MOF, Alm.del - 2022-23 (2. samling) - Bilag 466: Årlig rapport til EU-Kommissionen om den danske undtagelse fra nitratdirektivet

Miljø- og Fødevareudvalget 2022-23 (2. samling)
MOF Alm.del Bilag 466
Offentligt

Derogation Report 2022

Danish Report in

accordance with the

Commission Decisions

2005/294/EC, 2008/664/EC,

2012/659/EU, 2017/847/EU,

2018/1928/EU and

2020/1074/EU

April 2023

MOF, Alm.del - 2022-23 (2. samling) - Bilag 466: Årlig rapport til EU-Kommissionen om den danske undtagelse fra nitratdirektivet

Ministry of Environment of Denmark

Department

Slotsholmsgade 12

DK-1216 Copenhagen K

Ministry of Environment of Denmark / Nitrates Directive / Derogation Report 2022

MOF, Alm.del - 2022-23 (2. samling) - Bilag 466: Årlig rapport til EU-Kommissionen om den danske undtagelse fra nitratdirektivet

Contents

2.1

2.2

2.3

2.4

2.5

3.1

3.2

3.3

3.4

3.5

3.5.1

3.5.2

3.5.3

3.6

3.6.1

4.1

4.2

4.3

4.4

4.5

5.1

5.2

5.3

5.4

6.1

6.2

6.3

7.1

8.1

Introduction

Maps of cattle holdings, arable land and livestock in kg N in 2020/2021

Map of derogation holdings 2019/2020

Map of arable land 2020/2021

Map of livestock in kg N in 2020/2021

Use of the derogation

Trends in livestock

Controls at farm level

Control of compliance with the Danish derogation

Summary of inspection results 2022

Inspection of compliance within the derogation year

Results

General inspection of the harmony rules

Harmony rules

Soil analysis

Results of soil analyses from derogation farms

Control of fertilizer accounts

Results

Agricultural practices and water quality

Development in agricultural practices at the national level from 2005 to 2021

Development in modelled nitrate leaching in the Agricultural Catchment

Monitoring Programme 1990-2020

Measurements of nitrate in water leaving the root zone

The nitrogen flow to surface water in agricultural catchments

References

Reinforced monitoring in areas characterized by sandy soils

Introduction

Method

Characterization of monitoring stations and data analysis

Results and Discussion

Indicator and monitoring system for application of phosphorus in

Denmark

Introduction

Results from the P monitoring system

Results from P indicator system

Targeted catch crops scheme and targeted nitrogen regulation

Results from 2017 to 2021

Conclusions

Cattle holdings and controls on farm level

Ministry of Environment of Denmark / Nitrates Directive / Derogation Report 2022

MOF, Alm.del - 2022-23 (2. samling) - Bilag 466: Årlig rapport til EU-Kommissionen om den danske undtagelse fra nitratdirektivet

8.2

8.3

8.4

8.5

Agricultural practices and water quality

Targeted catch crops and targeted nitrogen regulation

The reinforced monitoring

The phosphorus indicator and monitoring system

Ministry of Environment of Denmark / Nitrates Directive / Derogation Report 2022

MOF, Alm.del - 2022-23 (2. samling) - Bilag 466: Årlig rapport til EU-Kommissionen om den danske undtagelse fra nitratdirektivet

1. Introduction

With Commission Decisions 2005/294/EC, 2008/664/EC, 2012/659/EU, 2017/847/EU,

2018/1928/EU, and 2020/1074/EU Danish cattle holdings are allowed to derogate from the

general rules in the Nitrates Directive (91/676/EEC).

The relevant decisions for the data reported in this report are 2018/1928/EU and

2020/1074/EU. According to these decisions, cattle holdings could apply for authorizations to

apply livestock manure corresponding to up to 230 kg N per hectare per year if more than 80

per cent of the area available for manure application was cultivated with beets, grass or grass

catch crops. Furthermore, derogation holdings have to comply with several other conditions

laid down in the decision.

The aim of this report is to present maps showing the percentage of farms and percentage of

agricultural land encompassed by the derogation in each Danish municipality for the planning

period 2020/2021.

According to the decisions 2018/1928/EU and 2020/1074/EU, the Danish authorities shall sub-

mit the following information to the Commission for the derogation period 2020/2021:



According to Article 10 (1) and 12 (a): maps, showing the percentage of cattle farms, per-

centage of livestock and percentage of agricultural land covered by the derogation for each

municipality of Denmark.



According to Article 12 (g), an evaluation of the implementation of the derogation conditions,

on the basis of controls at farm level and information on non-compliant farms, based on the

results of the administrative and field inspections.



According to Article 12 (b, c, e), the results on ground and surface water monitoring as re-

gards nitrate and phosphate, including information on water quality trends as well as the im-

pact of derogation on water quality. Further results of model-based calculations from farms

benefiting from an individual derogation.



According to Article 12 (d and f), the results of the surveys on local land use, crop rotations

and agricultural practices including tables showing the percentage of agricultural land under

derogation covered by clover or alfalfa in grassland and by barley/pea, undersown with

grass.



According to article 12 (h), trends in livestock numbers and manure production for each live-

stock category in Denmark and in derogation farms.

The derogation decision 2018/1928/EU and 2020/1074/EU requires according to Articles 10

(2) and 12 (b), reporting of water quality data from reinforced monitoring on sandy soils and in

an area, where at least 3% of all derogation farms are located. The monitoring data is updated

with data from 2021 in this report.

Various Danish authorities and institutions have contributed to this report, edited by the Minis-

try of Environment of Denmark. The respective authors, and hence responsible institutions for

the different chapters, can be found under the heading to the respective chapters.

Ministry of Environment of Denmark / Nitrates Directive / Derogation Report 2022

MOF, Alm.del - 2022-23 (2. samling) - Bilag 466: Årlig rapport til EU-Kommissionen om den danske undtagelse fra nitratdirektivet

2. Maps of cattle holdings,

arable land and livestock in

kg N in 2020/2021

Lars Paulsen & Lene Kragh Møller, the Danish Agricultural Agency, Ministry of

Food, Agriculture and Fisheries of Denmark, March 2023

For the planning period 2020/2021, the Danish Agricultural Agency received 31,300 fertilizer

accounts containing key figures on the use of nitrogen (commercial fertilizer and organic ma-

nure). The accounts were registered and reviewed. The maps (Figure

2.1 – Figure 2.3)

are

based on the number of agricultural holdings, kg N spread per hectare per year and arable

land used by derogation farms in 2020/2021. The fertilizer accounting year runs from 1st of

August to 31st of July. Accounts for 2020/2021 were to be submitted to the Danish Agricultural

Agency no later than 31st of March 2022.

In the fertilizer account, the farmer states whether the derogation was used.

This means that the individual farmer needs to apply for the use of the derogation when the

farmer submits the fertilizer quota and catch crops plan (at the latest 21st of April each year).

The information about the application is automatically transferred to the fertilizer accounting

system. The maps of cattle holdings, arable land and kg N spread from organic fertilisers per

hectare per year are based on the data reported by the farmers. In reports before 2019, a map

with livestock units per year was presented. This has from 2019 been replaced by a map

showing kg N spread from organic fertilisers, including livestock manure per hectare and year

at municipal level. In Danish regulation, it has generally from 2019 been changed to limit live-

stock density at farm level via a maximum allowable N application from organic fertilisers (in-

stead of number of livestock). However, since one livestock unit corresponds to 100 kg N (ex

storage), the data is directly convertible and hence does not present any change in the limita-

tion per area.

2.1

Map of derogation holdings 2020/2021

The map (Figure

2.1)

shows derogation holdings in percentage of the total number of agricul-

tural holdings registered in each respective Danish municipality.

In 2020/2021, 945

derogation holdings were encompassed by the derogation. This corre-

sponds to 3 % of all registered fertilizer accounts. The applied amount of manure on these

farms ranged from 170 to 230 kg N per hectare per year. If the production of manure on a der-

ogation farm corresponds to more than 230 kg N per hectare, the farmer is obliged to deliver

the excess manure to one or more contractual partner-farmers.

Previously, the number of derogation holdings was equal to holdings that indicated in their reported ferti-

lizer accounts that they had submitted an application and that they had used the derogation. From the

planning period 2020/2021, derogation holdings are equal to holdings that have submitted an application

and that have been granted authorization to use the cattle derogation, just as they have indicated in their

reported fertilizer account that they have submitted an application and that they have used the cattle der-

ogation.

Ministry of Environment of Denmark / Nitrates Directive / Derogation Report 2022

MOF, Alm.del - 2022-23 (2. samling) - Bilag 466: Årlig rapport til EU-Kommissionen om den danske undtagelse fra nitratdirektivet

2.2

Map of arable land 2020/2021

The map (Figure

2.2)

shows the share of arable land on derogation holdings in relation to the

total agricultural area in each Danish municipality.

In 2020/2021, the arable land on cattle holdings encompassed by the derogation was 163,732

hectare at national scale. This corresponded to 6.8 % of the registered area used for agricul-

ture in Denmark.

2.3

Map of livestock in kg N in 2020/2021

The map (Figure 2.3) shows the share of kg N distributed from cattle holdings encompassed

by the derogation holdings in relation to the total kg N from organic fertilisers in each Danish

municipality.

In 2020/2021, the kg N from organic fertilisers spread from cattle holdings encompassed by

the derogation was 32,9 million kg N in total. This corresponded to 14.5 % of all kg N in or-

ganic fertilisers spread on the agricultural area in Denmark.

2.4

Use of the derogation

Over the first three planning periods in which the derogation was used, i.e. 2002/2003,

2003/2004 and 2004/2005, an increase in the use of the derogation was registered both re-

garding the number of farms, the number of hectares and the number of livestock units (Table

2.1). This tendency was broken in 2005/2006, where a decrease was observed for all three

measured parameters and the decreasing trend continued until the period 2008/2009. Be-

tween 2009/2010 and 2015/2016, an overall increase in the agricultural area using the deroga-

tion was observed, whereas the number of farms remained at a more constant level. The gen-

eral trend of Danish farms becoming bigger is reflected in these numbers and from 2016/2017

there has been a decrease in the number of farms and the number of hectares encompassed

by the derogation. From 2017/2018, the number of livestock unit was replaced by produced kg

N per year in the Danish legislation.

Ministry of Environment of Denmark / Nitrates Directive / Derogation Report 2022

MOF, Alm.del - 2022-23 (2. samling) - Bilag 466: Årlig rapport til EU-Kommissionen om den danske undtagelse fra nitratdirektivet

TABLE 2.1 Development in use of the derogation for number of farms, agricultural area

and kg N in organic fertilisers per year (livestock units (LU) until 2016/2017) from

2002/2003 until 2020/2021 (One LU=100 kg N (ex storage)).

Year

Number

of dero-

gation

farms

1,845

1,927

2,331

1,779

1,610

1,296

1,115

1,507

1,607

1,652

1,481

1,482

1,500

1,466

1,378

of total

farms

(%)

4.0

5.0

3.4

3.2

2.8

2.4

3.3

3.9

4.0

3.7

3.8

4.0

4.2

3.9

Area of

deroga-

tion (hec-

tare)

123,068

128,523

134,780

115,336

111,845

92,282

90,647

134,698

164,353

175,783

162,176

189,495

205,165

210,061

205,874

of total

Area

(%)

5.0

4.2

4.0

3.9

3.6

6.1

7.4

7.1

6.7

7.7

8.2

8.6

8.4

Number

LUs

213,617

225,586

277,330

220,839

211,765

186,313

176,588

276,765

341,781

365,887

334,508

397,014

425,102

443,134

439,114

Mill. kg

N spread

(org.

fert.)

2017/2018

2018/2019

2019/2020

2020/2021

1,312

1,284

1,197

945

3.9

3.7

3.0

198,195

195,804

182,950

163,732

8.2

8.1

7.6

6.8

39.6

39.1

36.8

32.9

of total

LUs

(%)

10.6

12.9

10.3

9.5

8.3

8.2

11.9

14.1

15.5

14.5

17.1

18.6

19.4

19.3

of total

kg N

spread

(%)

18.1

17.8

16.8

14.5

2002/2003

2003/2004

2004/2005

2005/2006

2006/2007

2007/2008

2008/2009

2009/2010

2010/2011

2011/2012

2012/2013

2013/2014

2014/2015

2015/2016

2016/2017

The livestock density on derogation farms has remained at an approximately constant level,

compared to the periods 2009/2010-2016/2017 and the average number of livestock units per

farm has increased over the same period. From 2017/2018, the average livestock size and the

average livestock density were measured in kg N spread (from organic fertilisers) per holding

and in kg N spread (from organic fertilisers) per hectare per year.

By comparison, a total number of 9,503 Danish agricultural holdings had cattle as livestock in

2020/2021. These holdings spread total 105.8 million kg N from organic fertilisers and covered

an agricultural area of 807,936 hectare. This gave an average of 11,132 kg N spread from or-

ganic fertilisers per cattle holding and an average livestock density of 131 kg N spread from

organic fertilisers per hectare on all Danish cattle farms. Consequently, approximately 9.9 % of

all cattle farms were derogation farms in 2020/2021, and the derogation (cattle) farms spread

31.1 % of all cattle-kg N in Denmark, covering 20.3 % of the total Danish cattle farm area.

Ministry of Environment of Denmark / Nitrates Directive / Derogation Report 2022

MOF, Alm.del - 2022-23 (2. samling) - Bilag 466: Årlig rapport til EU-Kommissionen om den danske undtagelse fra nitratdirektivet

TABLE 2.2 Average number of spread livestock units

(LU) per holding and per hectare

under the derogation until 2016/2017. From 2017/2018 the number of livestock is ex-

pressed by kg N from organic fertilisers (One LU = 100 kg N (ex storage)).

Year

2002/2003

2003/2004

2004/2005

2005/2006

2006/2007

2007/2008

2008/2009

2009/2010

2010/2011

2011/2012

2012/2013

2013/2014

2014/2015

2015/2016

2016/2017

Average livestock size

(LU/holding)

115.78

117.07

118.97

124.14

131.53

143.76

158.37

183.65

212.68

221.48

225.86

267.89

283.40

302.27

318.66

Average livestock size

(kg N spread pr. holding)

Average livestock density

(LU/ha)

1.74

1.76

2.06

1.91

1.89

2.02

1.95

2.05

2.08

2.06

2.10

2.07

2.11

2.13

Average livestock density

(kg N spread pr. ha)

199

200

201

2017/2018

2018/2019

2019/2020

2020/2021

30,171

30,475

30,769

34,772

“Spread LU” is the term used to describe the amount of livestock manure, which is being applied to agri-

cultural land within the farm, as this amount can be different from the amount of livestock manure pro-

duced at farm level due to import or export of livestock manure from/to other farms. One LU corresponds

to 100 kg manure-N (ex storage) in the Danish system.

From 2017/2018, the number of livestock units (LU) is replaced by produced kg N from organic fertilisers

per year in the Danish legislation (One LU = 100 kg N).

Ministry of Environment of Denmark / Nitrates Directive / Derogation Report 2022

MOF, Alm.del - 2022-23 (2. samling) - Bilag 466: Årlig rapport til EU-Kommissionen om den danske undtagelse fra nitratdirektivet

FIGURE 2.1 Derogation holdings in percent of total number of agricultural holdings in Denmark in

2020/2021. The location of each holding is determined by ad- dress of the owner.

Ministry of Environment of Denmark / Nitrates Directive / Derogation Report 2022

MOF, Alm.del - 2022-23 (2. samling) - Bilag 466: Årlig rapport til EU-Kommissionen om den danske undtagelse fra nitratdirektivet

FIGURE 2.2 Agricultural land encompassed by the derogation in 2020/2021 in percent of

the total agricultural area in Denmark. The location of each holding is determined by ad-

dress of the owner.

