Comments on the EU Commission open consultation on EU strategy for livestock

General comments

We would like to underline that a coming livestock strategy must in order for the strategy to be overall beneficial for the society, focus on the livestock sector’s environmental and climate footprint as much as on stated goals of increased productivity. If the environmental impact is downgraded, the societal costs of loss of production, restoration of damaged ecosystems etc will be large. Many research studies show that acting late, is more expensive than preventive actions.

Increased livestock numbers lead to more manure and increased risk of nitrate leaching to surrounding waters. This risk is enhanced if the livestock numbers increase in limited geographical areas. Therefore, a livestock strategy must to a full extent consider the relation between the agricultural system, the effectiveness of its total plant nutrient use and risk of losses to surrounding waters. Below we use nitrogen to illustrate the importance of considering the flows of plant nutrients when developing strategies for livestock. Thereby, we do not mean that nitrogen is the only important plant nutrient. Phosphorous is of course as important, both from a production perspective as well as for eutrophication.

We use the situation in the Baltic Sea to exemplify the importance of plant nutrient use efficiency to reduce the risk of eutrophication. The Baltic Sea is by no means the only polluted water in the EU, but the problem of eutrophication is severe in the Baltic Sea and studies of effects and actions can be informative for other parts of the EU.

Nitrogen reductions to reach set goals

To tackle the eutrophication of the Baltic Sea, total inputs of nitrogen, as well as of phosphorus, need to be significantly reduced. Achieving the goals of HELCOM’s Baltic Sea Action Plan, requires a further reduction of 11 percent of nitrogen to the Baltic Sea as a whole and a reduction of 24 percent to the Baltic Proper (as per the latest assessment for year 2021).

As a large part of the riverine nitrogen inputs is carried by run-off from agricultural land (68% of riverine N load is from diffuse anthropogenic load in 2017, or 49% of the total N load to the Baltic Sea – riverine + atmospheric + direct point sources2), actions to reduce nitrogen losses are essential, but knowledge of the actual effects of different measures at the Baltic Sea scale is largely lacking.

In contrast, several of the rivers draining to the Baltic Proper (Barta, Lielupe, Nemunas, Venta and Vistula), show upward trends of flow-normalised Total Nitrogen load since 2010 and similar trends were detected for some Swedish streams with a high share of agricultural land in the watershed (e g Råån and Skivarpsån),

Mineral fertilisers result in nitrogen surpluses

Nitrogen is often the main limiting nutrient in boreal and temperate terrestrial ecosystems due to the high propensity for losses in dissolved forms, mainly nitrate leaching, or gas forms, via volatilization or denitrification (1). Natural systems rely on nitrogen-fixing organisms to compensate for the losses and pre-industrial agricultural systems relied on farm animals and their manure to import nitrogen from surrounding grazing grounds to the fields. Modern agricultural systems instead rely heavily on mineral nitrogen fertilisers produced with the Haber-Bosch process, which inaugurated an era of unprecedented nitrogen surpluses (2). The production of mineral fertilisers did not only boost yields, but has also allowed the decoupling of crop production and animal husbandry. This specialisation of farms and regions entailed new patterns of surplus imbalances, principally rooted in disparities between manure production and demand. The new nitrogen surpluses on the fields, have also rapidly been synonymous with elevated river loads of nitrates and atmospheric emissions/deposition of nitrogen, both of which have contributed to eutrophication of the Baltic Sea.

Nitrogen in the ecosystem

Part of the reactive nitrogen applied to fields, both as inorganic fertilisers and as manure, is lost already at the time of application to the atmosphere (volatilisation) and partly re-deposited on arable land but also along the edges of areas neighbouring farms. Another major metabolic pathway for the excess nitrogen is denitrification, where non-reactive nitrogen gas is formed and released, primarily under anoxic conditions either in soil, groundwater, wetlands, or river and lake sediments.

