Imagine you’re planning to drive into a ‘clean air zone’ (a common enough thing in UK cities these days). But to check you’re compliant and don’t have to pay a toll, rather than simply putting your reg number into a website that checks for you, you have to calculate your likely emissions against a specified limit, determined from: miles driven; speed driven; size and weight of car; engine type, capacity, and age; fuel type used, amount of fuel used, and octane content of fuel used, accounting for the effect of any additives (which must be lab-tested for your car at least once every five years); number and type of passengers, according to 43 categories, depending on their age, weight, sex, and fertility status; weather conditions on the day of travel and of the previous week, held against a 5-year average, including wind and rain, ambient temperature, etc.; quality of road surface; gradient of roads travelled and speed travelled at those gradients; etc., etc., etc.
It’s a complicated calculation and maybe not something you’d want to do yourself. But paying a professional to do it for you would cost many times more than the fine for non-compliance and hardly seems worth it.
Then again, the best available free resources for you to do this calculation yourself are some print-out PDF worksheets together with some online manuals (that run to hundreds of pages) and tables-of-values for reference, or else some very user-unfriendly software, all of which is deeply off-putting.
Perhaps you could avoid the ‘clean air zone’ entirely, but if you live in it you can’t help but drive in it. Further imagine that if you do not do this calculation (or do it but do it wrong) then you will get fined whether your journey is compliant or not, even if you have an electric car.
By analogy, that is essentially the situation for British farmers and ‘Nitrate Vulnerable Zone’ (NVZ) regulations.
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I’m trying to knock the rust off, having turned away from writing for a while.
Reality bit, and any time available to spend at a computer had to be dedicated to ‘practical’ matters: I sacrificed writing, Aztec-like, at the altar of something that might pay regular money, to keep the sun rising.
I’ve been working on the system for a new business doing ‘Nitrate Vulnerable Zone’ (NVZ) compliance paperwork.
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Approximately 55% of land in England is now ‘designated as being at risk from agricultural nitrate pollution’: i.e., NVZ. If you farm in an NVZ, to show compliance you must have the following paperwork updated every year (please feel free to skim the following because, while actually representing a shortened version, it’s comprehensive for rhetorical effect…you probably don’t need to know the details):
Stocking rate calculations to show that the total nitrogen produced by livestock on your farm doesn’t exceed 170kg/ha/yr, determined from DEFRA’s standard tables of values, which has 43 different categories for livestock and 14 categories of cattle alone, depending on age, sex, weight, breeding status, milk yield, etc. You also need to take into account the nitrogen content of any organic manures imported/exported to/from the farm.
Slurry and organic manure storage calculations, to show you have sufficient capacity to store all organic manures for the entire ‘storage period’, taking into account: volume of storage, surface area of yards and roofs, annual rainfall in your location (as a ‘wetter than average’ year, which they define as the wettest year in the past five), and the quantity of manure and dirty water produced by livestock (see the 43 categories in the tables of values above), proportional to the time they are housed or milked.
A farm ‘risk map’ detailing: area of each field (in ha); any rivers, streams, or surface water; any boreholes, wells, or springs on or within 50m of your land; any drains or ditches; soil type (for each field); any shallow or sandy soils; any slopes (slight/moderate/severe); location of muck heaps (which will change every year and must change every two years to be compliant); any ‘no-spread’ areas; any fields considered ‘low risk’ for spreading.
Records of all spreading activity including: date, quantity, content, and method of spreading; weather and soil conditions on the day; ‘field limit’ calculations to show you haven’t spread more than 250kg total N/ha/yr from organic manures on any one field; ‘N-max limit’ calculations to show you haven’t spread more crop available nitrogen (which is different from total nitrogen and varies significantly depending on the type of organic manure) than you should’ve in any one field, with the limit varying depending on crop type in that field.
A ‘four-step nitrogen plan’ for the year ahead, including: calculation of the ‘soil nitrogen supply’ status of each field; calculation of the nitrogen requirement for each field, depending on crop type; calculation of the crop available nitrogen from any planned spreading of organic manures; calculation of any additional nitrogen required from manufactured fertiliser, for each field, according to standardised recommendations…
All of this; every year. Whether you plan to spread any manufactured fertiliser or not.
Additionally, whether or not you are in an NVZ, you’ll need to get your soil tested for pH, phosphorus, potassium, and magnesium, at least once every five years, and show that you are using the results in your nutrient planning.