Ministry of Environment of Denmark / Nitrates Directive / Derogation Report 2022

MOF, Alm.del - 2022-23 (2. samling) - Bilag 466: Årlig rapport til EU-Kommissionen om den danske undtagelse fra nitratdirektivet

FIGURE 2.3 Kg N from organic fertilisers per hectare per year spread on derogation farms in percent of

total kg N from organic fertilisers in 2020/2021 in Denmark. The location of each holding is determined by

address of the owner.

Ministry of Environment of Denmark / Nitrates Directive / Derogation Report 2022

MOF, Alm.del - 2022-23 (2. samling) - Bilag 466: Årlig rapport til EU-Kommissionen om den danske undtagelse fra nitratdirektivet

The maps (Figure

2.1 – Figure 2.3)

illustrate that derogation cattle holdings are concentrated

in the western parts of Jutland. A few holdings are located on Zealand and even fewer on Fu-

nen and the island of Bornholm.

2.5

Trends in livestock

According to decision 2018/1928/EU, and 2020/1074/EU the Danish authorities shall submit

information about trends in livestock numbers and manure production for each livestock cate-

gory in Denmark and in derogation farms according to Article 12 (h). All numbers have been

brought to a round number in order to have a clearer picture.

The trends in livestock numbers (i.e. number of herds

) and manure production in kg N (until

2016/2017 in number of LUs

) for each livestock category and in derogation farms can be de-

rived from the data shown in

Table 2.3.

Over the planning periods from 2014/2015 to

2020/2021, the number of herds have decreased for each livestock category. The total number

of Danish herds of livestock has decreased by ca. 22 % in between the planning periods of

2014/2015 and 2020/2021. From 2017/2018 the LUs is replaced by kg N.

The total number of herds does not coincide with total number of holdings in Denmark. A herd includes

only one type of livestock and some holdings keep more than one herd, e.g. cattle and pigs.

One livestock unit is defined as 100 kg nitrogen in the livestock manure ex storage.

Ministry of Environment of Denmark / Nitrates Directive / Derogation Report 2022

MOF, Alm.del - 2022-23 (2. samling) - Bilag 466: Årlig rapport til EU-Kommissionen om den danske undtagelse fra nitratdirektivet

TABLE 2.3 Number of Danish herds of livestock and production of manure in live- stock

units (LUs) or in kg N per livestock category, rounded to the closest unit of 100 (1

LU=100 kg N (ex storage)).

Livestock

category

Year

2014/2015

No. herds

No. LUs

2015/2016

No. herds

No. LUs

2016/2017

No. herds

No. LUs

2017/2018

No. herds

Kg N, mill.

2018/2019

No. herds

Kg N, mill.

2019/2020

No. herds

Kg N, mill.

2020/2021

No. herds

Kg N, mill.

9,500

117.1

900

44.1

3,000

85.1

1,700

11.8

1,900

1.0

5,000

2.1

21,100

217.1

9,800

117.2

1,200

36.8

3,000

80.2

1,700

16.7

1,900

1.0

5,100

2.1

21,500

217.2

10,200

116.4

1,300

39.1

3,300

78.5

1,900

18.6

2,000

1.0

5,300

2.2

22,700

216.7

10,800

115.2

1,300

39.6

3,400

80.0

2,000

20.2

2,000

1.0

5,500

2.2

23,700

218.6

11,500

1,186,80

1,400

439,100

3,600

883,700

2,100

183,000

2,200

10,600

5,600

18,100

25,000

2,282,200

11,800

1,193,40

1,500

443,100

3,900

881,300

2,000

178,000

2,300

10,500

5,800

18,800

25,800

2,282,000

12,300

1,164,70

1,500

425,100

4,100

905,300

2,000

190,500

2,400

12,200

6,100

19,100

26,900

2,291,800

Cattle

total

Derogation

cattle

Pigs

Fur and

poultry

Sheep

and goats

Others

Total

The amount of derogation cattle herds and LUs/kg N (organic fertiliser) are a part of “cattle total” and,

thus, is not included in the summarization of herds and LUs/kg N (organic fertiliser) in “total”.

Ministry of Environment of Denmark / Nitrates Directive / Derogation Report 2022

MOF, Alm.del - 2022-23 (2. samling) - Bilag 466: Årlig rapport til EU-Kommissionen om den danske undtagelse fra nitratdirektivet

3. Controls at farm level

Lars Paulsen & Lene Kragh Møller, the Danish Agricultural Agency, Ministry of

Food, Agriculture and Fisheries of Denmark, December 2022

3.1

Control of compliance with the Danish derogation

According to Article 12 of Commission Decisions 2018/1928/EU, and 2020/1074/EU Denmark

must submit a concise report on the evaluation practice, i.e. control at farm level, to the Com-

mission every year.

The control of compliance with the Commission Decisions 2018/1928/EU and 2020/1074/EU

follows two strategies:

Inspection of compliance with farm management, which is carried out during the year the

farmer uses the derogation. This includes field inspections.

Control of the amount of livestock manure applied per hectare per year (control of compli-

ance with the harmony rules), which is carried out after the derogation year has ended.

This control is carried out as an administrative inspection of submitted fertilizer accounts.

3.2

Summary of inspection results 2022

Compliance with management conditions:



Inspection at the farm in January and February 2022: 70 inspections were carried out. 67

holdings complied with the derogation management conditions, and three holdings got a re-

mark in 2022 (Table

3.1).

Compliance with the harmony rules for holdings using the derogation:



Administrative inspections of the submitted fertilizer accounts for 76 inspected farms in Jan-

uary and February 2021: 65 holdings complied with the specific rules for derogation hold-

ings. Three holdings had minor violations. Eight holdings are still under investigation

(Table

3.2).



Administrative control of the submitted fertilizer accounts: 36 inspections were carried out,

out of which 21 holdings complied with the rules. Four holdings had minor violations and 11

holdings are still under investigation

(Table 3.5).

3.3

Inspection of compliance within the derogation year

The farmers are required to fulfil certain conditions in order to use the derogation. The Danish

Agricultural Agency has inspected the fulfilment of the Danish derogation conditions on dero-

gation holdings from 2002/2003 through 2021/2022. Some conditions have to be checked on

site at the farm (physical inspection), for example certain ploughing conditions, which are

checked in January and February.

During the inspection at the farm, the inspector asks the following questions:

1. Does the farm have a yearly production of nitrogen in livestock manure above 300 kg of

which at least 2/3 are from cattle (2/3 of the livestock units),

2. i.e. is the farm mainly a cattle holding?

Ministry of Environment of Denmark / Nitrates Directive / Derogation Report 2022

MOF, Alm.del - 2022-23 (2. samling) - Bilag 466: Årlig rapport til EU-Kommissionen om den danske undtagelse fra nitratdirektivet

Has a plan been made for crops grown in the actual planning period?

Has the manager stated that the farm intends to comply with the 230 kg nitrogen per hec-

tare per year derogation in the crop rotation plan?

Does the plan contain leguminous crops, e.g. red and white clover?

Has a declaration about (omitted) manure application been made?

Does the plan include ploughing grassland or grass catch crops in the planning period?

If the answer is “yes” in question 6: Have the fields already been ploughed by the time of

inspection?

Does 80 % or more of the acreage available for manure application cultivated with crops

with high nitrogen uptake and long growing season?

The inspection is based on 1) an interview with the farmer, 2) an inspection of the farms crop

rotation plan for the previous and coming growing season and 3) a visual inspection of fields

designated for ploughing.

At the inspection, the inspector draws up a report, which includes answers to the abovemen-

tioned questions. At the end of the inspection, the farmer is informed whether the holding is al-

lowed to apply manure corresponding to 230 kg N/ha/year, i.e. whether the derogation can be

used or not. If the holding is not complying with the derogation conditions, the holding is only

allowed to apply livestock manure up to 170 kg N/ha/year. In this case, the farmer has to find

other legal means of disposing the surplus manure produced on the farm.

If a farmer informs the inspector that the derogation will not be used, the field inspection is not

carried out. An administrative control of the farm is carried out instead by the time the fertilizer

account has been submitted. This control is carried out to secure that no more than 170 kg

N/ha/year was applied.

The inspection report is submitted by the inspector to the headquarters of the Danish Agricul-

tural Agency for possible further administrative inspection. The Danish Agricultural Agency

verifies the data. Additional remarks made by the inspector, if any, are examined. This in-

cludes a process where the parties of interest are allowed to make statements on the case if

an infringement is discovered.

3.4

Results

From 1st of January until 1st of March 2022, the Danish Agricultural Agency carried out 70 in-

spections on derogation holdings to inspect whether the conditions requirements were met.

The control refers to the fertilizer accounts for the planning year 2020/2021 where some condi-

tions are controlled in the next planning period 2021/2022.

Table 3.1

shows the results of the

inspection for the last 19 years. Only very few remarks have been given and in general a good

compliance with the rules has been noted.

Ministry of Environment of Denmark / Nitrates Directive / Derogation Report 2022

MOF, Alm.del - 2022-23 (2. samling) - Bilag 466: Årlig rapport til EU-Kommissionen om den danske undtagelse fra nitratdirektivet

TABLE 3.1 Results of on-site inspection of compliance within the derogation years dur-

ing winter.

Control

planning-

period

2003/2004

2004/2005

2005/2006

2006/2007

2007/2008

2008/2009

2009/2010

2010/2011

2011/2012

2012/2013

2013/2014

2014/2015

2015/2016

2016/2017

2017/2018

2018/2019

2019/2020

2020/2021

2021/2022

Total number of

inspections

Inspections without

remarks

Inspections with

remarks

3.5

3.5.1

General inspection of the harmony rules

Harmony rules

Control of the harmony rules (i.e. the amount of livestock manure applied per hectare per year)

on derogation farms is carried out after the derogation year has ended.

This control is carried out within the general inspection of the Danish harmony rules. The in-

spector visits the farm to inspect the production based on various production and fertilizer ac-

count documents. Violation of the harmony rules is sanctioned.

For minor violations, the farmer receives a notification and recommendation or a warning. For

more severe violations, the farmer is reports to the police and receives a fine. Farmers that re-

ceive a warning or a fine are reported for not complying with the cross compliance criteria.

Administrative inspection included submitted fertilizer accounts concerning the year

2019/2020, for 76 inspected farms in January and February 2021 for violation of the harmony

rules. The holdings were automatically selected for inspection, based on a previously agreed

set of “risk criteria”. The Danish Agricultural Agency has therefore no direct influence on how

The respective controls during the planning period 2021/2022, which have been performed in January

and February 2022 are related to the fact that the farmer has made use of the derogation in the previous

planning period, i.e. 2020/2021. This applies also to all previous control years.

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many derogation holdings ware selected for “harmony rules inspection”. Out of these adminis-

trative inspections, 65 holdings (85.5 %) complied with the specific rules for derogation hold-

ings. Eight holdings (10.5 %) are still under investigation and three holdings had minor viola-

tions (Table

3.2).

TABLE 3.2 Results of administrative inspection of compliance with the harmony rules

for farms using the derogation.

Control

Planning

period

Total

number of

Inspections

Inspec-

tions

without

remarks

Inspec-

tions with

minor

violations

Inspec-

tions with

fines

Inspections

still under

investiga-

tion

2006/2007

2007/2008

2008/2009

2009/2010

2010/2011

2011/2012

2012/2013

2013/2014

2014/2015

2015/2016

2016/2017

2017/2018

2018/2019

2019/2020

3.5.2

Soil analysis

If the derogation is used for four consecutive years, the farmer must provide a soil analysis

where phosphorous and nitrogen levels in the soil are examined. One sample per five hec-

tares must be provided.

In Denmark, the soil analysis for phosphorus (the ”P-tal”) indicates the soil’s phosphorus sta-

tus and hence approximates the level of phosphorus in the soil available for uptake by the

crop. Internationally, the soil analysis is referred to as “Olsen-P”. Olsen-P is often expressed in

mg P per kg soil. In Denmark, however, the “P-tal” is expressed in mg P per 100 g soil. Olsen-

P in Danish agricultural soil is in average around 40 mg P per kg soil (P-tal = 4.0). Only a part

of the inorganic phosphorus available for the crop is extracted from the soil sample, when the

phosphorus status is determined. This extractable part accounts for approximately 5 to 10 per

cent of the total phosphorous content of the soil. A P-tal between 2 and 4 is generally ac-

cepted as a sufficient level for most crops and 2-2.5 is the lower critical soil P level. A P-tal

above 6 is considered very high.

I.e. inspections still under investigation at time of reporting. Numbers of inspections still under investiga-

tion prior to 2017/2018 are not updated. Thus, these inspections may have been finalized.

Administrative inspections of the submitted fertilizer accounts for 76 inspected farms in January and Feb-

ruary 2021 (Table 3)

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The N-total analysis is used to determine the amount of extra fertilizer to be added to meet the

nutrient demand of the crop. The total soil N content (N-total) describes the N pool in the soil,

which potentially is available to the crops as a result of slow mineralization. In Denmark, de-

pending on the C/N ratio in the soil, the standard N-total is 0.13 %. The farmer cannot expect

any N-supply from mineralization, if the level of

0.13 % N-total is found. If the value is above 0.22 %, the level is high and expected mineraliza-

tion is (accounted for with) 40 kg N in maize and cereals per hectare.

The N-total standard for grass fields is 0.18-0.22 %, and if the value is above 0.22 %, the ex-

pected mineralization is (accounted for with) 10 kg N per hectare.

3.5.3

Results of soil analyses from derogation farms

The sampling and analyses must be carried out at least once every four years (prior to

2012/2013, the requirement was at least once every three years). The results of the develop-

ment of compliance with the requirement of soil analysis are shown in

Table 3.3.

The inspection of derogation farms for 2019/2020 showed that 42 holdings out of the 76

(53.9%) inspected holdings had to provide soil analysis. One holding got a remark regarding

soil analysis.

The results of the soil analyses for phosphorus and nitrogen on derogation farms are shown in

Table 3.4.

TABLE 3.3 : Results of inspection of compliance with the soil analysis requirement.

Control plan-

ning period

Number of inspec-

tions for soil analy-

sis

Inspections without

remarks

Inspections with re-

marks/still under in-

vestigation

2004/2005

2005/2006

2006/2007

2007/2008

2008/2009

2009/2010

2010/2011

2011/2012

2012/2013

2013/2014

2014/2015

2015/2016

2016/2017

2017/2018

2018/2019

2019/2020

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TABLE 3.4 Phosphorus (“P-tal” after Olsen-P-extraction) and nitrogen levels in soil

analyses, given as average of all inspected holdings (n=41 in 2019/2020) and with the

lowest and highest average values at holding scale, respectively.

Control planning

period

Average

P-tal

(mg P/100

g soil)

Minimum

Maximum

Average

N-total

(%)

Minimum

Maximum

Average

N in grass

(%)

Minimum

Maximum

2011/

2012

4.36

2.00

6.40

0.60

0.11

2.39

0.36

0.01

1.10

2012/

2013

4.60

2.90

6.10

0.33

0.12

1.71

0.24

0.17

0.35

2013/

2014

4.33

2.90

8.40

0.25

0.15

0.41

0.48

0.16

2.00

2014/

2015

4.60

2.87

6.08

0.25

0.13

0.58

0.24

0.16

0.51

2015/

2016

4.62

3.10

6.14

0.23

0.13

0.41

0.24

0.17

0.33

2016/

2017

4.29

2.39

6.95

0.21

0.11

0.59

0.22

0.13

0.36

2017/

2018

4.22

2.20

7.05

0.20

0.12

0.34

2018/

2019

3.98

3.26

4.47

0.23

0.11

0.36

2019/

2020

4.41

2.20

6.70

0.23

0.14

0.53

3.6

Control of fertilizer accounts

Each year, the farmers submit their fertilizer accounts to the Danish Agricultural Agency. The

accounts include key data on:



total arable land on the farm

arable land available for application of livestock manure

data on catch crops

type and number of livestock

production of livestock manure (kg N and P)

usage of livestock manure including manure from contractors

usage of fertilizers and organic matter other than livestock manure

the farms nitrogen quota and the average phosphorus ceilings for different livestock manure,

fertilizers and organic matter other than livestock manure



information on whether the farmer has used the derogation or not

For the year 2019/2020, 634 (2.0 %) of the submitted fertilizer accounts were subject to ad-

ministrative control. 117 fertilizer accounts remain to be investigated. The data was verified

and the parties of interest were allowed to comment on their cases.