Finally, part of the nitrogen surplus is accumulated within agricultural soils as organic matter, or in shallow oxic groundwaters as nitrates, forming legacies with the potential to leach directly or over time. The relative importance of all four processes – volatilisation, denitrification, legacy accumulation and leaching – depends on nitrogen application practices and on the local ecosystems’ capacity to assimilate and retain excess nitrogen, which might change as the ecosystem gets enriched in nitrogen and will depend on the local history of carbon and nitrogen loading. The terrestrial nitrogen cycle is mediated by the soil microbial communities, in turn strongly influenced by local climate, which will altogether determine the nitrogen turnover and how closely the net mineralisation rate matches crop demand during the season, and how much nitrogen is mineralised after harvest that is then prone to leaching.

Introduction of plant nutrients into the agricultural system

Nitrogen and phosphorus are essential nutrients in crop production. Fertiliser boosts crop growth and replenishes the plant nutrients removed during harvest. In an efficient agricultural system, nutrients circulate within the system and losses are minimal. Unfortunately, such systems are not the most common. Present dominating agriculture systems are dependent on the supply of plant nutrients in the form of animal feed and mineral fertilisers, and subject to nutrient losses that harm the aquatic environment. This is far from a sustainable system.

Purchased mineral fertilisers and feed account for the majority of the new plant nutrients entering the Baltic Sea catchment area. Plant nutrient flows from livestock production are particularly high. Around 70% of what is grown is used as animal feed, whilst 30% is consumed directly by humans. The region’s approximately 23 million pigs, 16 million cows and 244 million chickens produce 2 million tonnes of nitrogen and 0.4 million tonnes of phosphorus in manure each year – in other words, roughly three times as much as the nutrients from domestic sewage. Although the majority of this manure is used in agriculture, it could be utilised more efficiently.

The extent to which applied nitrogen is utilised in the agricultural system is expressed as nitrogen use efficiency. In today’s dominant production systems, nitrogen is supplied through mineral fertilisers, imported feed and nitrogen-fixing crops. Efficiency is low; on average in the Baltic Sea region, median 58 % of the nitrogen and 80 % of the phosphorus in farmyard manure and mineral fertilisers is converted into harvested crops.

The structure of agriculture

The production of mineral fertilisers has not only increased crop yields, but has also made it possible to separate crop production from livestock farming. This specialisation of farms and regions has led to an accumulation of farmyard manure in certain regions and a dependence on mineral fertilisers in others. Too many animals in relation to the amount of arable land, increases the risk of leaching during manure management. Nitrogen surpluses in the fields risk increasing and have resulted in elevated river loads of nitrates and atmospheric emissions/deposition of nitrogen, both of which have contributed to the eutrophication of the Baltic Sea. A livestock strategy must consider these problems and suggest ways of solving them.

In order to improve nutrient use efficiency by crops and reduce the risk of leaching, the balance between crop production and livestock farming should be improved at local and regional level. This could be achieved in various ways,

• Supporting mixed farming systems that balance crop production and animal husbandry, such as organic farming.
• Transporting manure from areas with high livestock density, where there are more nutrients than the crops require, to areas focused on crop production.
• Relocating livestock from areas with high livestock density and relatively little crop production to areas that focus on crop production and have few or no animals.
• Producing and consuming fewer animal products.

In summary, a livestock strategy should consider the following:

• Encourage agroecological and other circular economy-oriented farming practices, particularly a good balance between crop production and livestock farming at the local/regional level, with a view to improving the efficiency of manure utilisation.
• Focus the actions against leaching to areas with a high risk of nitrogen leaching.
• Remedy nitrogen inefficiencies in manure collection, storage and application (large drop in net atmospheric emissions) by for instance legal requirements but also support for on farm improvements.
• Implement measures against leaching (catch crops etc) and fostering nutrient retention between the root zone and the river outlets.
• Improve the quantification and timing of fertilisation with crop demands (compare harvest to mineral + manure fertilisation),
• Harmonise, facilitate and ensure crop nutrient balances at field level. Support soil mapping.
• Evaluate the long-term impact of implemented policy measures so that the effect on nitrogen leaching from soil deposits does not distort the results.