Failure to do any of this leaves you in breach of NVZ regulations, or else the ‘Farming Rules for Water’, and liable to fines and prosecution by the Environment Agency. Up to now they’ve been relatively lenient and keen only to give ‘advice’…but I hear more and more stories of ‘enforcement’ these days.
I’m strongly in favour of the underlying purpose of these regulations: preventing pollution and encouraging good manure and soil management. But the scale of the bureaucracy of it all is utterly ridiculous: not to mention the fact that farmers are expected to shoulder that bureaucratic burden. There are so many better ways it could be done.
Thus the new project, which came about organically: someone asked me if I could do their NVZ paperwork and I thought I’d give it a go. When I looked into it, I was amazed to find how remarkably complicated it could get, quite quickly, even for a simple farm.
There isn’t really an easy (and cheap) option to get the job done. I thought the best/recommended (and free) tools (PLANET, ‘Tried and Tested’ workbooks, or Slurry Wizard, e.g.) were still quite off-putting/inaccessible(/a lot of work), and none of them really offered an ‘all-in-one’ solution that not only did the calculations but also produced the required evidence, such as spreading maps and the like.
Already familiar with QGIS, I thought it would be easier to program that to do the job. I’m still finalising the system (now in a late beta stage) but it definitely is better/easier/quicker/etc. I’ll end up with a way to take simple farmer-friendly inputs (‘tonnes of manure’ or even ‘how many loads with your spreader’, e.g.), have them go through the calculations, then produce clear farmer-friendly outputs (i.e., whole-farm maps and visualisations).
This is only branching off from similar types of work I’ve fallen into of the past few years – soil reports and the like – but for me this represents a clear step into a different reality that I have decided to accept: not just a new business but a new picture of life.
For me, any living to be made is not to be found in farming but in the paperwork around farming. So I become a farm-paperwork person, not a farmer.
This is a shame. But I shrug and move on and take what satisfaction I can in learning how to code online calculators.
New Business
The first order of business, then: I’d welcome any feedback or suggestions about this website and the business it represents: nvzcompliance.co.uk
Particularly I’d direct your attention to some online calculators that might be useful for you or for any farmers that you know. There is a ‘livestock load’ calculator – for beef, dairy, and mixed farms – and a simple nitrogen spreading calculator that can show you the total and crop available nitrogen from cattle or other various types of slurries and manures.
I am (or at least I was) an absolute beginner in (at?) coding (or whatever the kids call it these days), so I’d be glad enough if these things simply worked. But I’d also welcome any suggestions for any other calculators that farmers (or farm advisors) might find useful. In time I will get to a full set of ‘nutrient management’ calculators, but until I get a ‘FACTS’ qualification (the little bit of paper that permits me to do full ‘nutrient management plans’) there’s little to be gained from this.
I hadn’t planned to go in this direction. I think I just got a bit distracted by the project of making the system: I wondered if it could be done using open source software and it turns out it can; it’s been a satisfying challenge. But having made it, and now it’s up and running, I expect it’s the clearest route to reliable income that I have in front of me, so I’d better go all in. I’ll get my ‘certificate’ when I can and become a ‘suitably-qualified professional’.
All the while recognising that all of that is nonsense, of course. I had a funny interaction with a farmer (client) recently. She queried a bit in my soil report that stated a field was ‘high risk’ for run-off. She said it wasn’t. I agreed, largely because of the health of the soil there but also other ‘real world’ factors. Then I said:
‘But the computer data [that everyone uses to determine these risks] suggests that it is, and if the Environment Agency query the report and see that I haven’t put the field as “high risk”, even though the data suggests otherwise, then I suspect they might side with the data and call me incompetent or worse.’
Which is absurd, when you think about it, but what’s remarkable is that I don’t really think about it. I put something in a report that I know to be actually false, because I know that the actual truth won’t match up to the perception of the bureaucrat, which reveals that the only real purpose of the report is to manage the perceptions of bureaucrats. Both I and the farmer agree that this is pointless and silly, but she will pay me to do it and she will get paid (more) by the government for having it done. And we will all happily ignore the falsity in the report and carry on doing what we’re doing: her because she knows perfectly well what she’s doing and needs no advice from me, and me because I get paid to produce reports whether or not anyone pays any attention to them.
