NAP proposals threaten to wreck NI farming as economic analysis reveals £1.56 billion annual cost
The Ulster Farmers Union conducted an independent economic analysis into the Nutrients Action Programme (NAP) proposals.
It was initiated by the Ulster Farmers’ Union and Northern Ireland agri-food stakeholders, and was conducted by AgriSearch confirming that the phosphorus (P) balance limits for 2026–2029, particularly the 8kgP/ha threshold and the imposition of buffer strips on arable land, would inflict irreparable harm on Northern Ireland’s farming industry.
The report launched yesterday outlines that the impact could exceed a staggering £1.56 billion and concludes that this will result in:xa0
- Widespread economic disruptionxa0across the agri-food sector and the wider economy, with projected losses exceedingxa0£1.56 billion per annum.
- Limit the resilience and competitiveness of the Northern Ireland family farm.xa0Improved productivity was one of the four key policy objectives of DAERA.xa0This could further exacerbate the economic gap between the farm and non-farm economy – rural and urban communities and act as a further disincentive for young people to enter farming.
- Severe financial strain on farm businesses,xa0many of which are already carrying significant debt burdens.
- Destabilisation of the land market,xa0with increased competition for land likely to disadvantage smaller and less intensive farms and non-livestock farms.
- Threats to supply chain resilience,xa0as reduced livestock numbers could render processing facilities economically unviable.
- Wider impact on rural communitiesxa0dependent on the agricultural sector for economic activity.
- Further weaken the food securityxa0and food sovereignty of the United Kingdom by reducing domestic production and increasing reliance on imported produce.

Commenting, UFU president William Irvine said: “The findings from this interim economic analysis into the NAP proposals are utterly dire.
“This report shows that these two proposals alone would decimate family farms.
“The financial impact following the implementation of the 10kg and 8kg/ha P balance and buffer strips would force drastic livestock cuts or significant land acquisition, both of which are economically unsustainable for many family farms.xa0
“For arable, potato and vegetable growers, they would lose an average of 2% of land to the mandated three metre buffer strips which would be required alongside water courses.
“That’s a significant area of productive land, having a huge impact on the farm’s viability whilst also adding more unnecessary and burdensome red tape.”
The NI agri-food sector is calling out DAERA for their failure to carry out a full and proper economic analysis.
“It’s disgraceful and frankly inexcusable that DAERA did not properly investigate and assess the consequences of these proposals before they were put forward.
“DAERA should never be allowed to release a major policy proposal without proper economic assessments being carried out.xa0
“Our study may have a narrow focus due to time constraints, but it very clearly illustrates unacceptable costs across all sectors. Our collected data shows no sector would get out unscathed by these NAP proposals, and underscores DAERA’s appalling failings and a lack of care to properly understand the impact of their policy decisions.
“The department is meant to be supporting farm families to become more sustainable and deliver more for the environment while producing the food we all need.
“Instead, DAERA has risked the future of farm families and local food production, with the potential of destroying NI’s rural economy.xa0
“A stakeholder task and finish group will be set up after the current NAP consultation closes, guided by the feedback submitted. Individual responses from the farming community are absolutely vital. We are now fighting for survival.
“I urge everyone to submit a personal and unique response by Thursday 24 July, to help us prevent these NAP proposals becoming policy. We need to all chip in, helping to shape the future direction of NAP and demanding much-needed change, because so far on this NAP journey DAERA has failed us significantly,” said Mr Irvine.xa0
- To view AgriSearch interim economic impact assessment of proposed measures within DAERA’s Nutrients Action Programme 2026-2029, go to:
- https://agrisearch.org/news/industry-news/agrisearch-urges-rethink-on-nap-proposal-amid-billions-in-potential-agri~food-supply-chain-losses
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Farmers For Action Make A NAP Consultation Response
FFA say proposals highlight Ministers Inadequacy
Farmers For Action have set out their table and submitted their response to the current Nutrient Action Programme (NAP) Consultation.xa0
The FFa’s Sean McAuley said: “Our consultation response clearly highlights the shortcomings of Minister Muir and his top civil servant advisors, who are currently insisting on enforcement and flawed solutions, when the real answers are staring them in the face.xa0 It begs the question – why are they trying to avoid the obvious?”
