blocks for answering the
question which combination of organic manure and mineral
fertilizer enabled meeting the N concentration goal of the
Nitrates Directive. Finally, the scientists proposed crop-specific
application rates based on the answers to the questions above.
The studies resulted in five reports: Tamminga et al. (2004), Van
Dijk et al. (2004, 2005) and Schröder et al. (2004b, 2005a).
In the past, such studies were often carried out as a joint
effort of policy officials, researchers and representatives of the
agricultural sector. This resulted in reports and decisions with an
appreciated broad support, but also in documents of which it
gradually became unclear by whom and why certain figures had
been chosen in final versions. Technical, economic and political
considerations were strongly interrelated at the time and those
representing environmental interests were unlike those repre-
senting agricultural interests, hardly involved in the decision
making. This time the roles were kept much more separated
right from the start and scientists could restrict themselves to
technical matters. It is part of the deal that policy makers do not
literally adopt the scientific proposals and may selectively graze
in the reports. The final versions of all reports have, incidentally,
been published and have been made available to each and
everyone, also to stakeholders and to evaluators in Brussels.
Anyway, policy makers could no longer suggest non-existing
scientific certainties by referring to the former joint reports of
policy, science and sector. In any case it was perfectly clear this
time who selects, weighs and decides.
3.2. Application standards
A ‘forward order’ has very explicitly been followed in the
scientific study into the relationship between fertilizer use and
water quality: the N concentration in water bodies was the point
of departure rather than the present agricultural practice. Upon
indication of the Ministries of LNV and VROM, the intended
goal was a concentration threshold of 11.3 mg NO3–N per litre
in the upper metre of groundwater underneath sandy soils and
11.3 mg N-total per litre in drain or ditch water in clay and peat
areas. The Ministries of LNV and VROM did incidentally not
derive these goals for clay and peat soil directly from European
regulations but from an arbitrary advancement on the N-total
concentrations that seem at least required in the low northern and
western areas of The Netherlands from an eutrophication point
of view. Note that on sandy, clay and peat soils 85–90%, 80–
85% and 0–20%, respectively, of N-total consists of NO3–N.
Soil type and crop-specific permissible N surpluses have
been calculated on the basis of existing measurements of N
concentrations and N surpluses on about 75 commercial farms
which participate annually in the Landelijk Meetnet Effecten
Mestbeleid (LMM, Netherlands Monitoring Network Effects
Fertilizer Policy) (Schröder et al., 2004b, later updated in
Schröder et al., 2007). The LMM network indicates that the
same soil N surplus does on balance result in more N leaching
from arable land than from grassland and that leaching from dry
soils is higher than from wet soils, where differences in deni-
trification seem to play the most important role. Table 2 presents
an overview of the average leaching fractions as derived from
the LMM network.
