National Pig Association THE VOICE OF THE UK PIG INDUSTRY NPA is active on members' behalf in Brussels & Whitehall, and with processors, supermarkets & caterers - fighting for the growth and pros-perity of the UK pig industry.

And it calls on the Agency not to go over the top by introducing IPPC rules that will cause considerable expense and difficulty on pig farms, but deliver little environmental benefit.

If only eight percent of UK agricultural ammonia emissions come from pig housing and if the herd has shrunk 40 percent over the past few years, it is important to retain a sense of proportion when targeting time, effort and money at reducing emissions from pig housing, says the NPA.

For instance, why is it necessary to treat lightly contaminated roof water? It is difficult to do, would be very expensive on some pig units and would appear to be disproportionate to the environmental risk.

Likewise, NPA wonders whether the Agency's strictures on weaner flooring are entirely necessary. "How much ammonia do weaner pigs normally produce in a flatdeck system? The amount must be very small as these pigs produce relatively small amounts of excrement."

NPA policy manager Ann Petersson also takes the Agency to task for proposing stall systems as an example of good housing. This error will do nothing, she says, to enthuse British pig producers to have a positive approach to IPPC.

Although critical of some aspects of the latest version of the Environment Agency's standard rules for IPPC (Integrated Pollution Prevention and Control), NPA makes a point of congratulating the Agency for the "tremendous amount of work" it is putting into developing a useful guide for producers.

"It is perhaps inevitable that our response has included some of our reservations about the impact of the rules, but we remain positive with regard to working with the Agency on improving the environment with a practical approach that matches and does not conflict with our strategy to improve the health and welfare standards of the UK pig industry," says Ann Petersson.

What NPA says about the draft IPPC standard farming rules for pigs

• The Agency's stipulation that proposals for covering or replacing existing slurry stores and lagoons must be submitted within six months of getting an IPPC permit flies against the spirit of gradual and affordable introduction of improvements. Existing uncovered slurry stores should be allowed to reach the end of their expected life cycle.
  
  

• Requiring incorporation of slurry within six hours is totally impractical. Where a single tractor driver is employed, he would only be apply slurry in the morning and then he would have to stop and get on with incorporation before dark/home time. This precludes spreading on short winter days, especially if the ground remains frozen until later in the day.
  
  

• Spreading slurry on grass reduces N requirements. Banning splash-plate applications on grassland is therefore not in the interests of an holistic joined-up approach to environment sensitive farming.
  
  

• Some of the factors the Environment Agency will use to determine ammonia emission from units have increased by between 25 percent and 63 percent. NPA is concerned about these calculations and wants to discuss them further with the Agency.
  
  

• The requirement for a third diet if pigs are routinely taken over 100kg is arbitrary and impractical. The 100kg ceiling should be changed to 115kg.
  
  

• Fitting all hoses and lances and washing equipment with triggers is not practical. It is appropriate on pressure washers but not on hose pipes.
  
  

• Having to extract dust from feed preparation areas will be expensive and impractical. Each situation should be assessed on its merits and if action is required there should be a lead-in time.
  
  

• Because of the expense and practicalities involved, there should also be a lead-in period if bunded areas are required, or the re-siting of a feed store.
  
  

• Requiring producers to treat even lightly contaminated roof-water involves greater expense than the scale of the problem warrants. A risk assessment should be made and if such action is necessary it should be grant-aided.
  
  

• The Agency's advice that self-cleaning or plastic-coated slats in dunging areas are better than concrete slats may be incorrect. The Dutch have moved away from this advice on the evidence of very little environmental improvement for plastic/metal over concrete, and greatly increased cost.
  
  

• Care needs to be taken with slopes in scraped passages. Too steep a slope can lead to excessive urine run-off and a build up of dry solids on the scraped floor, leading to more emissions. Ponding is more likely at the foot of a slope than on a floor laid level. Anything other than a very slight slope is impractical where bedding is used, as the bedding will also tend to move down the slope and therefore not function adequately in the lying area.
  
  

• Where weaners are concerned, it is not usually a practicable proposition to have a fully slatted floor, with a concrete sloped floor under it. This only works where large volumes of liquid are used to flush the sloping floor, which is contrary to reducing water use.
  
  

• The illustrated housing systems used by the Agency are either illegal or impose pen layouts and building designs that have evolved in other countries with different building, climate and welfare production cultures. Compliance would not only endanger the pig's welfare, but also lead to a complete change in building and pen layouts, with the resulting exorbitant cost impact on the UK pig industry.

The full NPA response to the Environment Agency's IPPC consultation can be downloaded from the NPA Library, as can the IPPC's draft standard farming rules for pigs.

Source: Digby Scott - National Pig Association - 16th August 2004