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Environment Agency Regulations on the application of Organic Matter to Arable Fields

Updated: Jan 27, 2022

The following is an email to my MP Sir John Hayes we will see what his response is.

Dear Sir John,

I wish to write to you concerning the Environment Agency’s amendment to rules regarding the application of organic matter to fields.

Please see the You tube posting by respected farmer Andrew Ward describing the problem.

The Environment Agency has just changed the Farming Rules for water. Our soils will suffer. - YouTube

Understanding the desire for clean water, especially in an environment where most water authorities have breached acceptable levels of pollution, with the much publicised Thames Water being the worst offender and our local Anglian Water having an amber EPA status in 2019 has to be balanced against what is practical, viable and manageable by farmers.

Whilst these rule changes appear welcome and reasonable on the face of it they do seem to be short sighted. Key to farming successfully in Eastern England is the ability to replace organic matter into the soil. Indeed government policy is driving farmers to a regenerative farming culture. This may appear reasonable and possible to a mixed farm in the Lincolnshire Wolds, but to the arable farmers in the Fens of your constituency and beyond this can be achieved by using processed organic matter usually from sewage farms in a responsible and sustainable way such as that described by Andrew Ward in his video. Such a policy does seem to work against regenerative farming , or worse still, only drive such farming down a single track avenue that does not look at different ways to achieve the circular model that regenerative farming has. Indeed, my understanding of the regulations are that even product from composting sites such as that at Postland near Crowland are affected and the waste composted there serves Peterborough and other areas.

Worse still, you and I still wish to enjoy the freedom to flush our toilets. What are the alternative uses for this waste if it is not used in Agriculture? We certainly will not get away with dumping into the North Sea. Many homes in rural Lincolnshire use septic tanks and the capacity for the waste from these to be processed is at best under strain with the ability to spread onto land (under licenced exemption) has taken up some of the slack.

Farmer’s do not wish to pollute water courses and mitigate this by using non -productive field margins or other measures such as phragmites to clean the water. The alternative to using non organic fertilizer are processed chemicals that are more expensive both in financial and environmental cost and do not filter so easily through the margins.

The Environment Agency has tried to mitigate the situation by issuing a regulatory position statement on 3rd August:

Spreading organic manure on agricultural land: RPS 252 - GOV.UK (

In my opinion this possibly just kicks the can down the road and does not fully help the farmer ensure he is both commercially and environmentally sustainable.

As ever the government has to ensure the balance between whether the farmer is a commercial business feeding the country or an instrument of government policy. I look forward to your response as to how farmers will be supported regarding this matter.

Kind Regards

Andrew Elsden

Since sending this I have a holding reply from Sir John Hayes as he has refered my concerns to the Minister concerned. A response is awaited. (1st Sept 2021)


I have received this reply:

Farmers should note the email to use if you have concerns of non-compliance and the review that is taking place. It will be interesting to see the outcome.

The outcome of the review is here (27/1/22) - my opinion is that its a fudge.

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