Following the calculation of the permissible soil N surpluses,
crop-specific coefficients for the N harvest index, the recovery
of soil mineral N and the N fertilizer replacement values of all
relevant organic N sources were used to calculate at which
manure–mineral fertilizer combination the N concentration goal
could just be met. Table 3 presents the relevant steps and
balance terms in the form of an example. It should be noted
here that at the input side all items have been included which,
according to Brussels, had incorrectly been lacking from earlier
Action Programmes. At the same time Brussels gradually
accepted the reasoning that in an equilibrium situation these
inputs are to be offset against outputs (‘investments’) which
may be deducted from the surplus to get a realistic picture of the
environmental load. The amount of N lost to groundwater or
surface water is calculated as the fraction (0.28 kg N per kg N
 J.J. Schröder, J.J. Neeteson / Geoderma 144 (2008) 418–425 421

Table 2 2004b). Especially on clay and peat soil, the calculated ap-
Leaching fraction (F, kg N leached per kg N soil surplus), precipitation surplus plication standards were often higher than the existing
(P, mm), and soil surplus (S, kg N per ha) corresponding with an N concentration
of 11.3 mg NO3–N (sandy soil) or total N (clay and peat soil) per litre as a
N recommendations. In such cases it is posed that the current
function of soil use and soil type (Landelijk Meetnet Effecten Mestbeleid N recommendation suffices as future application standard. This
(LMM) 1992–2001 meant that the existing N recommendations changed from a
Soil use Soil type Leaching Precipitation Permissible guideline into a legal instrument, a significance they never had
fraction, F surplus, P soil surplus, S before. Understandably, this put the N recommendations under
Arable Clay 0.31 387 141 fire even though they had been established under co-respon-
land Sandy, wet 0.50 387 87 sibility of the agricultural sector. A frequently heard argument
Sandy, 0.75 434 65 of those who opposed the current N recommendations was that
intermediary current crop production levels are higher than the levels in the
Sandy, dry 1.06 453 48
experiments on which the recommendations were based. Such
Grassland Peat 0.03 242 N 300
Clay 0.11 266 273 reasoning disregards that there generally is not a one-to-one
Sandy, wet 0.18 268 168 relationship between yield and the economically optimum
Sandy, 0.28 329 133 N rate. This is only the case if the relationship between supply
intermediary and uptake (‘recovery’) would remain unchanged and if the
Sandy, dry 0.39 355 103
relationship between uptake and marketable yield (N yield and
Source: Schröder et al., 2005a, 2007). harvest index) would remain unchanged. For silage maize, for
instance, there are many indications that high yields go hand
in the example of Table 3) times the difference of inputs in hand with lower optimum N rates as a result of higher
and outputs (i.e. 134 kg N per ha per year in the example of recoveries (Vanotti and Bundy, 1994a,b; Schröder et al., 1998;
Table 3). To arrive at a concentration, as required by the Nitrates Nevens and Reheul, 2005). Meanwhile a protocol has been
Directive, the amount of N lost to water (kg per unit area) must developed on the basis of which existing N recommendations
be divided by the volume of the precipitation surplus (litres per may be adjusted in case of justified doubt about their correct-
unit area, i.e. 329 mm in the example of Table 3). ness (Ten Berge et al., 2005).
In this way so-called application standards have been Contrary, for crops such as leafy vegetables grown on sandy
calculated for dozens of crops and soil types (Schröder et al., soil, the calculated application standards were lower than the

Table 3
The animal manure–mineral fertilizer N combination (total N per ha per year) for grassland under mixed cutting/grazing on a sandy soil with an average highest
groundwater table between 40 and 80 cm below surface level assuming good growing conditions and good management, complying with a nitrate concentration in the
upper 1m groundwater of exactly 11.3 mg NO3–N per litre whilst avoiding P accumulation (Schröder et al., 2005a)
Total N Effective Nd Total P2O5
−1
Input Manure Kg ha 275 118 99
Mineral fertilizer Kg ha− 1 171 171
Clover Kg ha− 1 0
Deposition Kg ha− 1 31 23 1
Nmin Soil, spring Kg ha− 1 30 30
Mineralization from Roots, stubbles Kg ha− 1 75 56
Harvest and Kg ha− 1 46 35
grazing losses
Manurea Kg ha− 1 69 52
Cover crop Kg ha− 1 0
Total Kg ha− 1 697 485 100
Output Crop exportb Kg ha− 1 324 100
NH3 volatilization Kg ha− 1 19
Investments into Soil, spring Kg ha− 1 30
Roots, stubbles Kg ha− 1 75
Harvest and Kg ha− 1 46
grazing losses
Manurec kg ha− 1 69
Cover crop 0
Total kg ha− 1 563 100
Soil surplus kg ha− 1 134 0
Leaching fraction kg kg− 1 0.28
Precipitation surplus Mm 329
NO3–N mg L− 1 11.3
a
N residual effect of manure from the years preceding the year of application.
b
N export after deducing harvest and grazing losses.
c
N investment to sustain future residual effects of manure.
d
N fertilizer replacement value in the year of application.