The accounts were selected based on different risk criteria. In 2019/2020, 36 (5.7 %) deroga-

tion holdings were selected for control. The holdings were asked to submit their updated and

valid fertilization plan and to state their manure application. It was checked whether the crop

rotation plan included at least 80 % crops with high N-up- take and long growing season as

well as whether leguminous plants were included. If the derogation had been used for four

consecutive years, the farmer also had to submit the results of the soil analysis. The share of

cattle- and other animal kg N on the farm was also controlled.

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3.6.1

Results

Out of the 36 harmony controls, 21 holdings (58.3 %) were closed without remarks. Four hold-

ings (11.1 %) were closed with remarks and 11 (30.6 %) inspections are still under investiga-

tion (Table

3.5).

TABLE 3.5 Results of administrative control of compliance with the harmony rules of

farms using the derogation.

Control planning

period

2009/2010

2010/2011

2011/2012

2012/2013

2013/2014

2014/2015

2015/2016

2016/2017

2017/2018

2018/2019

2019/2020

Number of

inspections

Inspections without

remarks

Inspections with

remarks

Inspections

still under

investigation

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4. Agricultural practices and

water quality

Jonas Rolighed, Mette Thorsen, Gitte Blicher-Mathiesen, Department of Eco-

science, Aarhus University, March 2023

Introduction

Since the late 1980s, Denmark has done a comprehensive and efficient effort to improve the

environmental state of groundwater and surface water by lowering nitrate concentrations, es-

pecially through reductions of nitrate leaching from agricultural sources. The first Action Plan

on the Aquatic Environment was adopted in 1987 and has since then been followed by subse-

quent action programmes to ensure efforts are made to reduce the loss of nitrogen and phos-

phorus to the aquatic environment.

In 1998, the Action Plan on the Aquatic Environment (APAE) II was accepted by the EU Com-

mission as the Danish Nitrate Action Plan implementing the Nitrates Directive (1998-2003). In

2003, a final evaluation of Action Plan II was performed. The results showed a 48% reduction

of the nitrate leaching from the agricultural sector, thus fulfilling the reduction target set in

1987.

In the subsequent action plans, the Green Growth Agreement from 2009, the first and the sec-

ond River Basin Management Plan from 2014 and 2016 as well as the Food and Agricultural

Agreement in December 2015, further mitigation measures were adopted to fulfil reduction tar-

gets for the N load to marine areas and the targets of the Water Framework Directive.

In 2015, Denmark implemented the EU Greening component under CAP direct payments

(REG EU 1307/2013), implying that at least 5% of the arable land of farms shall be appointed

as ecological focus areas with a greening element such as set-aside, catch crops etc.

From autumn 2012, it was decided to establish 50,000 ha of obligatory buffer zone placed ap-

proximately 10 m from the edge of open streams and lakes larger than 100 m2. In 2014, the

buffer zone area was adjusted from 50,000 to 25,000. From the beginning of 2016, the addi-

tional buffer zones are no longer mandatory and restricted to the former requirements of 2 m

buffer zones along target streams and lakes larger than 100 m

, amounting to approximately

6,000 ha.

The Political Agreement on Food and Agricultural Package from December 2015 includes a

diverse selection of measures aimed to change the environmental regulation of the agricultural

sector. The first part of this political agreement was implemented from 2016. In 2016, farmers

were allowed to use more fertiliser. According to the APAE II agreement, farmers were re-

stricted in the application of fertiliser at a level that was lower than the economic optimum. This

measure in APAE II was set to reduce the fertiliser application of nitrogen to 10% below this

optimum. This rule was regulated so that the total national nitrogen quota was set to a fixed

level but with the possibility of an adjustment relative to changes in crop cover.

This ad-

justment made sense as crops having a high application standard also have a higher nitrogen

uptake. If crops such as grass increase in cover, then the fertiliser application and N quota will

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increase as well. However, due to the suspension of set-aside in 2008, higher yields and in-

creases in the prices of cereals and proteins, the gap between the economic optimum and the

national N quota increased, especially after 2008, amounting to 18% in 2015.

According to the Political Agreement on Food and Agricultural Package implemented in 2016,

extra N fertiliser application, amounting to 2/3 of the gap between the economic optimum and

the reduced N quota, was allowed. From 2017, farmers were allowed to apply nitrogen up to

the economic optimum. Additional cover of catch crops and the greening element, for instance

more catch crops and set-aside, were, among other measures, introduced to counteract the

potential increase in leaching due to the extra application of N fertiliser from 2016 and on-

wards.

Additionally, targeted catch crops of 145,000 ha were implemented in 2017 to counteract the

potential increase in leaching due to the extra application of N fertiliser in 2017. In 2018 and

2019, the need for targeted catch crops was approximately 114,000 and 139,000 ha, respec-

tively. For 2020 and 2021, this area was increased to approximately 373.000 ha. The targeted

catch crops scheme was introduced to ensure that the status of coastal waters and groundwa-

ter does not deteriorate. Therefore, targeted catch crops are established in catchments where

reduction of the nitrogen load is needed. Applicants for targeted catch crops could be all farm-

ers who either own or lease fields for cultivation in such catchments.

The second River Basin Management Plans (RBMPII) was adopted in June 2016. It proposes

schemes for implementation of mitigation measures, such as re-establishment of riparian ar-

eas, construction of wetlands, set-aside of organic soils, afforestation and adjustment of

greening elements. The national reduction target for the annual marine N load in 2021 is esti-

mated to 13,100 t N. However, the RBMPII only includes mitigation measures to obtain an an-

nual reduction of the marine N load of 6,900 t N in the period 2015-2021 (SVANA 2016). The

decision on which measures to initiate to reach a further reduction in the annual nitrogen load

of 6,200 t N has been postponed to after 2021.

The N load to marine waters has been reduced incrementally along with the successful imple-

mentation of measures to reduce loadings from point sources and agriculture. Approximately

half of the Danish land area is located within catchments equipped with stream water gauging

stations where the N load to marine areas is regularly measured (Kronvang et al., 2008). The

nitrogen load for ungauged catchments has been modelled using an empirical model (Windolf

et al., 2011), and the combination of measurements and modelling shows that the total annual

load to marine waters varied between 55,000 and 59,000 t N, yielding an average of 57,000 t

N for the five years (2010-2014) used as status level in the RBMPII (SVANA (2016), Wiberg-

Larsen (2015)). However, the calculation of this total nitrogen load to coastal areas has been

updated and now includes a higher proportion of gauged catchments as well as an improved

and more detailed calculation of discharge in ungauged catchments (Thodsen et al., 2021).

For the period 2016-2020, the updated calculation yields an annual flow-normalised nitrogen

load ranging between 51,000 and 66,000 t N with the highest value in 2019 following a year

with drought-related low crop harvest. For 2020, the normalised total nitrogen load was 51,000

t N, which is the lowest value in the monitoring period (1990-2021). For 2021, the normalised

total nitrogen load was 55,000 t N (Thodsen, 2023).

The regulation and effects described in this chapter cover the period 2005-2021. Additional ag-

ricultural regulation, such as requirement to increase the utilisation efficiency of nitrogen in ma-

nure (2020/21), a reduced fertiliser application norm on soil with a high content of organic mat-

ter (2020/21) were implemented in 2020. A ban on application of solid manures in autumn and

ban on application of fertilizer on §3 extensive and permanent grasslands are fully imple-

mented in 2021/22.

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The remaining part of this chapter is divided into three parts:

First, the general development in agricultural practices at national level is presented for the pe-

riod 2005-2021. This analysis is based on national register datasets from the Ministry of Food,

Agriculture and Fisheries, i.e. the single-payment register and the farmers’ mandatory fertiliser

accounts.

Second, modelled nitrate leaching, including crop distribution and nitrogen balances, is pre-

sented for various farm types (including those benefitting from an authorisation of derogation)

and geographical areas. The impact of derogation farms is analysed based on a dataset de-

rived by linking data from the single payment register, including data on the crops on each field

comprised by the farms, and the fertiliser accounts. Both datasets cover agriculture in the year

2021. Modelling of nitrate leaching at national level is carried out by means of the empirical

model N-LES (version 4) (Kristensen et al., 2008).

Third, measurements of water quality from the National Monitoring Programme are presented

for the period 1990/91-2020/21, with particular reference to the Agricultural Catchment Moni-

toring Programme (Blicher-Mathiesen et al., 2023). This section includes:



Modelling of nitrate leaching in the agricultural monitoring catchments as referred to in Arti-

cle 10(3).



Measurements of nitrate and phosphorus in water leaving the root zone, including fields re-

ceiving more than 170 kg N ha-1 in organic manure as referred to in Article 10(2).



Nitrogen in surface water, draining from agricultural catchments as referred to in Article

10(2).

Modelling of nitrate leaching for the agricultural monitoring catchments in this section is carried

out by means of a new version of the empirical model N-LES (version 5) (Børgesen et al.,

2020, 2022). This model is partly based on data from the Agricultural Catchment Monitoring

Programme. The model requires input data for agricultural practises (N fertilisation, cropping

system), soil data and water percolation from the root zone. Percolation is calculated using the

Daisy model (Abrahamsen & Hansen, 2000) and a standardised climate dataset from a 10 km

grid net (Danish Meteorological Institute), representing weather measurements from the period

1990-2010. The climate dataset contains dynamic correction factors for rainfall (Refsgaard et

al., 2011). Thus, modelled nitrate leaching represents the leaching in a standardised climate

(water percolation). In contrast, all measurements from the Agricultural Catchment Monitoring

represent nitrate leaching under the actual climatic conditions.

So far, model-based calculations of phosphorus losses from farms benefitting from an authori-

sation of derogation are not available but measured phosphorus concentrations in root zone

water on fields with average application of less and more than 170 kg N ha-1 in organic ma-

nure are presented.

4.1

Development in agricultural practices at the national level

from 2005 to 2021

Crop distribution

The development in crop distribution for 2005-2021 was analysed on the basis of the single

payment registration.

Figure 4.1

presents the results for cash crops, fodder crops and non-cul-

tivated areas. The year 2005 was the first year with single-payment, and it was anticipated that

the reporting of areas for this first year would be overestimated. Hereafter, the total reported

agricultural area, including set-aside, decreased from approximately 2,757,000 ha in 2006 to

2,596,000 ha in 2021.

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The decrease in agricultural area of about 10,000 ha per year is due to road construction, af-

forestation, urbanisation etc. During the years 2006-07, set-aside comprised about 160,000

ha. As from 2008, the set-aside obligation was suspended, and in 2008 and 2009 most set-

aside areas were converted to cash crops, fodder crops and nature-like areas.

Set-aside covered between 23,000 and 33,000 ha in the period 2015-2021 as set-aside is an

element in the Danish implementation of the EU Greening. The area with cash crops and fod-

der crops has decreased slightly since 2012.

Catch crops

In Action Plan III, the requirement for growing catch crops was carried over from the former

Action Plan, stipulating that farmers in 2005-2009 should grow catch crops on at least 6% of

the potential catch crop area if they applied less than 80 kg organic manure N ha

-1

and on

10% of the area if they applied more than 80 kg organic manure N ha

-1

. The potential catch

crop area was defined according to crop type, including cereals, oilseed rape, maize, turnip

rape, soy, fava bean, sunflower, oil flax and other rotation crops without substantial nitrogen

uptake in the autumn. In 2008, the requirement for growing catch crops was raised to counter-

balance the effects of the set-aside suspension. From autumn 2009, an additional catch crop

area, equivalent to an extra 4% of the potential catch crop area, was implemented, yielding a

total requirement for the growing of catch crops of 10% or 14%, respectively. A further adjust-

ment of catch crop area was made to 10.7 and 14.7% from 2020.

During this period (2005-2010), farmers growing winter crops (wheat, rye, winter barley,

oilseed rape), preventing fulfilment of catch crop requirements, were granted a reduction of the

required catch crop area. From 2011, this possibility ceased.

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FIGURE 4.1 Development in crop distribution at the national level from 2005 to 2021,

data from the single payment register.

At the same time, voluntary alternatives to catch crops were introduced such as:



Reduction of the farm nitrogen fertilizer quota

Growing of special crops between harvest and sowing of winter crops

Growing catch crops on other farms

Establishment of perennial energy crops

Separation and treatment of animal manure (biogas and burning of the solid fraction of ma-

nure)

From 2015, substitution of one ha of catch crop by four ha of set-aside near open streams

and lakes larger than 100 m2 and located next to agricultural areas in rotation

From 2014, substitution of one ha of catch crop by four ha of winter cereals, if sown earlier

than September 7. From 2020, the area to substitute one ha of catch crop was decreased to

two ha of winter cereals sown earlier than September 7

From 2016, substitution of one ha of catch crop by one ha of set-aside

From 2022, substitution of one ha of catch crop by eleven ha of precision agriculture



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

From 2022, substitution of one ha of catch crop by one ha of catch crop with N-fixing spe-

cies and a deduction of 50 kg N ha-1 from the N-quota due to expected effect of nitrogen

taken up by the catch crop in the following crop

The possibility to grow catch crops on other farms to fulfil the catch crop requirement ceased

in 2021.

Data from the fertiliser accounts show that establishment of catch crops increased from about

118,600-138,000 ha in 2005/06-2007/08 to about 480.900 ha of catch crops in 2021/22 (Table

4.1).

The introduction and use of catch crop alternatives were equivalent to the effect of

13,900-95,000 ha catch crops in the period 2011/12-2021/22.

TABLE 4.1 Area with catch crops and catch crop alternatives (1,000 ha of catch crop

equivalents) reported by the farmers in the annual fertiliser account in the period

2005/06-2021/22.

05/06

138.0

06/07

118.6

07/08

127.2

08/09

196.6

09/10

183.0

10/11

211.0

11/12

211.0

12/13

224.0

13/14

295.7

14/15

321.1

15/16

390.0

16/17

353.1

17/18

415.2

18/19

366.5

19/20

355.6

20/21

505.1

21/22

480.9

Catch

crops

Catch

crop

alter-

na-

tives

28.6

44.0

13.9

43.3

37.6

36.1

28.5

42.8

16.2

95.0

32.7

In 2017, a new regulation of animal husbandry was implemented. With this regulation, addi-

tional catch crops, called “livestock catch crops”, were to be established in certain areas on

certain farms using organic fertilisers, including livestock manure. The regulation applies only

to farms cropping more than 10 ha and with the use of organic fertiliser of > 30 kg N ha

-1

. In

addition, the cropped area must be located in catchments with an increasing use of manure or

other organic fertilisers, and the area must drain into nitrate sensitive types of nature habitats

of the Natura 2000 area. Alternatively, to specific areas selected on a voluntary basis, which

drain into near coastal waters with a need for N load reduction according to the River Basin

Management Plans. The additional catch crops in certain areas on certain farms using manure

or other organic fertilisers can replace all or a part of the need for 80% fodder crops on dero-

gation farms and catch crops grown to fulfil the EU greening requirements.

