A measure that is frequently used by agricultural companies with pasture land in the context of the Programmatic Approach to Nitrogen is “grazing”. It can be found in the following measures: R1.1, R-2.1a, R-3.1c, R-6.1a, R-7.1a, R-2.1b, R-3.1d, R-6.1b and R-7.1b. The report “PASsing grazing” from Wageningen University discussed the preconditions. These are not found in the PAS fact sheet. In a ruling from the Court of North Netherlands, this PAS measure came under fire.
The Flemish PAS measure “grazing” is discussed in the following PAS fact sheets:
- R1.1 – Group grazing
- R2.1a – Grazing in combination with vacancy in cattle barns with slatted floors
- R2.1b – Grazing in combination with vacancy in bedded cattle barns
- Combinations of PAS measures
The Netherlands also has the PAS measure “grazing at least 720 hours in a calendar year (PAS 2015.08-02)” for the animal category of dairy and calf cows older than 2 years. This is included in Ammonia and Livestock Regulation – Annex 2. Grazing for 720 hours translates to a 5% emission reduction for floor and cellar.
The difference between the Flemish and Dutch measure is that grazing in Flanders must take place in connected periods of 24 hours. In the Netherlands, it concerns blocks of 3 hours per day.
Wageningen University published the report in 2016: “PASsing grazing”. The following relevant conclusions were formulated:
- The number of grazing hours has a clear effect on ammonia emissions throughout the manure chain. The number of hours of grazing must be balanced with the dry matter intake of fresh grass and thus with the available grazing space on the farm. More grazing requires a lower stocking density per hectare, which means that more grazable area is needed on more intensive farms to achieve ammonia reduction.
- The effects of grazing in the barn are based on calculations for a traditional housing system with slatted floors. For low-emission floors (which are mainly solid floors), the effect of grazing hours on ammonia emissions is 30-40% greater than with slatted floors.
- In farms with an automatic milking system (AMS), the reduction per grazing hour will be lower than in conventional milking systems because continuous cow traffic creates a larger (temporarily) contaminated area, thus increasing the chance of emissions.
The operator must demonstrate that they have sufficient grazable land. The PAS sheet does not indicate how large this area should be in relation to the number of days grazing will occur.
Furthermore, the operator must also take cow traffic into account when applying for an environmental permit. This aspect is also missing from the PAS sheet.
The Dutch ruling of 11 March 2021 by the Court of North Netherlands (ECLI:NL:RBNNE:2021:810) raises important considerations regarding emission reductions as a result of grazing. In this ruling, the judge expressed the following concerns:
a/ There is a lack of justification for the effect of the absence of livestock in the stable on the emissions from the stable.
b/ There is a lack of justification for the emissions caused by the livestock in the pasture.
c/ Especially with the application of stable systems that significantly reduce ammonia emissions, it is questionable whether the emissions from the livestock in the pasture do not exceed the emission factor of the stable.
Since the Flemish PAS sheets on grazing were last updated in March 2018, they do not take the above considerations into account. There is also no more detailed justification available. Consequently, there is no certainty that the proposed PAS measure will achieve the promised yield. This PAS measure cannot currently be applied.