422 J.J. Schröder, J.J. Neeteson / Geoderma 144 (2008) 418–425

Table 4 Table 6
Application standard for phosphate from organic manure and mineral fertilizer Nitrogen application standards for a number of forage crops (kg plant available
together (source: www.minlnv.nl/loket) N per ha) (source: please link: www.minlnv.nl/loket)
Crop P application standard (kg P2O5 ha− 1 year− 1) Crop Soil type and year
Year Clay Clay Sandy/loess Sandy/loess
and peat and peat
2006 2007 2008 2009 2015
2006 2009 2006 2009
Grassland 110 105 100 (95) b (90) b
Arable crops 85 (+10) a 85 (+5) a 85 (80) b (60) b Grassland, mixed use, clay 345 310
a Grassland, mixed use, sandy/loess 300 260
the supplements (in brackets) may only be given in the form of mineral
Grassland, mixed use, peat 290 265
fertilizer P.
b Grassland, cutting only, clay 385 350
indicative values requiring further study.
Grassland, cutting only, sandy/loess 355 340
Grassland, cutting only, peat 330 300
existing N recommendations. Meeting the N concentration goal Maize, with derogation 160 160 155 150
underneath the crop in question would in that case be associated Maize, without derogation 205 185 185 (b175)
with a yield penalty. This penalty may be restricted by alternative
fertilization techniques (splitting, placement, provisional fertiliza- There are three types of application standards: one for total P
tion on the basis of crop or soil indicators, removal of crop (sum of mineral fertilizer and organic manure; Table 4), one for
residues, cover cropping), but even then yield reductions would plant available N (sum of mineral fertilizer and N becoming
be imminent. In response to this, the Ministries have met the available during the first season after application of a manure
growers of these crops quite a long way by increasing the ap- (i.e. the N fertilizer replacement value) with examples for
plication standards proposed by scientists. The apparent reason- horticulture and arable crops shown in Table 5 and for forage
ing of the Ministries is that these crops only cover a small acreage crops in Table 6), and one for N in the form of animal manure.
which means that the relaxation of application standards does not In principle, not more than 170 kg animal manure N may be
or hardly affect the eventual outcomes of the mandatory (regional) applied per ha per year insofar this is not in conflict with the
water quality monitoring. As long as Brussels has not made clear application standard for total P (Table 4). Individual dairy farms
to what extent member countries are allowed to average land use can, however, submit a request for permission to apply up to
with high and low nitrate leaching risks (as when a farm with just 250 kg cattle slurry N per ha (see next section). Note that The
leafy vegetables such as spinach and lettuce is sufficiently com- Netherlands Action Programme includes N application stan-
pensated by nearby farms with e.g. only cut grassland), the dards for horticulture and arable crops grown on clay soils for
Ministries may get away with the previous reasoning. the full duration of the Programme i.e. up till 2009. However,
the European Commission gave a temporary dispensation to fix
3.3. New action programme the definitive numbers for this type of crops grown on sandy
and loess soils (Table 5), awaiting the outcomes of additional
The new, and meanwhile accepted Netherlands Action research. Final decisions on these N application standards will
Programme defines application standards, N fertilizer replacement be made in the course of 2007.
values of various organic manure types, and periods of the year in N fertilizer replacement values of manures have been laid
which the use of fertilizers and manures is forbidden. All these down for calculating the N supplement that may still be given as
aspects will be sharpened in the years after 2006. The full text with
Annexes can be found via www.minlnv.nl/loket (in Dutch).