Consumption of nitrogen fertiliser and nitrogen in manure

Data on the annual use of inorganic fertilisers and the use of nitrogen in animal manure are

obtained from the fertiliser accounts (Table 4.2). The application of animal manure N varied

between 216.000 and 227.000 t N from 2005 to 2021. The use of inorganic fertilisers

amounted to about 181,000-202,000 t N year

-1

in 2005-2007 and increased to 205,000 and

209,300 t N year

-1

in 2008 and 2009, probably due to the cultivation of previous set-aside ar-

eas. This was expected to be a temporary effect as the procedure for setting the crop nitrogen

standards implies that an increase in agricultural area with fertiliser requirements must be fol-

lowed by an equivalent reduction in nitrogen standards.

Administratively, however, this reduction is based on statistical data on the cultivated area, re-

sulting in a delay of two years. Thus, in 2010-2014, the use of inorganic fertilisers decreased

again, reaching the same level as in 2005-2007. The use of inorganic fertiliser increased from

210,000 t N in 2015 to 242,000, 237,000 and 224,000 t N in 2016, 2017 and 2018, respec-

tively, after the implementation of the Food and Agricultural Package, according to which farm-

ers were allowed to use more fertiliser after 2015.

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The lower use of inorganic fertiliser in 2018 compared to the two former years is caused by an

increase in organic farming, farms that do not use inorganic fertiliser, as well as a decrease in

the cultivated area. A change in the crop distribution with higher cover of spring cereals at the

expense of winter cereals also contribute to a lower use of inorganic fertiliser of approximately

20,000 t N in 2018 as winter cereals have a higher N uptake, higher harvest yield and there-

fore a higher economic optimal standard N-quota than spring cereals. The use of inorganic fer-

tilisers amounted to 223,000 t N in 2019, which is almost the same level as in 2018.

For the growing season 2019, farmers were recommended to apply app. 4 kg N ha-1 less as a

significant amount of nitrogen still remained in the soil in spring due to a very dry autumn and

winter. A wet autumn in 2019 made the establishment of winter cereals difficult. This resulted

in a decrease in the 2020 winter cereal area compared to 2019.

TABLE 4.2 Development in the use of inorganic nitrogen fertiliser and of nitrogen in ani-

mal manure as reported by the farmers in the annual fertiliser accounts for the period

2005-2021 (1,000 t N yr

-1

2005

2006

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

2017

2018

2019

2020

2021

Fertilizer

Animal

manure

191

227

181

218

202

236

205

230

209

226

198

224

203

223

198

220

199

215

203

212

210

216

242

219

237

218

224

223

219

230

216

200

216

However, the use of N in inorganic fertiliser increased to 230,000 t N, partly due to a recom-

mended higher application rate to compensate for a low soil N content prior to the growing

season of 2020 in some parts of the country. In 2021, the use of inorganic N has decreased to

200,000 t N, partly due to the requirement to increase the utilisation efficiency of nitrogen in

manure.

Modelled nitrate leaching for farm types and geographical areas and the impact of derogation

farms at the national level – 2021 data Modelled nitrate leaching demonstrates the effect of

crop distribution, nitrogen input, soil type and water percolation through the soil. This section

includes a presentation of all of these parameters. Regarding crop distribution and nitrogen in-

put, the analyses are based on the national datasets from the single payment register and the

fertiliser accounts. However, before the data can be used for this purpose, a detailed compila-

tion of the two datasets must be made (Børgesen et al., 2009).

The single payment register contains information on crops at field-block level, and the fertiliser

accounts contain information on the use of nitrogen (inorganic fertiliser and organic manure) at

farm level.

The two datasets are linked by means of the common farm identity number or a common farm

address, and the reported amounts of fertiliser and manure from the individual accounts are

distributed on the fields of each farm according to the crop nitrogen standards. Hereby, we ob-

tain a dataset with coherent data on crops and nitrogen application at field level. We have no

information on grass-ley from either dataset. Therefore, we estimate this parameter based on

the area with rotation grass, assuming a conversion rate of three years. If there is not sufficient

space in the crop rotation, the area with grass-ley is reduced accordingly. Data on catch crops

are derived from the fertiliser accounts.

The field-blocks are geographically mapped, implying that each field can be linked to soil maps

and to the meteorological grid. Having established the soil type for each field-block, the stand-

ard harvest yield may be estimated. Furthermore, nitrogen fixation is included using standard

values for each crop.

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This final dataset now contains all information necessary for geographically distributed compu-

tation of crop coverage and field nitrogen balances and for modelling nitrate leaching.

Farm type

The data are divided into three main groups of farm type – arable farms, pig farms and cattle

farms. A pig farm is defined as a farm where more than 2/3 of the used organic N including

manure originate from pigs, and a cattle farm is defined as a farm where at least 2/3 of the

used organic N including manure originate from cattle. An arable farm is a farm with a produc-

tion of organic fertiliser including manure of less than 20 kg N ha-1.

The farm may import animal manure, which will appear in the fertiliser account and is therefore

included in this analysis. Other farm types are not included in this analysis. The area occupied

by organic farms constitutes about 313,000 ha in 2021 (Landbrugsstyrelsen, 2022).

Figure 4.2

shows that arable farms and pig farms grew cereals, particularly winter wheat, on

most of the agricultural area (58 and 74%) in 2021. Other major cash crops were oilseed rape,

peas, root crops (potatoes and sugar beet) and grass for seeds (20-23%). Cereal silage, grass

and maize constituted a lesser part of the area (5-16%). Catch crops were grown on 17-22%

and newly established grass-ley on 3-4% of the agricultural area on arable and pig farms as

an autumn-winter plant cover.

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FIGURE 4.2 Crop distribution for three main farm types in 2021. Combined dataset from

the single payment register and the fertiliser status accounts.

Cattle farms have a different crop rotation. Cereals and other cash crops were grown on 34%

of the area, whereas cereal silage, grass and maize were grown on 57% of the area. In addi-

tion, grass-ley was found on 9% and catch crops on 19 % of the area.

On arable farms, an average amount of about 51 kg N ha

-1

from animal manure was applied.

For pig and cattle farms, the amounts were, respectively, 102 kg N ha

-1

and 129 kg N ha

-1

(Ta-

ble 4.3).

The use of inorganic fertilisers decreased with increasing application of animal manure. Total

inputs of nitrogen from inorganic fertiliser, manure, other organic sources, N fixation and at-

mospheric deposition amounted to 177, 198 and 246 kg N ha

-1

for arable farms, pig farms and

cattle farms, respectively. N balances, calculated as the difference between the total input of

nitrogen and removal by harvested crops, were 65, 84 and 95 kg N ha

-1

for arable farms, pig

farms and cattle farms, respectively. As expected, modelled nitrate leaching was lower from

arable farms (on average 51 kg N ha

-1

) than from animal husbandry farms (59 kg N ha

-1

from

pig farms and 65 kg N ha

-1

from cattle farms). N leaching was, on average, 6 kg N ha

-1

higher

for cattle farms compared to pig farms.

TABLE 4.3 N inputs, N balances, nitrate leaching and nitrate concentration at the bot-

tom of the root zone for three main farm types in 2021 based on model calculations.

Combined dataset. Organic farms were not included in the analysis.

N balance

In-

org.

fer-

ti-

lizer

Ani-

mal

ma-

nure

Other-

org.

.fix.

depos.

Seeds

To-

tal

in-

put

(kg N ha

-1

)

Ara-

ble

Pigs

Cat-

tle

Har-

vest

bal-

ance

Root zone water

Per-

co-

la-

tion

(mm

-1

)

Ni-

trate

leach-

ing

(kg N

-1

)

conc.

(mg l

)

102

129

4.9

1.6

1.5

8,0

4,8

22,0

2.0

2.2

1.6

177

198

246

112

114

151

339

373

409

On arable farms, the modelled nitrate leaching amounted to 78% of the N balance, which is a

high value relative to the 70% calculated for pig farms and the 68% for cattle farms. An expla-

nation may be that leaching on these soils with low input of organic manure is affected by min-

eralisation of the soil organic pool, i.e. depletion of the total soil N content. However, the high

leaching fraction may also be caused by the uncertainties associated with the two separate

calculations of the N leaching and N balance.

Water percolation through the soil is considerably higher on cattle farms than on arable and

pig farms.

However, this is not due to the differences in farm type but the fact that the cattle farms are lo-

cated mainly in the western part of the country with more sandy soil and higher rainfall and a

consequently higher percolation.

The higher percolation may contribute to an increased nitrate leaching and a dilution of the ni-

trate concentration in the soil water. Thus, the modelled average nitrate concentrations in soil

water were 67 and 70 mg NO3 l-1 on arable and pig farms, respectively, and 70 mg NO3 l-1

on cattle farms for the year 2021.

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Geographical areas

Farm types are not evenly distributed throughout the country because of variations in farming

conditions. For the following analysis, Denmark has therefore been divided into five farming

regions

(Figure 4.3).

FIGURE 4.3 Farming regions in Denmark used in the analysis and the location of the six

monitored agricultural catchments.

Table 4.4

shows that Zealand is dominated by arable farming, whereas arable farming and pig

production dominate Eastern (E) Jutland and Funen. Finally, North (N), North-West (NW) and

West (W) Jutland have the highest density of cattle farming. Thus, arable and pig farms are

located mainly in the eastern part of Denmark on loamy soils and with low rainfall, whereas

cattle farms are located mainly in the northern and western parts of Denmark on sandy soils

and with higher rainfall, the rainfall increasing from north to south.

TABLE 4.4 Distribution of farm types and soil types in Denmark divided into five main

geographical areas – 2021.

Arable

Pig

Cattle

Other

Sand

Loam

Organic

soils

% of agricultural area

Zealand

Jutland E + Fu-

nen

Jutland N

Jutland NW

Jutland W

% of agricultural area

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FIGURE 4.4 Crop distribution for five farming regions in Denmark in 2021. Combined

dataset from the single payment register and the fertiliser accounts.

The crop distribution within the five farming regions of Denmark follows the same pattern as

for farm types, i.e. mainly cereals and other cash crops on the islands and in Eastern Jutland

and cereals and fodder crops in West and North Jutland (Figure

4.4).

The input of nitrogen with animal manure, the total nitrogen input and the field nitrogen bal-

ances are lowest on Zealand, higher in E Jutland and on Funen and highest in W, NW and N

Jutland (Table

4.5).

In the latter three areas, the average nitrogen input varied between 200 and 220 kg N ha

-1

The average modelled nitrate leaching generally increased from east to west due to increases

in nitrogen input and percolation. Within the three western and northern parts of Jutland, the

nitrate leaching increased from northern to southern Jutland, mainly due to increased water

percolation through the root zone. Higher water percolation led to dilution of the nitrate con-

centrations of the soil water, resulting in an average nitrate concentration in soil water of 79,

69, 71, 65 and 60 mg NO

-1

on Zealand, Funen + E and N Jutland, and NW and W Jutland,

respectively.

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TABLE 4.5 N inputs and N balances, nitrate leaching and nitrate concentration at the

bottom of the root zone (1 m) calculated for five geographical areas in Denmark in 2021.

Combined dataset from the single payment register and the fertiliser accounts. Organic

farms were not included in the analysis.

N balance

Inorg.

fertilizer

Animal

manure

Other-

org.

N .fix.

depos.

(kg N ha

-1

)

Seeds

Total

input

Harvest

Root zone water

Percola- Nitrate

tion

leaching

balance

(mm a

-1

)

(kg N

-1

)

conc.

(mg l

-1

)

Zealand

Jutland

E + Fu-

nen

Jutland

114

3.7

8.8

1.8

174

117

199

3.1

9.2

1.9

188

118

328

111

112

2.5

0.9

4.7

14.9

13.1

13.7

1.7

1.8

2.0

200

208

220

120

123

131

364

446

540

Derogation farms

Derogation farms are mainly located in N, NW and W Jutland where cattle farming is domi-

nant. The effect of the derogation was evaluated for these three geographical areas. The cattle

farms were grouped into four livestock density groups depending on the application of organic

N including manure: 0-100, 100-140, 140-170 kg N ha

-1

and derogation farms with the use of

organic N including manure of 170-230 kg N ha

-1

The crop distributions for the three geographical areas were found to be almost identical, with

some differences in crop cover between spring and winter cereals as well as larger proportions

of maize and catch crops in W Jutland (Figure

4.5.).

There is a clear trend indicating a de-

crease in areas with cereals and an increase in the areas with catch crops with increasing live-

stock density. In addition, the area with fodder crops increases with increasing livestock den-

sity. The area with roughage amounted to 57, 63 and 76% for the three groups, 0-100, 100-

140, 140-170 use of organic N including manure ha

-1

, respectively, whereas derogation farms

grew roughage on an average of 86% of the area.

The effect of derogation on nitrate leaching was evaluated separately for the three geograph-

ical areas. The nitrogen input as well as the field nitrogen balances increased with increasing

livestock density (Table

4.6).

Modelled nitrate leaching is generally a combined effect of two opposing mechanisms – an in-

crease in leaching due to increased nitrogen input and a decrease in leaching due to an in-

creased area with roughage and catch crops.

Table 4.6

shows that the modelled nitrate leaching generally increased with increasing live-

stock density and hence with increasing nitrogen input. Thus, differences occurred in the mod-

elled annual nitrogen leaching of 0, 7 and 5 kg N ha

-1

, respectively, between derogation farms

and farms using 140-170 kg N ha

-1

of N in manure and other organic fertilisers in the three Jut-

land regions N, NW and W, respectively. Modelled nitrate concentrations in the soil water leav-

ing the root zone were 2, 6, and 3 mg NO

-1

higher for derogation farms than for cattle farms

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using 140-170 kg N ha

-1

of N in manure and other organic fertilisers in Jutland N, NW and W,

respectively.

FIGURE 4.5 Average crop distribution for four groups of livestock density in N, NW and

W Jutland in 2021. Combined dataset from the single payment register and the fertiliser

accounts. Organic farms were not included in the analysis.

The use of legumes (clover, alfalfa, peas) in grass and cereal silage is shown in

Table 4.7.

The general trend is that derogation farms grow less legumes than non-derogation farms (Ta-

ble 4.7).

Thus, clover or alfalfa (max. 50% share) in rotation grass was used on 65% of the ro-

tation grass area for derogation farms and on 77-79% for non-derogation farms. For perma-

nent grass including legumes, the equivalent values were 20% for derogation farms and 25-

40% for non-derogation farms. Cereal silage with peas amounted to 15% of the silage area for

derogation farms and 15-20% for non-derogation farms.

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TABLE 4.6 N inputs, N balances and nitrate leaching and nitrate concentration at the

bottom of the root zone calculated for four groups of livestock densities at cattle farms

and for three geographical areas in Jutland, Denmark, 2021. Combined dataset from the

single payment register and the fertiliser accounts. Organic farms were not included in

the analysis.

N balance

Region

Annual

use of or-

ganic N

kg N ha

-1

Inorg.

ferti-

lizer

Animal

manure

Other-

org.

N .fix.

depos.

Seeds

Total

input

Harvest

balance

Root zone water

Perco-

lation

(mm a

-1

)

Nitrate

leach-

ing

(kg N

-1

)

conc.

(mg l

-1

)

(kg N ha

-1

)

Jutland N

0-100

100-140

140-170

170-230

117

157

199

120

153

196

119

158

201

1.6

1.1

0.1

3.8

0.0

0.2

5.3

1.7

0.8

0.2

1.2

1.5

1.4

1.3

1.5

1.6

1.7

1.5

167

233

271

314

180

226

259

303

173

235

273

314

105

135

161

188

113

130

155

184

115

139

166

192

109

126

104

119

107

123

355

361

359

349

430

458

436

445

520

546

544

550

Jutland

0-100

100-140

140-170

170-230

Jutland

0-100

100-140

140-170

170-230

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Table 4.7 Use of legumes in grass and cereal silage at cattle farms for derogation and

non-derogation farms 2021. Organic farms were not included in the analysis.