A philosopher really struggles with this priority of representation over reality. It’s as if people are only willing to pay for photographs of food, not food itself, and then wonder why they end up hungry. But you don’t get paid for reality these days, only for its representations, and the need to get paid is a reality that no one can deny.
We shrug and move on.
Representation and Reality
Imagine the sensors on your car alerted the police: a warning comes up on the dashboard – ‘low tyre pressure’, for example – and they’d pull you over to give you a ticket for ‘driving a vehicle in a dangerous condition’.
We all know sensors can be faulty. Imagine your sensor is faulty: it pings a warning, but you check the tyres manually and they’re all ok, so you drive on. Only, the police pull you over and penalise you. When you point to the reality that your tyres are ok, they penalise you on the basis of the representation of the sensor’s indication.
A silly hypothetical, perhaps, but it’s not so different from how it is with farming regulation. I’ve known farms that are in an absolute state, reality-wise, but their paperwork is all in order so no one pays any attention. And I’ve known farms get unwelcome ‘attention’ from enforcement agencies even though there’s nothing in reality wrong with anything that they’re doing, only they haven’t measured it or documented it because a) they have a brain and can remember things (though whether that’s a legitimate excuse for not doing your paperwork I’m not sure), and more revealingly b) it all goes without saying, for them, because it’s obvious. And the thought doesn’t occur to measure or document what for them is obvious.
Isn’t that ‘obviousness’ a product of knowing what you’re doing, which we’d say is (in reality) a rather good thing?
I think so, in most cases, but the reasonable answer seems to be ‘it depends’, because it could just as easily be a product of thoughtlessness, naivety, or arrogance, which are rather less good.
Whether or not someone really knows what they’re doing seems to be an important question. How do we go about answering it? Because while there’s nothing particularly mysterious about this kind of knowledge, it will remain a mystery to those who don’t have it.
I don’t have it, but I’m happy to embrace the mystery because I recognise the causes of it, which I will here attempt to outline:
Cars now have tyre pressure sensors but this wasn’t always the case: I expect a racing driver in the 60s could ‘feel’ when the tyres weren’t right and know what to do about it; mechanics used to be able to diagnose an engine fault by ear, and no one doubted their diagnosis on the basis of it having been done by ear (and there being no data available beyond that). If you asked for evidence in either case, asked them how they know, they might only reply ‘it doesn’t feel/sound right’. The timing’s off.
To anyone who shares that understanding, that answer makes complete sense and is all there is to say. But to anyone else it is uninformative and very unhelpful.
Isn’t there a lesson in that, since there doesn’t seem to be anything wrong with that picture? If anyone who clearly knows what they’re doing offers an explanation that you don’t understand, the presumption ought to be in their favour. I suspect once upon a time this was a commonly-accepted principle, but it seems to be slipping away with the increasing availability of some ‘artificial’ measurement or other. We’d take the word of a single digital readout, and would look for that first, over a lifetime of experience.
That last sentence doesn’t sound as silly as it ought.
A clearer simile: it’s like a musician knowing when their instrument is out of tune. They don’t need a digital tuner to tell them what they already know. And if there’s a disagreement between the tuner and the musician, we should side with the musician (when they are a real musician).
This happened to me. I play the guitar – not very well but neither very badly – and when once playing (in student days) in the company of a friend of mine who is now a professional opera and choral music singer (extremely talented/educated/trained/‘pitch-perfect sight reader’, etc.), he pulled a face and asked to have my guitar to retune. I’d tuned it perfectly according to my digital tuner, and it sounded ok to me, but it didn’t sound right to his trained ear. Sure enough, he retuned it to his ear and it sounded much better.
(Guitars are notoriously difficult to tune ‘properly’: this is because they are in fact always out of tune, as are even perfectly-tuned pianos. A real musician can hear this in a way that someone like me can’t. If you don’t believe this, jump to 12:30 in this video, or 10:30 for the preamble.)
Was I right to take his correction? Of course I was, and how silly it would’ve been to reject it: ‘You may know what you’re doing and have a highly refined ear for such things, and it might sound better doing it your way, but my digital tuner says you’re wrong so…I’m going to go with the evidence and say you’re wrong.’ Absurd.
I very much believe in that kind of musical know-how, but not being a musician myself I can only take their word for it and trust their ear (and appreciate the results); there’s no greater evidence I could appeal to, nor any rational account to be offered, beyond their word (and what follows from it); I couldn’t say how they know what they know, because I don’t know the first thing about it, and neither would they because for them it goes without saying. What is opaque for me is obvious for them, so I trust their judgement over mine, as someone blind trusts someone sighted to guide them around the room.