Table 7
N fertilizer replacement value to be applied for organic manure (kg N per 100 kg
Table 5 N) (source: Please link: www.minlnv.nl/loket)
Nitrogen application standards for a number of arable and horticulture crops Manure type Year
(kg plant available N per ha) (source: www.minlnv.nl/loket)
2006 2007 2008 2009
Crop N application standard (kg plant available N ha− 1 year− 1)
In-farm produced cattle manure (farm yard 35 35 45 45
Soil type and year manure, slurries) on farm with (also) grazing
Clay Clay Sandy / loess Sandy / loess In-farm produced cattle manure (farm yard 60 60 60 60
manure, slurries) on farm with only cutting
2006 2009 2006 2007
Imported cattle manure (farm yard manure, 60 60 60 60
a a a
Ware potatoes 250–300 225–275 240–290 225–275 a slurries) and all other slurries
Sugar beet 165 150 150 145 Solid manures from pigs and poultry, solid 55 55 55 55
Winter wheat 240 220 160/220 160/220 fraction after separation
Spring barley 90 80 80 80 Liquid manure, liquid fraction after separation 80 80 80 80
Spinach, 1st crop 285 260 210 200 Manure (farm yard manure, pigs/poultry) on 30 30 35 35
Spinach, 205 185 160 150 clay and peat arable land in autumn
follow-up crop Manure (farm yard manure, other) on clay and 25 25 30 30
Leeks 270 245 245 235 peat arable land in autumn
Broccoli 295 270 270 255 Manure (slurries) on clay and peat arable land 30 40 50 Forbidden
a in autumn
variety-dependent.
 J.J. Schröder, J.J. Neeteson / Geoderma 144 (2008) 418–425 423

Table 8
Periods during which spreading of organic manure is forbidden, in relation to the farm (not) having submitted a derogation request (source: please link: www.
minlnv.nl/loket)
Crop Soil type Derogation Year
2005–2006 2006–2007 2007–2008 2008–2009 2009–2010
Grassland Sandy, loess Yes/no 1 Sept–31 Jan 1 Sept– 31 Jan 1 Sept–31 Jan 1 Sept–31 Jan 1 Sept–31 Jan
Clay, peat Yes/no 15 Sept–31 Jan 15 Sept– 31 Jan 15 Sept–31 Jan 15 Sept–31 Jan 15 Sept– 31 Jan
Arable Sandy, loess Yes/no 1 Sept–31 Jan 1 Sept–31 Jan 1 Sept–31 Jan 1 Sept–31 Jan 1 Sept–31 Jan
land Clay, peat Yes 15 Sept–31 Jan 15 Sept–31 Jan 15 Sept–31 Jan 15 Sept–31 Jan 15 Sept– 31 Jan
Clay, peat No 1 Dec–31 Jan 15 Nov–31 Jan 1 Nov–31 Jan 15 Oct–31 Jan 15 Sept–31 Jan

mineral fertilizer within the application standard for available N, to apply up to 250 instead of 170 kg cattle slurry N per ha per
i.e. in addition to manure (Table 7). These imposed replacement year. Note that these rates pertain to the amount of total N
values are ambitious and will hence discourage ineffective applied in manure including the urine and dung excreted during
applications of animal manure in autumn. Autumn application grazing while deducing the gaseous N losses occurring from
of animal manure on clay and peat arable land will in fact in due housing and storage (but not those emitted during grazing). As
course no longer be permitted, comparable to the existing ban the internal manure flow on livestock farms is difficult to
on sandy soil (Table 8). administer, it is required to convert registered animal numbers
The Action Programme also contains instructions regarding into produced amounts of manure N and manure P. N and P
manure storage capacity (6 months) and regarding times and excretion, however, not only depend on animal types and
places when and where the use of fertilizers and manures is numbers but also on production level and N concentration of the
forbidden (slopes, frozen and snow-covered soil, along water- feed ration. For dairy cattle it has been decided to derive this N
courses). Another requirement is the obligation to grow a cover concentration in feed from the urea content of the delivered milk
crop after maize on sandy and loess soil. (Tamminga et al., 2004). The urea content in milk reflects to
what extent N in excess of animal demand has been offered,
3.4. Derogation which N will inevitably be excreted in manure (e.g. Schröder
et al., 2005c). All this has led to detailed excretion tables of
Parallel to the preparation of a new Netherlands Action which Table 10 shows an example.