Use of organic N, including manure (kg N ha-1 a-a)

0-100

100-140

140-170

170-230

share of agricultural area (%)

Rotation grass

10.7

15.1

share of rotation grass (%)

No clover/alfalfa

< 50% clover/al-

falfa

> 50% clover/al-

falfa

22.5

33.5

Permanent grass

share of agricultural area (%)

15.7

10.8

share of permanent grass (%)

7.3

6.0

No clover/alfalfa

< 50% clover/al-

falfa

> 50% clover/al-

falfa

Cereal silage

share of agricultural area (%)

1.4

2.2

share of cereal silage (%)

4.5

7.9

No legumes

< 50% legumes

100% legumes

4.2

Development in modelled nitrate leaching in the

Agricultural Catchment Monitoring Programme 1990-2020

This section deals with the general development in nitrate leaching from 1990/91 to 2020/2021

for measured nitrated concentrations in soil and ground water and to 2020/21 for the modelled

nitrate leaching for tree loamy and two sandy agricultural-dominated catchments. Information

on agricultural practises is derived from the Agricultural Catchment Monitoring Programme.

This programme includes six small agricultural catchments situated in various parts of the

country in order to cover the variation in soil type and rainfall and hence in agricultural prac-

tises (Figure

4.3).

The farmers are interviewed every year about livestock, crops and fertilisa-

tion and cultivation practises.

Modelled nitrate leaching presented for these five catchments was in the former derogation re-

ports modelled using the NLES3 and NLES4-models. The model was updated and recali-

brated to a new NLES5-model using a larger dataset in 2020 (Børgesen et al., 2020, 2022).

Nitrate leaching for the agricultural catchments in the present report is modelled with the

NLES5 model. The modelling results are therefore not directly comparable to the results in the

former reports.

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The modelling has been conducted for all fields in the catchments based on the information

from farmers on agricultural practises and standard percolation values that are calculated on

the basis of the climate for 1990-2010.

In 2021, 120 farmers participated in the investigation. 88 farms agreed to give information

about part of their farming area. Of all the investigated farms, 19 were cattle farms. Three of

the cattle farms were registered as derogation farms. These derogation farms covered 8% of

the total area in the Agricultural Monitoring Catchments in 2021.

The modelled nitrate leaching from the agricultural area in the catchments was calculated for

the period 1990 to 2021 (representing the hydrological years 1990/91 to 2021/22). The mod-

elled leaching is shown in

Figure 4.6

as an average for sandy and loamy catchments, respec-

tively.

FIGURE 4.6 Simulation of the nitrate leaching using the NLES5 model in a standard cli-

mate for the fields of tree loamy and two sandy catchments within the Agricultural

Catchment Monitoring Programme 1990/91-2021/22.

With the present model calculation with NLES5, a decrease in the modelled nitrate leaching of

42 % has been achieved for the entire period 1991/92 to 2021/22, with each LOOP catchment

weighing 1/5. In this way, the average corresponds to clay soil in Denmark covering 60% and

sandy soil 40%. For the period 1991/92 to 2003/04, the decrease in modelled nitrate leaching

amounts to 37%. With model calculation of nitrate leaching with NLES3 and NLES4, the corre-

sponding decrease was approx. 43% (Blicher-Mathiesen et al., 2021). The model calculation

in LOOP only has data from 1991, while it is expected that nitrate leaching was also reduced

before this time. At the final evaluation of Water Environment Plan II in 2003, it was calculated

that nitrogen leaching at national level had been reduced by 48% from 1985 to 2003 (Grant &

Waagepetersen, 2003). Here there was a reduction in leaching from 1985 to 1989 estimated

to 12 percentage points.

For the loamy catchments, modelled annual nitrate leaching was relatively stable around 40 kg

N ha-1 during the period 2003-2014 decreasing to a level just below 40 kg N ha-1 in the period

2015-2021. For the sandy catchments, the modelled annual nitrate leaching was relatively sta-

ble around 67-68 kg N ha

-1

during the period 2003-2021.

The purpose of the root zone modelling is to show the effects of measures introduced to miti-

gate nutrient losses from agriculture. The modelling is therefore carried out for climate normal-

ised growth conditions, i.e. averaging the model output for a 20-year period: The model is run

for each year in the 20-year period and model outputs are then averaged for the period. The

climatic data used cover the period 1990-2010. Actual measurements of nitrate leaching will

show higher annual variations than the climatic average of the modelled values as the meas-

urements depend on the actual climate.

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4.3

Measurements of nitrate in water leaving the root zone

In five of the six Agricultural Monitoring Catchments, soil water samples are collected regularly

at 30 sites. One of the sites is covered by forest and is therefore not included in the data on

nitrate concentrations measured in agricultural areas. Measurements were ceased on a sandy

site in 2011 as the farmers did not want to participate in the monitoring. Two sites on a loamy

catchment are located very close to the edge of the field, and tractor transport in and out of the

fields results in high damage to crops, possible uneven fertiliser application and very high val-

ues of measured nitrate leaching in some of the monitored years. Out of the remaining 27 sites

on agricultural areas, 14 are located on loamy soils and 13 on sandy soils, and the data on

these are considered valid for use in the trend analysis of the loamy and sandy catchments.

The samples represent the root zone water (approx. 1 m depth – 30 samples per year) and the

upper oxic groundwater (1.5-5 m depth – 6 samples per year). To obtain an annual repre-

sentative value for the nitrate leaching, the measured nitrate concentration is multiplied by the

percolation in the sampling period. Samples are taken weekly in periods with percolation (au-

tumn, winter and spring) and monthly in summertime when percolation is scarce or zero. Per-

colation values are modelled as measurements of soil water content and flow in soil, covering

soil variability at field level, are difficult to perform (Blicher-Mathiesen et al., 2014). The annual

flow-weighted nitrate concentration is calculated by dividing the annual percolation by the an-

nual nitrate leaching.

Since the publication of the annual derogation report for 2018, inconsistencies in the precipita-

tion time series have been detected (Svendsen & Jung-Madsen (Ed.) (2020); Andersen (Ed.)

(2021)). These inconsistencies affect the reported flow-weighted concentrations as the precipi-

tation time series are used for the calculation of percolation. Specifically, it was found that the

relation between precipitation and stream runoff in the monitoring catchments was inconsistent

before and after 2010, respectively. The precipitation is measured at several rain gauge sta-

tions and distributed to cover 10x10 km

grids by the Danish Meteorological Institute (DMI).

The type of rain gauge station was changed from 2011, and also the number of stations de-

creased significantly. This explains some of the inconsistency related to measured discharge.

DMI has delivered new precipitation data for the period after 2010, but all inconsistency in the

data has not yet been resolved. In order to address the possible bias or inconsistency in the

precipitation time series, we included an uncertainty in the precipitation data, which is reflected

in the calculated percolation and flow-weighted nitrate concentration. This uncertainty was de-

rived from an analysis of radar-detected precipitation in five subplots within ten precipitation

grids of 10x10 km

The standard error bars on the flow-weighted nitrate concentration in

Figure 4.7

and

Figure

4.11

represent this uncertainty from variation in precipitation on field level but tabulated as an

average uncertainty from ten precipitation grids (Blicher-Mathiesen et al., 2023).

The flow-weighted nitrate concentrations are shown as annual average values for loamy and

sandy soils, respectively, for the period 1990/91 to 2020/21 (Figure

4.7).

Generally, measured data on nitrate leaching from the root zone at only 27 sites cannot be

used directly for estimating the effect of a single variable as the input of fertiliser or manure be-

cause of the high variability in actual fertiliser and manure practice and climate between the

monitoring fields and the measured years. Instead, the measured nitrate leaching data, to-

gether with other leaching data, were used for the development of the nitrate leaching model,

N-LES5, which was subsequently used for calculating the leaching from all the fields in the

catchments accounting for agricultural practises.

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FIGURE 4.7 Annual flow-weighted nitrate concentrations measured in root zone water (1

m below ground level) and annual average nitrate concentrations measured in upper

oxic groundwater (1.5-5 m below ground level), the Agricultural Catchment Monitoring

Programme 1990/91 to 2020/21. Error bars indicate variation in percolation as precipita-

tion variated on local scale within a DMI 10 x 10 km

precipitation grid.

General trend for nitrate concentrations in water leaving the root zone

There is strong inter-annual variation in the measured nitrate concentrations due to differences

in rainfall and temperature. Therefore, a long time series and a large number of measuring

points are needed to detect any statistically significant trend. Such data series are available

from the Danish Monitoring Programme. A statistical trend analysis – a Mann-Kendall test, in-

corporating annual variations in the mean annual flow-weighted nitrate concentrations for wa-

ter leaving the root zone – showed that concentrations decreased significantly by 1.2 and 2.6

mg NO

-1

for the measured sites on loamy and sandy soils, respectively, and for the whole

26-year monitoring period from 1990/91 to 2015/16.

In loamy catchments, the measured nitrate concentrations in root zone water decreased from

61-155 mg NO

-1

in the 5-year period 1990/91-1994/95 to 37-66 mg NO

-1

in the 5-year pe-

riod 2011/12-2015/16. In the latest 5-year period 2016/17 - 2020/21 the concentrations have

varied from 50 to 116 mg NO

-1

. The high nitrate concentrations are seen in years with low

percolation– as observed on loamy soils in 2004/05, 2010/11, in 2016/17, in 2018/19 and in

2020/21. In sandy catchments, the nitrate concentration decreased from 73-192 mg NO

-1

the 5-year period 1990/91-1994/95 to 54-73 mg NO

-1

in the 5-year period 2011/12-2015/16.

In the latest 5-year period 2016/17-2020/21 the concentrations have varied from 61 to 113 mg

-1

(Figure

4.7).

High nitrate concentrations were measured after 2018, a year with

drought and low yield as well as low percolation. In contrast, low nitrate concentrations were

measured in 2019/20 due very high percolation diluting the nitrate in the root zone.

After 2003/04 (Action Plan III + Green Growth), no statistically significant change in measured

nitrate concentrations in soil water leaving the root zone has been recorded. However, before

2011/12, high concentrations were temporarily observed for sandy soils. This is most likely

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due to growth of crops with high leaching potential on these fields, such as turnover of grass-

land followed by cereals with no catch crops the following years, growing of maize and winter

oilseed rape etc.

It should be noted that the measurements of nitrate leaching originate from a small number of

sampling stations (27 stations). Furthermore, the measurements are affected by high crop

yields, in particular in 2009, and effects of crop rotation, especially of grass in rotation. These

conditions induce higher inter-annual variations than seen in the average modelled nitrate

leaching, which covers a larger area including approx. 124 farms.

In the upper groundwater (1.5-5.0 m below ground level), nitrate concentrations were lower

than in the root zone water especially on loamy catchments, indicating nitrate reduction in the

aquifer between the bottom of the root zone and the uppermost groundwater

(Figure 4.7).

In loamy catchments, the measured annual mean of nitrate concentrations in the upper oxic

groundwater decreased from 40-47 mg NO

-1

in the 5-year period 1990/91-1994/95 to 31-38

mg NO

-1

in the 5-year period 2016/17-202020/21. In sandy catchments, the nitrate concen-

tration decreased from 87-112 mg NO

-1

in the 5-year period 1990/91-1994/95 to 54-77 mg

-1

in the 5-year period 2016/17-2020/21.

Nitrate concentrations in water leaving the root zone from cattle farms with average

manure N applications below and above 170 kg N ha

-1

during the 10-year period 2011-

2020.

Five of the monitoring sites received an average between 130 and 170 kg organic manure N

-1

in the period 2011/12 -2020/21, and six sites received an average of more than 170 kg or-

ganic manure N ha

-1

In the same period. Measurements of nitrate in water leaving the root

zone are shown annually for each site for the period 2000/01 to 2020/21 (Figure

4.8A and B).

At two of the sites, station “st 604” and “st 202”, the manure input changed from a high annual

input (>170 kg N ha

-1

) in the period 2000-2010 to a lower input (<170 kg N ha-

) in the follow-

ing years (Figure

4.8.A).

In the period with an annual average manure application of more than 170 kg N ha

-1

, nitrate

concentrations were very high at “st 604” compared to the following period. At “st 202” the ni-

trate concentrations varied at a lower level than “st 604” in the period where the annual aver-

age manure application was more than 170 kg N ha

-1

, (2000/01 to 2010/11) and showed in-

creased concentrations in the period where the annual average manure application was less

than 170 kg N ha

-1

(2011/12 to 2020/21).

At two other sites, station “st 201” and “st 206”, the manure input changed from a low annual

input (<170 kg N ha

-1

) in the period 2000-2010 to a higher input (>170 kg N ha

-1

) in the follow-

ing years (Figure

4.8.B).

In the period with an annual average manure application of less than

170 kg N ha

-1

, nitrate concentrations were very low at “st 206” compared to the following pe-

riod.

At “st 201” the nitrate concentrations did not show a general increase in the period where the

annual average manure application was more than 170 kg N ha

-1

, (2000/01-2010/11).

The average flow-weighted nitrate concentrations in root zone water for the six specific sites

with an average manure application within 170-230 kg N ha

-1

during the last 10-year period

(2011/12-2020/21) varied between 54 and 128 mg NO

-1

for the recent ten hydrological years

(2011/12-2020/21) (Figure

4.8D).

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The average flow-weighted nitrate concentrations in root zone water at five specific sites with

an average manure application within 130-170 kg N ha

-1

varied between 47 and 92 mg NO

-1

for the recent ten hydrological years (2011/12-2020/21) (Figure

4.8C).

Thus, there was no

clear difference in flow-weighted nitrate concentration between monitored fields with applica-

tion of 130-170 kg N ha

-1

and 170-230 kg N ha

-1

in manures.

FIGURE 4.8 Measured flow-weighted nitrate concentrations in root zone water (1 m

depth) with average application during the last ten years of 130-170 N ha

-1

(A) and more

than 170 kg N ha

-1

in manure and other organic fertilisers (B) at the sites (average appli-

cation of organic manure N is shown in brackets). Annual averages for the measured

stations, average application of 130-170 kg ha

-1

in ma-

nure and other organic fertilisers (D). All data from the period 2000/01 to 2020/21 are

shown.

Annual variations in measured concentrations at the individual monitoring stations were ex-

pected, partly due to crop rotation and variations in yield and meteorological conditions. Both

the sites that annually received an average of 130-170 kg N in manure ha

-1

in the period

2011/12-2020/21 and the sites that received an average >170 kg N in manure ha

-1

in the pe-

riod had high average nitrate concentrations (>100 mg/l) in some of the years (Figure

4.8).

High nitrate concentrations are most likely a result of crop rotation, especially turnover of clo-

ver grass in rotation, followed by cereals without catch crops or high N input to maize, and

they cannot be linked to the level of manure input alone.

Phosphorus concentrations in the water leaving the root zone are shown in

Figure 4.9.

Gener-

ally, the concentrations varied between 0.005 and 0.050 mg PO

-P l

-1

, irrespective of the use

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of organic manure. However, in two fields receiving an average of above 170 kg organic N ha

-1

(“st 607” and “st 608”) in the entire period from 2000/02-2020/21, P concentrations were much

more variable in the first part of the period (until 2011/12) with P concentrations exceeding

0.05 mg PO

-P l

-1

in three hydrological years.

The soil texture in these fields is coarse sand, and they are located in an area with high rain-

fall. Since 2011/12, the max. annual P concentrations at all monitored stations have been be-

low 0.020 PO

-P l

-1

FIGURE 4.9 Measured phosphorus concentrations as dissolved orthophosphate (PO

-P)

at soil water stations (1 m depth) with average application of 130-170 (A) and more than

170 kg organic manure N ha

-1

(B) at the sites in the recent 10 years (average application

of organic manure N is shown in brackets). All data for the period 2000/01 to 2020/21

are shown.

4.4

The nitrogen flow to surface water in agricultural

catchments

This chapter gives an overview of the nitrogen pathways in the hydrological cycle and de-

scribes the trends for nitrate in water for the period 1990 to 2021. Continued monitoring within

the framework of the Agricultural Catchment Programme and the Stream Programme will pro-

vide indicators for the future development.