I don’t know what they know, but I know that they know, and that’s enough for me, because I’m not going to stand in judgement over them about something I’m in no position to judge. There’s nothing at all mysterious about that: I recognise their ability and respond naturally, with reverence and deference.
That represents a kind of blind faith in the trained ear of the real musician. Ordinarily, blind faith isn’t something we’d want to encourage, but whenever we run up against the limits of our ability to understand, the most we can say is that we understand those limits. We acknowledge our lack of knowledge: if we want to hold this alongside any acknowledgement of their knowledge (which is beyond ours) then it follows that we must embrace a mystery.
If we don’t want to embrace such a mystery then we have options: we could dismiss their knowledge as trumped-up nonsense, for example, as I might be inclined to do with so very many ‘experts’ on wellness. But that is difficult to do when it comes to someone with genuine expertise. The value of a good mechanic’s know-how, or a real musician’s sound, is hard to deny.
Philosophers would call someone with that kind of status an ‘authoritative example’: they are someone whose knowledge can not only be trusted, but who in some sense defines what trustworthy knowledge is.
The philosopher Plato said that those who love and seek wisdom are clinging in recollection to things they once saw. On many occasions in my life I have had the need to say, and thankfully have been able to say: I know what a good workman is; I know what an honest man is; I know what friendship is; I know because I remember these things in the person of my father, in the person of his friend Hora, and in the example of their friendship.
Raimond Gaita, ‘Romulus, My Father’
Which is why blind faith in someone who really knows what they’re doing isn’t such a bad thing: it would be a mistake to ask for evidence, because it’s already been established that there is no greater evidence than their example.
(This presents a problem for paperwork, because you can’t measure or document an authoritative example, except perhaps in literature, and even then only as a sketch. The bureaucrat will not recognise it in any case, since literature is not the language of bureaucrats.)
Which is also why it’s so important to be able to tell the difference between, for example, a real musician and a pseudo one, especially when we aren’t musicians ourselves.
That’s not an easy task, when you think about it. But demarcating the real from the pseudo, even when we aren’t either, is one thing that philosophy can do for you. Most philosophical tasks can be seen in that light and understood by it: the philosophy of science does it explicitly, separating science from pseudoscience in order to better understand what good science is or ought to be (and you don’t need to be a scientist to understand those lines of reasoning), but ethics is really nothing more than the attempt to distinguish real goodness from pseudo-goodness (the many false claims to goodness that we get distracted by), and likewise for the philosophy of religion, or knowledge, or art, or whatever else you’d care to ask the question of.
I understand all of that very clearly, which is why I feel such a contradictory tension in doing farm paperwork (and getting paid for it). I feel like I’m siding with the pseudo over the real, and no one wants the pseudo over the real.
I represent representations that change no realities and often have little connection with them. All of this work exists in a world away from the farm itself: the data is online; the computations in my office.
The bureaucrat is detached from reality and yet stands in judgement over it. They deny the know-how of the authoritative example that stands in front of them: the multi-generational farmer who knows their land better than anyone else alive (and who would themselves refer to the passed-down knowledge of those now dead). There are truths about the land that only generations can tell. That’s not a melodramatic appeal to something mystical but a simple statement of fact: there is no better record of a land’s history and character than the oral tradition of the people who’ve worked it. Because they never thought to measure or document it beyond that, because it all went without saying for them, because it was obvious, because they knew what they were doing.
The bureaucrat sweeps all of that away with a bit of data, AI-generated from an image taken from space, and considers themselves virtuous to do so.
And I seem to be joining them, because there is no better way to defend yourself against them.
We shrug and move on. I need the money.
But I suspect tuning the land is a bit like tuning a guitar; I suspect you need to cultivate an ear for it, or else be prepared to have a little faith in those who really know what they’re doing.
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In my grandiose moments, trying to reassure myself, I see myself as the thin green line standing against the bureaucrat hoards. They come with their inspections and questions and we bat them back with suitably-prepared paperwork.
You don’t want to give them a free run at it. The more suitably-prepared paperwork you can throw at them, the less momentum they build up. I would rather meet them at the gates with everything they need to leave wanting nothing more.
Then farmers will be free to return to the work of real worth. Which is surely a good thing, even if I’m not one of them.
tobybetenson.com 