Programme as described above, a scientific basis has been
developed for a derogation request for dairy farms. This basis is,
as opposed to situations in the past, not an ex-post justification
of an earlier taken political position but again an objective ex- Table 10
Excretion of nitrogen (kg N per animal per year after deduction of losses from
ante exploration. housing and storage) and phosphate (kg P2O5 per animal per year) by dairy cattle
The study, consisting of a mix of modelling and experimental and young stock, depending on housing system (‘manure type’), milk
validation (Schröder et al., 2005a, 2007) showed that the production level, and feed protein content (as represented by milk urea
fertilizer and manure rates to be defended depend on 1) the content) (source: Please link: www.minlnv.nl/loket)
shares of cut grassland, grazed grassland and maize land in the Manure Animal Milk production, Urea, mg/ Nitrogen Phosphate
total land use, 2) soil type, and 3) growing conditions and type category kg/year 100 ml
management qualities of the farmer (Table 9). The Ministries of Mixed Dairy cow 5500 14 79 35
LNV and VROM have eventually ‘flattened’ these scientific manure
nuances to averages to arrive at simple and enforceable legis- 38 115 35
7500 14 97 42
lation. This resulted in a proposal to Brussels to permit all dairy
38 133 42
farms of which more than 70% of the soil is used as grassland, 9500 14 113 47
38 149 47
Young stock, Not 70 24
Table 9 1–2 year old applicable
Cattle slurry rates (kg N per ha per year) that are according to an ex-ante study Young stock, Not 33 9
permitted in view of the NO3–N concentrations (sandy soil) or total N 0–1 year old applicable
concentrations (clay and peat) lower than 11.3 mg per litre without P Solid Dairy cow 5500 14 71 35
accumulation, as a function of soil and crop type (band widths represent manure
suboptimal to good growing conditions and management (Schröder et al., 38 104 35
2005a, 2007) 7500 14 88 42
Soil type Crop type 38 120 42
9500 14 102 47
Grassland, cutting Grassland, mixed use of cutting Forage
38 135 47
only grazing maize
Young stock, Not 60 24
Clay, wet 290–340 240–280 170–200 1–2 year old applicable
Sandy, wet 290–340 230–270 150–180 Young stock, Not 28 9
Sandy, dry 270–330 210–270 130–160 0–1 year old applicable
424 J.J. Schröder, J.J. Neeteson / Geoderma 144 (2008) 418–425

Table 11 between nutrient inputs and nutrient concentrations in receiving

Permitted mineral fertilizer N rate (kg per ha, weighted average over grassland water bodies. Ideally, regulations should acknowledge these
and maize land) on a dairy farm with derogation of 250 kg fertilizer N per ha and
a grass maize ratio of 70%/30%
differences. At the same time governments find themselves
under pressure to reduce the administrative burden and to create
Soil type and year
a so-called level playing field for their civilians (cf. Schröder
Clay Clay Sandy and loess Sandy and loess et al., 2004a). Apparently, when designing their New Fertilizer
2006 2009 2006 2009 Policy, administrators sought a balance between refinement and
Grassland (mixed use) 202 153 169 115 harmonization.
and maize The European directives themselves are not clear as regards
Grassland (cutting only) 168 143 145 133 the extent to which averaging in space and time is permitted.
and maize There is a high degree of averaging in space and time, with
Brussels permission, in the current Netherlands Action Pro-
The consequence of these criteria is that dairy farmers can gramme. It makes quite a difference whether a criterion must be
produce up to about 14.000l milk per ha without needing to met at a regional level and averaged over a large number of years
dispose of any of the associated manure from their farms. or whether the criterion must be met on each individual field,
Farmers who contract out the rearing of replacement stock or farm and sub-region, in each year, in 95 out of 100 years, or in 90
succeed in keeping their urea content low can produce even out of 100 years (Schröder et al., 2005a, 2007).