When percolating water leaves the root zone, it can conceptually be partitioned into a compo-

nent that discharges directly to surface water and a component that discharges to groundwater

from where it will eventually – often some years later – discharge into the streams. In Den-

mark, the pathways for water and nutrients in agricultural catchments are analysed in the Agri-

cultural Catchment Monitoring Programme. Nitrate concentrations are measured in soil water,

water from tile drains, upper groundwater and surface water from three loamy catchments and

two sandy catchments.

The monitoring programme does not allow a specific evaluation of the effect of derogation

farms on the nitrate transport in the streams since measurements at the catchment outlet inte-

grate the effects of all activities in the catchment. However, the monitoring programme will pro-

vide an overview of the general trend for surface water, including the effect of any derogation

farms in the catchment.

The hydrological pathways

An analysis of the water flow in the streams of the five agricultural catchments has shown that

water flow can be conceptually divided into three components – rapid, intermediate and slow

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response to precipitation (Table

4.8)

(Blicher-Mathiesen et al., 2021). These components may

be regarded as flow from the upper soil layers (including tile drainage), from the upper oxic

groundwater and from deep reduced groundwater.

TABLE 4.8 Partitioning of water flow in streams into three components – rapid, interme-

diate and slow responding water. The analysis included three loamy catchments and

two sandy catchments (1989/90-2002/03).

Flow response

Rapid

Loamy catchments

Sandy catchments

41%

20%

Intermediate

16%

23%

Slow

43%

57%

FIGURE 4.10 Measured means of nitrate concentrations in the hydrological cycle in

three loamy catchments and two sandy catchments included in the Agricultural Catch-

ment Monitoring Programme. Values instreams and root zone are shown as means, and

data on min and max for the individual catchments are given in brackets. The values are

calculated as an annual mean for the period 2015/16 to 2020/21.

In loamy catchments, the flow path is characterised by relatively rapidly responding water

(from upper soil layers), whereas there is a larger proportion of slowly responding water (from

deeper groundwater) in sandy catchments (Figure

4.10)

(Blicher-Mathiesen et al., 2023).

Figure 4.11

illustrates measurements of nitrate concentrations (mg NO

-1

) in soil root zone

water, upper oxic groundwater (1.5-5 m below ground level) and in streams. When water per-

colates from the root zone to the upper groundwater, denitrification processes may take place

depending on the redox conditions and reduction potentials. Thus, nitrate concentrations in the

upper groundwater are lower than in the root zone water especially in the loamy catchments.

When the water passes through the deeper aquifers, it can also be denitrified in anoxic nitrate

reducing zones.

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FIGURE 4.11 Nitrate concentrations measured in root zone water, upper groundwater

and in streams for three loamy catchments and two sandy catchments according to the

Agricultural Catchment Monitoring Programme, 1990/91-2020/21.

As streams in sandy catchments are dominated by deeper groundwater flow, the groundwater

discharging to the streams has often been exposed to reduction processes. Thus, nitrate con-

centrations in the stream water are relatively low. In loamy catchments, the discharging water

has mainly passed through the upper soil layers and through the drainage system where there

is less nitrate reduction. Hence, nitrate concentrations in the streams on loamy soils are higher

than in sandy catchments.

In this context, it should be noted that cattle farms, i.e. the derogations farms, are mainly lo-

cated in the western and northern parts of Jutland that are characterised by sandy soils and

deep groundwater flow, leading to relatively high nitrate removal and lower nitrogen concentra-

tions in the streams streams but high nitrate concentrations in the upper oxic groundwater.

Trends in nitrate concentrations in the hydrological cycle

The development in nitrate concentrations in root zone water, upper oxic groundwater and

stream water is shown in

Figure 4.11.

Statistical analyses incorporating the annual variations

showed that the nitrate concentration in water leaving the root zone decreased significantly by

1.2 and 2.6 mg NO

-1

at the measured sites on loamy and sandy soils, respectively, for

the 26-year monitoring period from 1990/91 to 2015/16.

However, as mentioned before, the root zone concentrations have varied from 50 to 115 mg

-1

in the latest 5-year period 2016/17-2020/21 on loamy soils and between 61 to 113 mg

-1

in the corresponding five years, on sandy soils (see section 4.5). In the Stream Monitor-

ing Programme, the development is analysed for a larger number of streams. This programme

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reported that during the period 1989-2021, in 45 agriculturally dominated catchments repre-

senting both loamy and sandy soils, there was an average reduction of 48% (±5%) of the total

nitrogen transport (Thodsen et al., 2023).

4.5

References

Andersen R.C. (Ed.). (2021). Undersøgelser af DMI’s nedbørsdata til anvendelse for hydrolo-

giske formål. Afrapportering til miljøministeriet. Danmarks Meteorologiske Institut.

https://www.dmi.dk/fileadmin/Rapporter/2021/Undersoegelser_af_DMI_s_nedboers-

data_til_anvendelse_for_hydrologiske_formaal.pdf

Blicher-Mathiesen, G., Thorsen, M., Houlborg, T., Petersen, R.J., Rolighed, J., Andersen,

H.E., Jensen, P.G., Wienke, J., Hansen, B. & Thorling, L. (2023). Landovervågningsoplande

2021. NOVANA. Aarhus Universitet, DCE – Nationalt Center for Miljø og Energi, 284 s. - Vi-

denskabelig rapport nr., 526

Blicher-Mathiesen, G., Houlborg, T., Petersen, R.J., Rolighed, J., Andersen, H.E., Jensen,

P.G., Wienke, J., Hansen, B. & Thorling, L. 2021. Landovervågningsoplande 2020. NOVANA.

Aarhus Universitet, DCE – Nationalt Center for Miljø og Energi, 260 s. - Videnskabelig rapport

nr. 472. http://dce2.au.dk/pub/SR472.pdf

Blicher-Mathiesen, G., Andersen, H.E. & Larsen, S.E. (2014). Nitrogen field balances and suc-

tion cup-measured N leaching in Danish catchments. Agriculture, Ecosystems and Environ-

ment 196, 69-75.

Børgesen, C.D., Sørensen P., Blicher-Mathiesen G., Kristensen, K.M., Pullens J. W., Zhao. J.

& Olesen J.E. (2020). NLES5 - An empirical model for estimating nitrate leaching from the root

zone of agricultural land. DCA - Danish Centre for Food and Agriculture. 116 p. - DCA report

No. 163. https://dcapub.au.dk/djfpublikation/djfpdf/DCArapport163.pdf

Børgesen C.D., Pullens J. W., Zhao. J., Sørensen P., Blicher-Mathiesen G. & Olesen J.E.

(2022). NLES5 - An empirical model for estimating nitrate leaching from the root zone of agri-

cultural land. European Journal of Agronomy 134, 126465.

Grant, R., Blicher-Mathiesen, G., Pedersen, M.L., Jensen, P.G., Pedersen, M. & Rasmussen,

P. (2003). Landovervågningsoplande 2002. NOVA 2003. Danmarks Miljøundersøgelser. 132

s. - Faglig rapport fra DMU nr. 468.

Grant, R., Nielsen, K. & Waagepetersen, J. (2006) Reducing nitrogen loading of inland and

marine waters – evaluation of Danish policy measures to reduce nitrogen loss from farmland.

Ambio 35, 117-123.

Kristensen, K., Waagepetersen, J., Børgesen, C.D., Vinther, F.P., Grant, R. & Blicher-Mathie-

sen, G. (2008). Reestimation and further development in the model N-LES - N-LES3 to N-

LES4. DJF Plant Science No. 139.

Kronvang, B., Andersen, H.E., Børgesen, C., Dalgaard, T., Larsen, S.E., Bøgestrand, J. & Bli-

cher-Mathiasen, G., (2008). Effects of policy measures implemented in Denmark on nitrogen

pollution of the aquatic environment. Environmental Science & Policy 11, 144-152.

Landbrugsstyrelsen (2022). Statistik over økologiske jordbrugsbedrifter 2021. Landbrugsstyrel-

sen, Ministeriet for Fødevarer, Landbrug og Fiskeri. https://lbst.dk/fileadmin/user_upload/Natu-

rErhverv/Filer/Tvaergaaende/Oekologi/Statistik/Statistik_over_oekologisk_jordbrugsbedrif-

ter_2021_v2.pdf

Ministry of Environment of Denmark / Nitrates Directive / Derogation Report 2022

MOF, Alm.del - 2022-23 (2. samling) - Bilag 466: Årlig rapport til EU-Kommissionen om den danske undtagelse fra nitratdirektivet

Thodsen, H., Tornbjerg, H., Bøgestrand, J., Larsen, S.E., Ovesen, N.B., Blicher-Mathiesen,

G., Rolighed, J., Holm, H. & Kjeldgaard, A. 2021. Vandløb 2019 - Kemisk vandkvalitet og stof-

transport. NOVANA. Aarhus Universitet, DCE – Nationalt Center for Miljø og Energi, 74 s. - Vi-

denskabelig rapport nr. 452

Thodsen, H., Tornbjerg, H., Rolighed, J., Kjær, C., Larsen, S.E., Ovesen, N.B., Blicher-Mathie-

sen, G. 2023. Vandløb 2021 - Kemisk vandkvalitet og stoftransport. NOVANA. Aarhus Univer-

sitet, DCE – Nationalt Center for Miljø og Energi, 90 s. - Videnskabelig rapport nr. 526

SVANA (2016). Vandområdeplaner 2015-2021. Styrelsen for Vand og Naturforvaltning. Miljø-

og Fødevareministeriet. https://mst.dk/natur-vand/vandmiljoe/vandomraadeplaner/vandomraa-

deplaner-2015-2021/vandomraadeplaner-2015-2021/

Svendsen, L.M. & Jung-Madsen, S. (Ed.) 2020. Homogenitetsbrud og potentielle fejl i ned-

børsdata. Eksempler på konsekvenser for myndighedsbetjeningen. Aarhus Universitet, DCE –

Nationalt Center for Miljø og Energi, 28 s. Fagligt notat nr. 2020|51 https://dce.au.dk/filead-

min/dce.au.dk/Udgivelser/Notatet_2020/N2020_51.pdf

Wiberg-Larsen, P., Windolf, J., Bøgestrand, J., Larsen, S.E., Thodsen, H., Ovesen, N.B., Bjer-

ring, R., Kronvang, B. & Kjeldgaard, A. (2015). Vandløb 2013. NOVANA. Aarhus Universitet,

DCE – Nationalt Center for Miljø og Energi, 50 s. - Videnskabelig rapport fra DCE - Nationalt

Center for Miljø og Energi nr. 121 http://dce2.au.dk/pub/SR121.pdf

Windolf, J., Larsen, S.E., Thodsen, H., Bøgestrand, J., Ovesen, N. & Kronvang, B. (2011). A

distributed modelling system for simulation of monthly runoff and nitrogen sources, loads and

sinks for ungauged catchments in Denmark. Journal of Environmental Monitoring 13, 2645-

2658.

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5. Reinforced monitoring in

areas characterized by

sandy soils

This chapter is based on selected data from the National Monitoring Program

of Water and Nature (NOVANA), provided by the Danish Environmental Protec-

tion Agency, and data on derogation farm location, provided by the Danish Ag-

ricultural Agency.

5.1

Introduction

Prior to 2018, data on water quality in the derogation report was based on data from the na-

tional agricultural catchment monitoring program. This program combines detailed information

on both agricultural practice and crop rotation as well as data on water quality in root zone wa-

ter, uppermost groundwater and small local streams. Monitoring takes place in five agricultural

catchments throughout the country, of which three are located in parts of Denmark character-

ized by loamy soils and two in the western part, where sandy soils predominate. The latest,

relevant results from the program are reported in chapter 4 of this report.

Due to the limited size of the area monitored within the national agricultural catchment moni-

toring program, only very few derogation farms are located in the five catchments. The major-

ity of derogation farms are found in the western part of Denmark, especially in the western part

of middle and southern Jutland, as shown on the maps in chapter 2 of this report. This part of

Denmark is also characterized by pre- dominantly sandy soils.

The derogation decision from 2017 (2017/847/EU) introduced the requirement that water qual-

ity should be reported using data from reinforced monitoring. The reinforced monitoring is car-

ried out on sandy soils and in an area that comprises fields belonging to at least 3% of all der-

ogation farms. The derogation decision from 2018 (2018/1928/EU) and the latest derogation

decision from 2020 (2020/1074/EU) specifies in Article 10 (2) that, in addition to the monitoring

obligations in prior derogation decisions,

"[...] Reinforced monitoring of water quality shall be

carried out in areas with sandy soils. In addition, nitrates concentrations in surface and

groundwater shall be monitored in at least 3 % of all holdings covered by an authorisation."

5.2

Method

Selection of relevant monitoring stations

Besides the results from the national agricultural catchment monitoring program (see chapter

4), which previously has formed the basis for annual reporting according to the derogation de-

cision, Danish authorities also collect data through a number of other national monitoring pro-

grams. As part of the “National Monitoring Program of Water and Nature” (NOVANA), data

from approximately 500 water quality stations in streams and rivers are collected several times

annually.

The primary purpose is to determine nutrient loads to sensitive recipients, i.e., coastal waters

and lakes. Water samples from more than 1,000 groundwater monitoring stations are analyzed

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once a year; according to the monitoring and reporting requirements of the Nitrates Directive

and the Water Framework Directive. One of the usual parameters that both groundwater and

surface water samples are analyzed for is nitrate concentration.

Simultaneously, the Danish Agricultural Agency registers which fields belong to derogation

farms.

The approach is based on the identification of either surface water or groundwater monitoring

stations located in close proximity to a field belonging to a derogation farm. More precisely, the

GIS-analysis is based on the coordinates of the surface water or groundwater monitoring sta-

tion as well as the surrounding area within a fixed 15-metre radius. This circle allows for an

overlap between the position of the monitoring station and any fields in close proximity.

Only watercourse and groundwater monitoring stations located within 15 meters of a field reg-

istered to a derogation farm are selected. To determine whether this criterion is met, the latest

registry data from the Danish Agricultural Agency is used.

If a groundwater monitoring well fulfils the location criterion but contains several monitoring

stations at different depth (“multi-filter wells”), only one of these stations is selected; typically,

the station that has the largest number of prior nitrate concentration samples.

Groundwater monitoring stations at a depth of 80 meters or more have been excluded from

the data set, as data from the national groundwater monitoring (“GRUMO”) program shows

that nitrate levels are no longer quantifiable (<1 mg/L) at these depths.

Only surface water monitoring stations that are part of the national program monitoring

“Transport of nutrients in streams” have been considered for the reinforced monitoring. A few

mobile stations used for lake monitoring that would have fulfilled the proximity criterion have

been excluded from the data set, as their locations typically change every year, making it im-

possible to create time series. Monitoring stations that have been installed in watercourses to

monitor the outflow from constructed wetlands have also been excluded.

In all, this selection method has identified a total of 33 monitoring stations. 17 stations of these

(51 %) are groundwater monitoring stations, while 16 stations (48 %) are located in water-

courses (Figure

5.1).

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FIGURE 5.1 Map showing the locations of the 33 monitoring stations selected as the re-

porting basis for the reinforced monitoring. The squares show the location of in total 17

groundwater monitoring stations at different depths – these may overlap due to the

scale of the map. The circles show the location of the 16 watercourse monitoring sta-

tions. Grey shading indicates all fields belonging to Danish derogation farms.

The majority of derogation farms are located in the western part of Denmark, especially the

western, northern and southern parts of the peninsula of Jutland, also illustrated in chapter 2

of this report. These parts of the country are characterized by sandy soils, whereas loamier

soils dominate the more eastern parts of the country.

Consequently, the described approach of linking the locations of monitoring stations to fields

belonging to derogation farms results in a considerable enlargement of the data basis for re-

porting of water quality in sandy areas.