FFA’s NAP Consultation response :
“Northern Ireland’s farmers have been increasingly influenced by the rise of extremely powerful corporate food retailers, corporate food wholesalers, corporate food processors and Government, this in turn has resulted in intensive demands from corporate food processors that supply those corporate food retailers and corporate food wholesalers.

“On a rising scale over the last 40 years large corporate food processors and Government in Northern Ireland have driven the agenda on many NI farms by creating and building on the belief that they (the farmers) would always be better off sticking with the intensive model.xa0
“This in turn has left many intensive farmers in a lot of debt and a few currently in a good position but only due to extreme market circumstances caused by those same food corporates driving many farmers out of business.
“In short, the background to the current surplus nutrients / run-off issue is the fault of the food corporates xa0and Government policy who have no intention of backing off with their demands.xa0
“The demand for food is obviously there, however, the supply system from Northern Ireland farms needs to change to deliver for the Nutrients Action Programme and ultimately the European Water Framework Directive.xa0
“Firstly, the supply of food from Northern Ireland farms must be properly paid for, meaning that the true of cost of production inflation linked plus a margin must legally be paid for all the different types of produce leaving NI farms and this can only be delivered by the Northern Ireland Farm Welfare Bill.xa0
“This Bill must be taken forward in Stormont under emergency legislation as the first step to the Minister being able to reach his European Water Framework Directive deadline – fast looming.xa0
“The additional dividend of this legislation is that there would be a musical chairs of farming activity in Northern Ireland, which would see a reduction in the extreme intensive farming sector, as delivery would be spread out over a lot more farms, but still deliver the same amount of food with even additional scope for bio-fuel production.
“The second action that must be taken immediately to create the change needed on a huge scale by the Department for Agriculture whose current proposals including enforcement are totally unacceptable; as a) they do not provide finance or knowledge for the proper distribution of surplus nutrients from intensive farms being transported to farms that are in a shortage situation.xa0
“The model must be that Northern Ireland uses all the nutrients that Northern Ireland farms need first and foremost and the surplus must be returned to the grain and oil seed supplying countries (such as Brazil) in the transport ships that bring in the 3million+ tonnes of imported grain and oil seeds to Northern Ireland annually – the logistics are possible just currently not being implemented.xa0
“This calculation alone puts Northern Ireland’s surplus nutrients back into balance, something which the Departments enforcement stick will not do and only result in pushing family farmers out of business and lead to increased factory farming.xa0
“At this point the Department must accept the fact that only one third of Northern Ireland farms have a connection to Lough Neagh.
“And due to their (those farmers) actions in recent years any nutrient leakage is diminishing – leaving NI Water, Department for Infrastructure and other industries responsible for the remaining surplus nutrients in plainer sight by the day.
“Of the remaining 2/3rds of farms in Northern Ireland not connected by waterways to Lough Neagh, only a fraction of these will have diminishing run-off issues – this in effect means that the Departments’ one shoe fits all’ is not acceptable, nor is their intention to enforce their version of nutrients leakage controls – as there is already in place legislation on any sort of pollution that occurs across Northern Ireland.
“Lough Neagh is now the Lough that is in the news in recent years with farmers getting more than their fare share of the blame for the green algae and now the halt on eel fishing, however, the intransigence of the Minister last year to accept a proposal by Farmers For Action for an international company that have a solution to seal the phosphorus on the bed of the Lough to come and give their opinion on how it would work was refused.xa0
“In short, a year has been lost and more time will be lost if the Minister and his top civil servant advisors do not change their direction of travel to one that has worked in numerous other countries across the world.”
Sean McAuley added: To conclude here is the ABC of Farmers For Action’s consultation response:-
- xa0The Northern Ireland Farm Welfare Bill must be put in place immediately by Stormont MLA’s to help Northern Ireland achieve the Water Framework Directive deadline.
- Millions of tonnes of surplus nutrients being created annually in Northern Ireland due to grain and oil seed imports must be returned to the original supplying nations, who clearly need those nutrients badly.
- The solution for Lough Neagh is available today, waiting on the Minister and his Department to implement it.
If the above is carried out then Northern Ireland’s family farmers can move forward in leaps and bounds delivering the new ideas and goals of a healthy agriculture in Northern Ireland including regenerative agriculture all of which will deliver the food required in harmony with the environment.