some more milk. As opposed to a balance approach, a system of application
Based on the excretion criteria, N fertilizer replacement standards does not really put a premium on efficient nutrient
values of manure N and the proposed application standards for management by the farmer because there is in fact no longer a
(effective) N on grassland and maize land, Brussels has formal restriction to feed a herd with imported feed instead of
meanwhile agreed to such a derogation up to 250 kg slurry N with on-farm grown feed whereas the starting point in
per ha for the period 2006–2009. The derogation will be closely defending the derogation of 250 kg manure N per ha is
followed by monitoring of groundwater and surface water precisely the assumption of efficient fertilization, cropping and
quality. This has resulted in a substantial extension of the LMM
network. Table 11 indicates which mineral fertilizer N rates, Table 12
given the application standards, are permitted on a dairy farm Indicative terms of the N balances (kg total N per ha per year) underlying the N
application standards of the New Fertilizer Policy (NFP, as applicable in 2009)
with 70% grass and 30% silage maize while making maximum
and those underlying the N loss standards (permitted surplus) of the MINAS
use of the derogation. regulation in its strictest and ultimate form, had MINAS not been replaced by the
NFP, for two typical farm types in The Netherlands
4. Discussion Soil type Clay Sand
Farm Arable a Dairy b
On 1 January 2006 The Netherlands replaced the balance type
approach involving loss standards (MINAS) by application
Policy MINAS NFP MINAS NFP
standards. It should be noted, however, that application
standards already existed for arable farming and horticulture Inputs Feed A 0 0 96 96
Deposition B 31 31 31 31
in MINAS because these sectors were allowed to work with
Manure C 145 135 250 250
fixed output values. This means that the major pain of the new Mineral D 120 115 160 115
system arises from the N and P application rates being fertilizer
decreased. Table 12 presents some indicative numbers of Outputs Crops E Default 165
(implicit) loss standards and (implicit) application standards for F True 145 145 280 280
Milk and G 105 105
typical farms under MINAS and under the New Fertilizer
meat
Policy. This table shows that the consequences of the New NH3 H Default c 35
Fertilizer Policy are in particular far-reaching for dairy farming volatilization
despite the derogation. Depending on the circumstances of the I True 7 7 13 13
farm, the room to use mineral fertilizer may decrease on average Permitted
MINAS Arable C+D 100 (85)
by 50 kg N per ha. This is because the loss standards that
surplus −E
implicitly form the basis of the application standards are in fact Dairy A+D 116 d (71)
more stringent than the explicit MINAS loss standards. −G
Although some distinction has been made on the basis of soil −H
type, crop type and grassland use, the very nature of application Soil B+C 144 129 148 103
surplus +D
standards does no justice to all individual situations. The
−F−I
permitted amounts of animal manure are probably still too high a
for farms with much maize on dry sandy soil and unnecessarily 20% sugar beets, 35% potatoes, 30% winter wheat, 15% spring barley.
b
70% grassland (mixed use of cutting and grazing), 30% silage maize;
strict for grass dominated farms on clay soil (Schröder et al., 16,000 l milk per ha.
2005a). This lack of discrimination denies the evident c
so-called ‘animal correction’.
d
differences between soil types regarding the relationship weighted loss standards of grassland (70%) and arable (silage maize) land (30%).
 J.J. Schröder, J.J. Neeteson / Geoderma 144 (2008) 418–425
harvesting (Schröder et al., 2005a, 2007; Aarts et al., 2005).
Therefore, an additional advisory effort seems needed to
prevent that the derogation will in four years not as yet lead
to exceedance of the nitrate concentration target. If this happens,
the application standards will be further reduced. It is not yet
clear whether the interpretation of the Framework Directive
Water will necessitate an additional downward adjustment. The
11.3 mg total N per litre surface water criterion is in any case
often not sufficient to meet the envisaged ecological quality
levels (Camargo and Alonso, 2006), let alone a criterion of
11.3 mg NO3–N per litre.