The geological map in

Figure 5.2

below illustrates the soil substrates throughout Denmark.

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FIGURE 5.2 Geological map of Denmark showing the substrates that are the basis for

soil development. Modified from a map produced by GEUS. The legend is only available

in Danish, but the four main soil substrate types that can be categorized as “sand” have

been marked with an “S” in the legend.

Coverage of Danish derogation farms

The locations of the 33 monitoring stations have been linked to 40 fields, which in turn belong

to 33 different derogation farms. Out of the 33 farms, 16 are subject to the reinforced monitor-

ing due to the proximity of their fields to a watercourse monitoring station, while 17 farms are

included owing to proximity to groundwater monitoring stations. One farm was included due to

proximity to both a watercourse and a groundwater monitoring station. The total number of

farms encompassed by the reinforced monitoring corresponds to 3.3 % of all holdings that

make use of the derogation.

5.3

Characterization of monitoring stations and data analysis

Groundwater

The selected groundwater monitoring stations are located at depths below the surface ranging

from 1.75 m to 72 m. The majority of the stations monitor water quality in comparatively shal-

low groundwater, at an average depth of 24.26 m and a median depth of 18 m. Of the selected

groundwater monitoring stations, 29 % of the samples are of very shallow groundwater from a

depth of less than 10 m. 24 % are located from 10-20 meter below surface and the rest 47 %

of the stations are located from 20-80 meters.

Groundwater monitoring stations are expected tobe sampled at least once per year.

Historic data since 2002 – the year Denmark obtained a derogation from the Nitrates Directive

for the first time – have been included to the extent that they are available. If groundwater has

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been sampled more than once per year, the average annual nitrate concentration has been

calculated for this station for each respective sampling year.

For the purpose of presenting the data in the results section below, the stations have been

grouped into three different categories, stations at a depth of less than 10 m below surface,

stations at 10 to almost 20 m depth and stations at 20 m depth or deeper. Annual average ni-

trate concentrations have been calculated for each depth category for each year since 2002,

based on the actual number of stations sampled in the respective year.

Surface water

The monitored watercourses vary considerably in size and flow rate. The widths of the water-

courses at the monitoring station vary from 2 m to 10.5 m. 7 out of the 16 stations are located

in small streams of less than 5 meters’ width.

Samples from watercourses are generally analysed for Nitrite- and Nitrate-Nitrogen

(N). Nitrite-N-concentrations are typically negligible, and under this assumption, nitrate con-

centrations in the water samples could be calculated by multiplying the Nitrate-N concentration

by a factor of 4.4268. In this chapter, the surface water concentration is generally given in Ni-

trite- and Nitrate-Nitrogen. Historic data since 2002 is included to the extent that it is available.

Only data from monitoring stations that have been sampled at least 9 times annually in the pe-

riod before 2017 are displayed in the results. In 2020, each watercourse monitoring station has

been sampled more frequently, from 16 to 18 times annually.

For the purpose of presenting the data in the results section, stations have been grouped

based on the approximate width of the water course at the sampling station site into three dif-

ferent categories, as also displayed in

Figure 5.1:

less than 5 m, 5 to 10 m and more than 10

m width. Average nitrate concentrations have been calculated for each category for each year

since 2002, based on the actual number of stations sampled in the respective year.

As a consequence of the political agreement on the Food and Agricultural Package from De-

cember 2015, the number of water course monitoring stations has been significantly in-

creased. 9 out of the 16 water course stations selected for the reinforced monitoring were es-

tablished in 2016 as a consequence of the agreement, and now, it is decided to continue the

monitoring.

5.4

Results and Discussion

Groundwater

Figure 5.3

shows the nitrate concentration of each groundwater monitoring station selected for

reinforced monitoring, as well as the average nitrate concentrations per sampling year for the

period 2002 to 2021 for each of the depth categories. The quality limit value of 50 mg nitrate

per liter is also shown.

The data generally shows great variability in nitrate concentrations from one year to another in

water samples from individual monitoring stations. Especially in the shallowest groundwater

(Figure

5.3A),

absolute concentration changes of up to more than 80 mg nitrate per liter can

be observed from one sampling year to the other.

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FIGURE 5.3 Nitrate concentration of the individual groundwater monitoring stations se-

lected for the reinforced monitoring, as well as the average nitrate concentrations per

sampling year for the period 2002 to 2021 for each of the three depth categories of

groundwater stations: (A) stations at less than 10 m depth; (B) stations at 10-20 m

depth and (C) stations at 20 m depth and deeper below the surface. A red dashed line at

50 mg nitrate per liter is inserted in each figure.

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No clear trend in the average nitrate concentration can be observed over time for any of the

three depth categories. Due to the limited number of stations and samples per year, the an-

nual average values are highly influenced by the variability in nitrate concentration in the water

sampled from some individual stations.

Table 5.1

shows the average nitrate concentration of all stations for each year in the period

2002 to 2021, irrespective of their depth and the number of stations sampled

(n) in the respective year that form the basis of this calculation. The annual average nitrate

concentration varies between 20.9 mg/L, as sampled in 2003 (n=11), and

41.9 mg/L in the groundwater samples from 2009 (n=13).

TABLE 5.1 Annual average nitrate concentration of all groundwater stations in rein-

forced monitoring in the period 2002-2020 and number of stations sampled

Sampling year

Average nitrate concen-

tration [mg/L]

29.2

20.9

27.0

37.0

38.1

37.8

32.1

41.9

40.7

28.7

28.8

29.2

28.8

35.1

35.2

31.9

30.5

26.9

27.2

28.9

Number of sampled sta-

tions (n)

2002

2003

2004

2005

2006

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

2017

2018

2019

2020

2021

When calculated across the entire period from 2002 to 2021, the (non-weighted) mean value

of the annual average concentrations is 31.9 mg/L. The 2021 average is lower than the mean

value for the whole 2002-2021 period.

Surface water

Figure 5.4

shows the Nitrite- and Nitrate-Nitrogen concentration of the individual watercourse

monitoring stations selected for reinforced monitoring, as well as the average nitrate concen-

trations per sampling year for the period 2002 to 2021 for each of the width categories. The

quality limit value for groundwater of 50 mg nitrate per liter, which corresponds to approxi-

mately 11.3 mg Nitrate-N per liter, is also shown.

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Figure 5.4 : Nitrite- +Nitrate-Nitrogen (N) concentration of the individual surface water

monitoring stations selected for reinforced monitoring, as well as the aver- age nitrate

concentrations per sampling year for the period 2002 to 2021 for each of the three width

categories (determined at sampling site): (A) less than 5 m wide; (B) 5 to 10 m wide and

corresponding to approx. 50 mg nitrate per liter. The standard deviation in absolute

concentration are 1.81 mg/l.

At the level of the individual monitoring station, nitrite- + nitrate-N concentrations can vary sig-

nificantly from year to year mainly due to variation in amount and timing of precipitation. Nev-

ertheless, the year-to-year variations are not as pronounced as those seen in groundwater

samples.

For all watercourse categories it is, however, important to underline that the N transport is not

determined by the nitrogen concentration alone, but also by the water flow in the watercourse,

which can significantly vary due to the specific and local weather conditions of a given year. In

low flow rate situations, nitrogen levels may be relatively high while total N transport remains

unchanged, and vice versa. As smaller watercourses typically have a smaller catchment

area than rivers, variations in local weather conditions are expected to have a greater impact

on the nitrogen concentration in water sampled from small watercourses.

For all individual watercourse-monitoring stations, nitrate-N concentrations remain well below

the quality limit for groundwater and drinking water throughout the whole period from 2002 to

2021. Absolute concentrations tend to be higher in the smaller watercourses than in the larger

ones, which is likely to be a result of nitrate being removed through natural processes along

the course of the water. Overall, the annual average for each category has been steadily de-

creasing over the last 10 years of the period shown.

Table 5.2

shows the annual average nitrite- and nitrate-N concentration in water sampled at all

water course stations – irrespective of their width – and the number of stations sampled in the

respective year (n).

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Table 5.2 Annual average nitrite- + nitrate-N concentration in water sampled at all sta-

tions selected for reinforced monitoring, as well as the number of stations sampled in

each year.

Sampling

year

2002

2003

2004

2005

2006

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

2017

2018

2019

2020

2021

Average nitrite- +nitrate-N

concentration [mg/L]

4.1

3.8

4.4

4.0

4.4

4.1

3.9

3.8

3.3

3.4

3.3

3.0

2.9

3.3

3.4

Number of sampled

stations (n)

The annual average nitrite- + nitrate-N concentration has decreased from 4.4 mg/L in the early

years of the reported period (e.g. 2006, n=10) down to 3.3 mg/L in 2016 (n=11). Since 2017, 9

additional watercourse-monitoring stations have been established, improving the data basis

significantly. Hence, it is now possible to follow the development in watercourses, which have

been equipped with new monitoring stations as a consequence of the political agreement on

the Food and Agricultural Package from December 2015. Despite the significant increase in

number of monitoring stations, which are considered in the reinforced monitoring, the average

nitrite- + nitrate-nitrogen concentrations for the different water course categories remains fairly

constant. The average concentration in 2021 for all watercourse stations was 3.4 mg/L.

General discussion

It is important to highlight that the reinforced monitoring does not provide data that can be

used to examine any potential effect on water quality that might be the result of the use of the

derogation. A range of other fluctuating factors influence nutrient concentrations in the aquatic

environment, and as such, it would not be possible to identify or isolate such an effect.

Because the reinforced monitoring method is based on linking the locations of monitoring sta-

tions to fields belonging to derogation farms in a two-dimensional way: The approach does not

account for the actual catchment area and subsurface water paths for the respective monitor-

ing stations. Hence, it is only to a very limited degree possible to get a picture of the effects of

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land use on surface water and groundwater quality. A clearer picture would require a catch-

ment-based approach, which takes into account that water quality in the recipient water is af-

fected by land use in the whole catchment area.

The present method does not include a reference group of monitoring stations that are not lo-

cated in proximity to fields belonging to derogation farms. However, by including the data from

this selected set of the surface water and groundwater monitoring stations, the data basis for

water quality in sandy areas has been considerably enlarged from the two sandy catchments

within the national agricultural catchment monitoring program (see chapter 4), which formed

the basis for reporting prior to 2018 and still provides comprehensive data on land use at farm-

level.

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6. Indicator and monitoring

system for application of

phosphorus in Denmark

Ministry of Environment of Denmark

6.1

Introduction

In consultation with the European Commission, the Ministry of the Environment and Food

(since November 2020 the Ministry of Environment) has agreed that Denmark must monitor

the use of phosphorus (P) in organic fertilizer and commercial fertilizer, so that it is ensured

that the average use does not exceed the national phosphorus ceiling. The monitoring is

based on data from the fertilizer accounts, which is available approximately one year after a

planning period is completed, when the farmers submit their fertilizer accounts to the Danish

Agricultural Agency. The first planning period with limiting phosphorus use by specific ceilings

at farm level was 2017/2018.

As a supplement to monitoring, it has been agreed that an "indicator system" must be estab-

lished, where data from the NOVANA monitoring program in Agricultural Catchments (LOOP)

in combination with available data on livestock production and sales of fertilizer and other

phosphorus sources can provide an updated overview of the average amount of phosphorus

used in Danish agriculture.

These results from the P monitoring and indicator system, respectively, should be compared

with the phosphorus ceilings. In this connection, it was agreed, that the total amount of phos-

phorus used should be divided by the total agricultural area in order to calculate the average

fertilizer rate per year per ha on agricultural land. No requirement has been set for the first

planning period 2017/2018, but in the planning period 2018/2019 the average use should be

below 34.7 kg P/ha, and in the planning period 2019/2020 the average use should be below

34.1 kg P/ha. In the planning period 2020/2021 and planning period 2021/2022 the average

use must be below 33.2 kg P/ha. If the average use exceeds 33.2 kg P/ha, the phosphorus

ceilings must be lowered.

6.2

Results from the P monitoring system

The Danish Agricultural Agency compiled data from the fertilizer accounts with data from the

planning period 2020/2021. The compiled data has not been processed or checked thoroughly

for exorbitant values and other "noise", e.g. typos. If there are exorbitant values, it is estimated

that only extremely high values in a few fertilizer accounts can have an important influence on

the overall results, so the results represent a “worst case” scenario of phosphorus use.

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Table 6.1 Compiled data from fertilizer accounts 2020/2021 (rounded numbers).

Produced P

(tons)

Poultry/fur

Finishers

Sows and piglets

Cattle (non-derogation)

Cattle (derogation)

Manure – Total

Waste and other P

Manure + waste

Chemical fertilizers

Used P – Total

3,400

10,600

8,600

11,300

6,800

40,800

40,500

3,300

43,800

15,100

58,900

Mio. ha

Agricultural area

Harmony area

The average national phosphorus ceiling in

2020/2021

Kg P/ha agricultural area

Kg P/ha harmony area

2,600

2,400

33.2

22.8

24.6

Used P

(tons)

6.3

Results from P indicator system

The following table shows the phosphorus inputs as reported in the NOVANA report "Land

Surveillance Survival 2021" from December 2021

. The table shows an increase as expected

in the use of phosphorous in 2017, due to the increase in the P-ceiling from 2016 to 2017. In

the coming years the P-ceiling will be decreased back to a lower level, so the increase in the

use of phosphorous is not expected to continue.

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Table 6.2 The use of P-input in Danish agriculture in 2013-2021

2013

Use of P (1,000 tons)

in different inputs:

- Chemical fertilizer

- Livestock manure

- Seed

- Sludge

- Waste from industry

- Other organic ferti-

l lizer

- Deposition

Total use of P

Agricultural area

(1,000 ha)

Kg P/ha in average

Kg P/ha (the average

national P-ceiling )

0.3

63.4

2,671

23.7

0.3

65.9

2,661

24.7

0.3

66.2

2,633

25.1

0.3

64.4

2,625

24.4

[32.2]

2014

2015

2016

2017

2018

2019

2020

2021

11.3

45.3

1.0

2.4

3.1

13.0

46.1

1.0

2.4

3.1

13.3

46.1

1.0

2.4

3.1

13.3

44.3

1.0

2.4

3.1

20.8

43.0

1.0

2.4

3.1

14.8

44.3

1.0

14.6

44.9

1.0

16.0

43.8

1.0

14.9

43.8

1.0

2.8

0.3

70.5

2,610

27.0

0.3

63.2

2,602

24.3

34.1

3.1

0.3

63.9

2,613

24.4

34.1

3.1

0.3

64.3

2,613

24.1

33.2

3.1

0.26

63.2

2,600

22.8

33.2

In the dialogue with the EU Commission, it was expected that the development in livestock

production should be monitored via data from the CHR register, since Denmark previously pre-

pared an annual status on the size of livestock production in various catchments. This annual

status is now done instead on the basis of the fertilizer accounts, which is why the best data

material on the development in livestock production is the annual status of the livestock popu-

lation, which is made by Statistics Denmark. Statistics Denmark's information on livestock in

2017-2021 can be seen in

Table 6.3.

Source: Blicher-Mathiesen et al. (2022): Landovervågningsoplande 2021. Aarhus University.

From 2018 onwards, amount of other organic waste, such as sludge and waste from industry, is derived

from the fertilizer accounts.

Agricultural area for the years 2016, 2017 and 2018 has been updated after submission of the Deroga-

tion Report 2019.

This figure indicates the average phosphorus protection level in 2016 expressed as a theoretical P-ceil-

ing, before the P-ceilings were introduced, and is included for comparison.