Another important point is the long-term behaviour of soil–
plant–animal systems. In the underpinning of the current
Netherlands Action Programme, long-term equilibrium situations
were assumed whereas such an equilibrium does in fact not exist
in a dynamic agricultural practice (Schröder et al., 2005a,b). Some
parameters, including those of the LMM network, must by nature
be derived from a continuously changing field situation. It is up to
experts covering areas such as animal feeding, soil science and
crop growing to test the applied parameters in the years ahead.
Without scientific insight in the causes of success and failure,
there is a risk of focusing on the wrong aspects. It will, for
instance, not be necessary to change the application standards if
underestimation of excretions would appear to be the true cause of
too high nitrate concentrations. It could also be interesting to
investigate whether a regional realization of a certain nutrient
concentration in water bodies can be reached via permanent set-
aside/nature development while maintaining the current applica-
tion standards on the remaining farm acreage (Verloop and
Schröder, 2006).
References
Aarts, H.F.M., Daatselaar, C.H.G., Holshof, G., 2005. Bemesting en opbrengst
van productiegrasland in Nederland (Fertilization and yield of production
grassland in the Netherlands, in Dutch). Rapport 102. Plant Research
International, Wageningen. 34 pp.
Anonymous, 2000. Directive 2000/60/EC of the European Parliament and of the
Council of 23 October 2000 establishing a framework for the community action
in the field of water policy. Off. J. Eur. Communities 1–72, 22.12.2000, Brussels.
Camargo, J., Alonso, A., 2006. Ecological and toxicological effects of inorganic
nitrogen pollution in aquatic ecosystems: a global assessment. Environ. Int.
32, 831–849.
Carton, O.T., Jarvis, S.C., 2001. N and P cycles in agriculture. In: De Clercq, P.,
Gertsis, A.C., Hofman, G., Jarvis, S.C., Neeteson, J.J. and Sinabell, F. (Eds).
Nutrient Management Legislation in European Countries, pp 4–13. Ghent,
Belgium, Ghent University, Department of Soil Management and Soil Care.
Nevens, F., Reheul, D., 2005. Agronomical and environmental evaluation of a
long-term experiment with cattle slurry and supplemental inorganic
N applications in silage maize. Eur. J. Agron. 22, 349–361.
Schröder, J.J., Corré, W.J., 2000. Sterkte-en zwakteanalyse van het mineralenaan-
gifte systeem MINAS. (SWOT analysis of the mineral accounting system
MINAS; in Dutch). In: Schröder, J.J., Corré, W.J. (Eds.), Actualisering stikstof-
en fosfaatdeskstudies (Actualization of nitrogen and phosphate desk studies).
Rapport 22. Plant Research International, Wageningen, pp. 119–128.
425
Schröder, J.J., Neeteson, J.J., Withagen, J.C.M., Noij, I.G.A.M., 1998. Effects of
N application on agronomic and environmental parameters in silage maize
production on sandy soils. Field Crops Res. 58, 55–67.
Schröder, J.J., Aarts, H.F.M., Ten Berge, H.F.M., Van Keulen, H., Neeteson, J.J.,
2003. An evaluation of whole-farm nitrogen balances and related indices for
efficient nitrogen use. Eur. J. Agron. 20, 33–44.
Schröder, J.J., Scholefield, D., Cabral, F., Hofman, G., 2004a. The effects of
nutrient losses from agriculture on ground and surface water quality: the
position of science in developing indicators for regulation. Environ. Sci. Pol.
7, 15–23.
Schröder, J.J., Aarts, H.F.M., De Bode, M.J.C., Van Dijk, W., Van Middelkoop,
J.C., De Haan, M.H.A., Schils, R.L.M., Velthof, G.L., Willems, W.J., 2004b.