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Table 6.3 The development in the livestock production according to Statistics Denmark

in 2017, 2018, 2019 and 2020

Number

Number of

animals

2017

Number of all

kinds of cattle

and dairy cows

on all farms

Number of all kinds

of pigs on all farms

Number of all kinds

of poultry on all

farms

Number of all kinds

of mink on all farms

3,429,472

3,379,931

2,489,751

2,234,101

-100

21,483,698

19,973,164

23,059,881

22,132,858

21,891,757

1.90

12,307,667

12,781,247

12,298,993

13,162,627

13,168,466

Number of

animals

2018

Number of

animals

2019

animals

2020

Number

animals

2021

% change in total

number of animals

2017-2021

1,545,417

1,540,446

1,491,433

1,498,713

1,488,421

-3.69

6.99

The manure production based on data from the fertilizer accounts shows that 8 % of the total

manure production comes from poultry, 47 % from pigs and 45 % from cattle. The amount of

mink presented in the table, is the number of mink before termination. In November 2020, all

mink in Denmark were ordered to be terminated, as they were classified as a possible health

risk with regard to the spread of Covid 19

There are no signs that indicate that a considerably larger amount of livestock manure will be

produced in 2022, and that the average phosphorus application in Denmark will exceed 25-28

kg P/ha, as the phosphorus ceiling from 2018 onwards will be reduced continuously. This level

will be well below the average phosphorus ceilings of 34.7 kg P/ha in 2018, 34.1 kg P/ha in

2019, 33.2 kg P/ha in 2020 and 2021 and further reductions set for 32-33 kg P/ha in 2022 and

30-31 kg P/ha in 2025.

Data from Statistics Denmark: for cattle, pigs, poultry and mink: https://www.statistikbanken.dk/10472

https://www.ft.dk/samling/20201/almdel/mof/bilag/131/2284052.pdf

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7. Targeted catch crops

scheme and targeted

nitrogen regulation

Kari Lundsager and Marie Dam, The Danish Agricultural Agency, Ministry of

Food, Agriculture and Fisheries of Denmark, October 2020. Updated by Laurits

Hesselager, The Danish Agricultural Agency, Ministry of Food, Agriculture and

Fisheries of Denmark, October 2021

As part of the political agreement on the Food and Agricultural Package of December 2015,

the reduction of the nitrogen application standards was removed. It was also agreed to de-

velop a new nitrogen regulation, the “targeted nitrogen regulation”, which was to be imple-

mented in 2019.

The Danish government introduced an intermediate initiative, the “targeted catch crops

scheme”, to reduce N-losses through promoting the establishment of additional catch crops in

2017 and 2018. The scheme was designed to protect both groundwater bodies and coastal

waters. The scheme was targeted by assigning different requirements of nitrogen reductions

for different water catchment areas, based on the calculated needed effort within each

area.The scheme consisted of a voluntary phase, where farmers applied for participation in the

scheme, and a subsequent mandatory requirement for catch crops if the voluntary scheme did

not reach the predefined targets within each catchment area. The latter requirement was un-

compensated whereas the voluntary part was compensated with de minimis support.

In November 2017, a political agreement for targeted nitrogen regulation was reached and

would be implemented from 2019. The targeted nitrogen regulation is similar to the targeted

catch crops scheme in many ways. The most significant difference is the introduction of the

possibility to use alternative measures to catch crops. Conversion factors are used to secure

that the alternatives have the same effect as catch crop. Like the targeted catch crops

scheme, the targeted nitrogen regulation is divided into a voluntary and a mandatory part. The

targeted nitrogen regulation was subsidised by de minimis in 2019 and by RDP funds in 2020

and 2021.

After the application deadline in the voluntary crop scheme, the farmer is bound by any com-

mitment made, either through catch crops or alternatives, as well as by any additional catch

crop requirement imposed through the mandatory round. The farmer will not be able to opt out

of any of these requirements without consequences. The voluntary and obligatory targeted

catch crops or alternatives must be additional to the national mandatory requirement for catch

crops on 10.7 or 14.7% of the farm’s crop base area, and they cannot be established on the

same area used for catch crops to meet the EFA requirement under direct payments.

If the farmer opts out afterwards or non-compliance is detected during control, the nitrogen

quota for the farm (calculated on the basis of the composition and distribution of crops and the

soil and crop-specific nitrogen standards) is reduced corresponding to the non-compliance

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with the voluntary and/or mandatory requirement and according to a conversion factor be-

tween the nitrogen reduction effect of catch crops and the nitrogen quota reduction for the

planning period. This quota reduction will contribute to meeting the objectives of the Nitrates

Directive. Furthermore, if the reduced nitrogen quota is exceeded, the farmer will be in breach

of the Fertilizer Act and will be sanctioned accordingly cf. Annex III point 1.3 of the Nitrates Di-

rective.

This is similar to the current practice for the general catch crop requirements and additional

catch crop requirements for holdings using organic manure.

In 2019, the targeted nitrogen regulation contributed to a nitrogen reduction of 1,174 tons in

coastal waters, including reductions of nitrogen leaching to the groundwater. Further, in 2019,

it was decided by political agreement to increase the effort of the targeted nitrogen regulation

in 2020 for additional contribution to meet the objectives of The Water Framework Directive. In

2020, the targeted nitrogen regulation will thus contribute to a nitrogen reduction of 3,514 tons

in coastal waters. In 2021, the targeted nitrogen regulation contributes to a nitrogen reduction

of 3,514 tons in coastal waters plus an additional 4 tons postponed from the previous year.

7.1

Results from 2017 to 2021

Prior to 2017 and 2018, respectively, the ministry calculated the need for further nitrates efforts

for each of the years, which can be expressed as the amount of additional catch crops re-

quired in the individual water catchment areas, in terms of hectares and as a percentage of the

crop base area. The calculation is based on the estimated need for reductions in the nitrates

contents of groundwater bodies and coastal waters, adjusted by the estimated soil nitrates re-

tention in the water catchment area. In 2019 and 2020, the targeted nitrogen regulation was

dimensioned to comply with the Danish implementation of The Water Framework Directive.

In 2017, the need for further nitrogen efforts was calculated to 137,560 ha. By the application

deadline, the farmers had applied for a total of 144,220 ha of catch crops. However, the geo-

graphical distribution of the catch crops was not optimal in relation to the efforts needed. Cal-

culations revealed that an additional 3,253 ha catch crops were needed in order to reach the

target. It was decided politically to postpone the residual effort until 2018.

In 2018, the need for further nitrogen effort was calculated to 114,300 ha catch crops (includ-

ing the postponed 3,253 ha). By the application deadline, the farmers had applied for a total of

105,000 ha of catch crops. It was furthermore decided to postpone the effort related to aqua-

culture (fish farming, mariculture, etc.), as extensions of existing aquaculture facilities had not

been approved. Calculations revealed that an additional 3,000 ha catch crops were neverthe-

less needed in order to reach the target. This has been implemented as a mandatory uncom-

pensated requirement in 2018.

In 2019, the need for nitrogen efforts in targeted nitrogen regulation was calculated to 138,200

ha of catch crops. By the application deadline, the farmers had applied for 139,350 ha of catch

crops (and alternatives). Calculation revealed that an additional 275 ha were needed to reach

the set effort. The reason was the geographical distribution of the catch crops, which was not

optimal. It was decided politically to postpone this insignificant residual effort to 2020.

In 2020 the need for nitrogen efforts in targeted nitrogen regulation was calculated to 373,000

ha of catch crops and included the residual effort from 2019. By the application deadline, the

farmers had applied for 370,000 ha of catch crops (and alternatives). Some applications had to

be dismissed, as the set effort for the individual water catchment areas was already reached.

A total of 349,400 ha was approved for the voluntary phase. Calculations of the geographically

specific retention disclosed that an additional 12,493 ha were needed to reach the set national

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nitrogen reduction effort. Consequently, this was implemented as a mandatory uncompen-

sated requirement in 2020. Excluding a minor residual effort of 350 ha of catch crops, which

was decided politically to postpone.

In 2020, the need for nitrogen efforts was calculated to 3,518 tons of nitrogen, which included

4 tons of residual effort postponed from the previous year. That corresponded to 373,600 ha of

catch crops. By the application deadline, the farmers had applied for 359,200 ha of catch

crops and alternatives. Due to suboptimal geographical placements of the catch crops in rela-

tion to the needed efforts in the individual water catchments areas, some applications had to

be rejected. Some water catchment areas had too many applications, while in other areas the

applications did not meet the required nitrogen targets. A total of 351,800 ha was approved. It

was calculated that an additional effort corresponding to a total of 17,200 ha was needed to

meet the national nitrogen effort goal. This remaining effort was implemented as a mandatory

uncompensated requirement in 2021.

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8. Conclusions

8.1

Cattle holdings and controls on farm level

In the planning period 2020/2021, a total of 945 cattle holdings made use of the derogation.

This corresponds to 3.0 % of the total number of agricultural holdings in Denmark. These hold-

ings spread 32.9 million kg N corresponding to 14.5 % of the total kg N spread. The arable

land encompassed by the derogation in year 2020/2021 was 163,732 hectares corresponding

to around 6.8 % of the total arable area. Compared to the previous reporting period, in

2020/2021 there has been a decrease in the number of farms and the number of hectares en-

compassed by the derogation. The average livestock size was 44,069 kg N produced pr. hold-

ing in 2020/2021.

In January – February 2022, 70 inspections of compliance with the derogation management

conditions were carried out. 67 of these inspections were closed without remarks, and three

were closed with remarks.

For the year 2019/2020, 79 inspections (0.2 % of all Danish holdings) at the holding were

made concerning compliance with the harmony rules (amount of livestock manure applied per

hectare). 76 of the inspected farms used the derogation. 65 of these inspections were closed

without remarks. Three holdings were closed with remarks. 8 holdings are still under investiga-

tion.

All 32,164 fertilizer accounts submitted in 2019/2020 (100 %) were automatically screened by

the IT-system according to normal procedure. Of these, 634 (2.0 %) were subject to adminis-

trative control or administrative inspections. In all, 112 of these holdings used the derogation.

Of the inspections of derogation farms, 86 (76.8 %) were closed without remarks, 7 (6.3 %)

were closed with remarks and 19 (17.0 %) are still under investigation.

In total, approximately 7.0% of derogation farms were selected for physical inspections. In to-

tal, more derogation farms have been subject to controls due to the aforementioned adminis-

trative inspections. As holdings are automatically selected - based on a previously agreed set

of risk criteria - for both physical inspections and administrative inspections, the Danish Agri-

cultural Agency has no direct influence on the share of holdings using the derogation that are

inspected each year. Therefore, the share of derogation farms that in some way has been sub-

ject to controls varies from year to year.

8.2

Agricultural practices and water quality

Conclusions

In 1998 the Action Plan for the Aquatic Environment (APAE) II was accepted by the EU Com-

mission as the Danish Nitrate Action Plan implementing the Nitrate Directive (1998-2003). In

2003, a final evaluation of Action Plan II was performed, showing a reduction of 48% of the ni-

trate leaching from the agricultural sector, fulfilling the reduction target set in 1987.

Further mitigation measures were implemented in the following Action Plans. The APAE III

from 2008 were implemented to reduce N leaching from the root zone and the Green Growth

Agreement from 2009. Hence, the first and second River Basin Management Plan from 2014

and 2016, respectively as well as the Food and Agricultural Agreement in December 2015

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suggests mitigation measures and reductions target for N load to marine areas in order to fulfil

the targets in the Water Framework Directive.

Modelling

of the nitrate concentrations in the soil water leaving the root zone at national level

showed an average concentration of 71-85 mg NO

-1

for cattle holdings using 170-230 kg or-

ganic manure N in 2021 and the concentrations were 2-6 mg NO

-1

higher for derogation

farms than for cattle farms using 140-170 kg N ha

-1

of N in manure and other organic fertilis-

ers.

Measured

average flow-weighted nitrate concentration in root zone water at six specific sites

with an average manure application within 170-230 kg N ha

-1

during the last 10 years varied

between 77 and 128 mg NO

-1

for the recent five hydrological years (2016/17-2020/21). Thus,

there was no clear difference in flow-weighted nitrate concentration between monitored fields

with application of 130-170 kg N ha

-1

and 170-230 kg N ha

-1

in manures. Phosphorus concen-

trations in the water leaving the root zone varied in general between 0.005 and 0.050 mg PO

P l

-1

, irrespective of the amount of applied organic manure.

The general conclusions to be drawn on trend in measured nitrate concentrations in

root zone water and upper oxic ground from the Agricultural Catchment Monitoring Pro-

gramme are that:



Nitrate concentrations in root zone soil water (1.0 m below soil surface) have decreased

steadily from 1990/91 to 2015/16. On loamy catchments the measured nitrate concentration

decreased from 61-155 mg NO

-1

in the five-year period 1990/91 to 1994/95 to 37-66 mg

-1

in the five-year period 2011/12 to 2015/16. On sandy catchments the nitrate concen-

tration was 73-207 mg NO

-1

in the five-year period 1990/91 to 1994/95 and decreased to

54-73 mg NO

-1

in the five-year period 2011/12 to -2015/16. High annual variation was

measured after 2015/16 until 2020/21, 50-115 mg NO

-1

on loamy soils and 61-113 mg

-1

on sandy soils with the highest concentrations in years with low precipitation and

subsequent percolation and lowest concentrations in years with high precipitation and sub-

sequent percolation as seen in 2019/20.



Average annual nitrate concentrations in the upper oxic groundwater (1.5-5.0 m below soil

surface) are well below the limit of 50 mg NO

-1

for loamy catchments since 1990/91 and

at 54-77 mg NO

-1

for sandy catchments in the 5-year period 2016/17 to 2020/21.

8.3

Targeted catch crops and targeted nitrogen regulation

For the year 2017, a total of app. 144,000 ha voluntary targeted catch crops were established,

and a further effort of 3,250 ha were postponed to 2018. In 2018, a total of app. 105,000 ha

voluntary catch crops were established, and in addition a mandatory effort of app. 3,000 ha

has been applied (uncompensated). In 2019, first year of targeted nitrogen regulation, a total

of 139,350 ha voluntary catch crops (or alternatives) were established, a further effort of 275

ha was postponed. In 2020, the targeted nitrogen regulation continued with a total of app.

349.400 ha voluntary catch crops established, and an additional mandatory effort of app.

12,500 ha applied (uncompensated). A further effort of 350 ha was postponed. In 2021, tar-

geted nitrogen regulation continued with a total of 359,200 ha of catch crops and alternatives

applied for in the voluntary phase. Of those, 351,800 ha catch crops and alternatives were ap-

proved, and a further 17,200 ha was applied through an uncompensated mandatory effort.

8.4

The reinforced monitoring

The reinforced monitoring does not provide data that can be used to examine any potential ef-

fect on water quality that might be the result of the use of the derogation. A range of other fluc-

tuating factors than proximity to a derogation farm influence nutrient concentrations in the

Ministry of Environment of Denmark / Nitrates Directive / Derogation Report 2022

MOF, Alm.del - 2022-23 (2. samling) - Bilag 466: Årlig rapport til EU-Kommissionen om den danske undtagelse fra nitratdirektivet

aquatic environment. However, by including the data from the selected set of the surface water

and groundwater monitoring stations, the data basis for water quality in sandy areas is consid-

erably enlarged. The total number of farms encompassed by the reinforced monitoring corre-

sponds to 3.3 % of all holdings that make use of the derogation.

8.5

The phosphorus indicator and monitoring system

Neither the phosphorus indicator nor the P monitoring system indicate that the average phos-

phorus application in Denmark exceeds the average phosphorus ceiling of 33.2 kg P/ha. There

is currently also no risk for exceeding future P-ceilings, which are reduced compared to current

level.

Ministry of Environment of Denmark / Nitrates Directive / Derogation Report 2022

MOF, Alm.del - 2022-23 (2. samling) - Bilag 466: Årlig rapport til EU-Kommissionen om den danske undtagelse fra nitratdirektivet

Ministry of Environment

of Denmark - Departement

Slotsholmsgade 12

DK - 1216 Copenhagen K