Gebruiksnormen bij verschillende landbouwkundige en milieukundige
uitgangspunten (Application standards under various agricultural and
environmental assumptions; in Dutch). Rapport 79. Plant Research
International, Wageningen. 60 pp.
Schröder, J.J., Aarts, H.F.M., Van Middelkoop, J.C., De Haan, M.H.A., Schils,
R.L.M., Velthof, G.L., Fraters, B., Willems, W.J., 2005a. Limits to the use of
manure and mineral fertilizer in grass and silage maize production, with
special reference to the EU Nitrates Directive. Report 93. Plant Research
International, Wageningen. 48 pp.
Schröder, J.J., Jansen, A.G., Hilhorst, G.J., 2005b. Long term nitrogen fertilizer
value of cattle slurry. Soil Use Manage. 21, 196–204.
Schröder, J.J., Bannink, A., Kohn, R.l., 2005c. Improving the efficiency of
nutrient use in cattle operations. In: Pfeffer, E., Hristov, A.N. (Eds.),
Nitrogen and Phosphorus Nutrition of Cattle. CABI Publishing Wallingford,
pp. 255–279.
Schröder, J.J., Aarts, H.F.M., Van Middelkoop, J.C., Schils, R.L.M., Velthof, G.L.,
Fraters, B., Willems, W.J., 2007. Permissible manure and fertilizer use in dairy
farming systems on sandy soils in The Netherlands to comply with the Nitrates
Directive target. Eur. J. Agron. 27, 102–114.
Tamminga, S., Aarts, F., Bannink, A., Oenema, O., Monteny, G.J., 2004.
Actualisering van geschatte N en P excreties door rundvee (Actualization of
estimated N and P excretions by cattle, in Dutch). Reeks Milieu en Landelijk
gebied 25, Wageningen UR, Wageningen. 48 pp.
Ten Berge, H.F.M., Van der Meer, H.G., Schils, R.L.M., Van Dam, A.M., Van
Dijk, T.A., 2005. Protocol voor de actualisatie van bemestingsadviezen voor
stikstof (Protocol for the actualization of nitrogen fertilizer recommenda-
tions, in Dutch). Nota 332. Plant Research International, Wageningen. 26 pp.
Van Dijk, W., Conijn, J.G., Huijsmans, J.F.M., Van Middelkoop, J.C., Zwart, K.B.,
2004. Onderbouwing N-werkingscoëfficiënt organische mest (Justification
N efficacy coefficient organic fertilizer, in Dutch). Rapport 337. PPO, Lelystad.
63 pp.
Van Dijk, W., Van Dam, A.M., Van Middelkoop, J.C., De Ruijter, F.J., Zwart, K.B.,
2005. Onderbouwing N-werkingscoëfficiënt overige organische meststoffen
(Justification N efficacy coefficients other organic fertilizers, in Dutch).
Rapport 343. PPO, Lelystad. 50 pp.
Van Grinsven, H.J.M., Ward, M.H., Benjamin, N., De Kok, T.M., 2006. Does
the evidence about health risks associated with nitrate ingestion warrant an
increase of the nitrate standard for drinking water? Env. Health 5 (26), 1–6.
Vanotti, M.B., Bundy, L.G., 1994a. An alternative rationale for corn nitrogen
fertilizer recommendations. J. Prod. Agric. 7, 243–249.
Vanotti, M.B., Bundy, L.G., 1994b. Corn nitrogen recommendations based on
yield response data. J. Prod. Agric. 7, 249–256.
Verloop, J., Schröder, J.J., 2006. The position of dairy farming amidst N-sensitive
ecosystems. In: Schröder, J.J., Neeteson, J.J. (Eds.), N Management in
Agrosystems in Relation to the Water Framework Directive. Proceedings of
the 14th N Workshop. Plant Research International, Wageningen, pp. 43–46.
Report 116.