MOF, Alm.del - 2024-25 - Bilag 454: Orientering om rapport jf. ophørt undtagelse fra nitratdirektivet (kvægundtagelsen), fra ministeren for grøn trepart

Miljø- og Fødevareudvalget 2024-25
MOF Alm.del Bilag 454
Offentligt

Derogation Report 2024

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

May 2025

MOF, Alm.del - 2024-25 - Bilag 454: Orientering om rapport jf. ophørt undtagelse fra nitratdirektivet (kvægundtagelsen), fra ministeren for grøn trepart

Ministry of Green Transition of Denmark

Agency for Green Transition and Aquatic Environment

Ministry of Green Transition of Denmark / Nitrates Directive / Derogation Report 2024

MOF, Alm.del - 2024-25 - Bilag 454: Orientering om rapport jf. ophørt undtagelse fra nitratdirektivet (kvægundtagelsen), fra ministeren for grøn trepart

Contents

2.1

2.2

2.3

2.4

2.5

2.6

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

Introduction

Maps of cattle holdings, arable land and livestock in kg N in 2022/2023

Introduction

Map of derogation holdings 2022/2023

Map of arable land 2022/2023

Map of livestock in kg N in 2022/2023

Use of the derogation

Trends in livestock

Controls at farm level

Control of compliance with the Danish derogation

Summary of inspection results 2024

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 fertiliser accounts

Results

Agricultural practices and water quality

Introduction

4.2

Development in agricultural practices at the national level from 2005 to 2023

4.3

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

derogation farms at the national level – 2023 data

4.4

Development in modelled nitrate leaching in the Agricultural Catchment Monitoring

Programme 1990-2023

4.5

Measurements of nitrate in water leaving the root zone and in upper oxic

groundwater

4.6

The nitrogen cycle in agricultural catchments

4.7

5.1

5.2

5.3

6.1

6.2

7.1

7.2

7.3

7.4

References

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

Introduction

Results from 2017 to 2024

Conclusions

Cattle holdings and controls on farm level

Agricultural practices and water quality

Targeted catch crops and targeted nitrogen regulation

The phosphorus indicator and monitoring system

Ministry of Green Transition of Denmark / Nitrates Directive / Derogation Report 2024

MOF, Alm.del - 2024-25 - Bilag 454: Orientering om rapport jf. ophørt undtagelse fra nitratdirektivet (kvægundtagelsen), fra ministeren for grøn trepart

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 Danish derogation 2020/1074/EU

expired the 31st of July 2024.

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 2022/2023.

According to the decisions 2018/1928/EU and 2020/1074/EU, the Danish authorities will

submit the following information to the Commission for the derogation period 2022/2023:

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

percentage 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

regards nitrate and phosphate, including information on water quality trends as well as the

impact 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

livestock category in Denmark and in derogation farms.

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

Ministry of Green Transition 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 Green Transition of Denmark / Nitrates Directive / Derogation Report 2024

MOF, Alm.del - 2024-25 - Bilag 454: Orientering om rapport jf. ophørt undtagelse fra nitratdirektivet (kvægundtagelsen), fra ministeren for grøn trepart

2. Maps of cattle holdings,

arable land and livestock in

kg N in 2022/2023

Lars Paulsen & Lene Kragh Møller, the Agency for Green Transition and Aquatic

Environment, Ministry of Green Transition, December 2024

2.1

Introduction

For the planning period 2022/2023, the Danish Agricultural Agency received 27,314 fertiliser

accounts containing key figures on the use of nitrogen (commercial fertiliser and organic

manure). 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 2022/2023. The fertiliser accounting year runs from 1

August to 31

of July. Accounts for 2022/2023 were to be submitted to the Danish Agricultural

Agency no later than 31

of March 2024.

In the fertiliser 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 fertiliser quota and catch crops plan (at the latest 21st of April each year).

The information about the application is automatically transferred to the fertiliser 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

livestock density at farm level via a maximum allowable N application from organic fertilisers

(instead 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

limitation per area.

2.2

Map of derogation holdings 2022/2023

The map (Figure

2.1)

shows derogation holdings in percentage of the total number of

agricultural holdings registered in each respective Danish municipality.

In 2022/2023, 818 derogation holdings were encompassed by the derogation. This

corresponds to 3.0 % of all registered fertiliser 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 derogation 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.

2.3

Map of arable land 2022/2023

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.

Ministry of Green Transition of Denmark / Nitrates Directive / Derogation Report 2024

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In 2022/2023, the arable land on cattle holdings encompassed by the derogation was 154,009

hectare at national scale. This corresponded to 6.7 % of the registered area used for

agriculture in Denmark.

2.4

Map of livestock in kg N in 2022/2023

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 2022/2023, the kg N from organic fertilisers spread from cattle holdings encompassed by

the derogation was 29.7 million kg N in total. This corresponded to 14.0 % of all kg N in

organic fertilisers spread on the agricultural area in Denmark.

2.5

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

regarding 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.

Between 2009/2010 and 2015/2016, an overall increase in the agricultural area using the

derogation was observed, whereas the number of farms remained at a more constant level.

The general 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.

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 2022/2023 (One LU=100 kg N (ex storage)).

Year

Number of

derogation

farms

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

Area of

deroga-

tion

(hectare)

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

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

Number

of LUs

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

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

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

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

Ministry of Green Transition of Denmark / Nitrates Directive / Derogation Report 2024

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2015/2016

2016/2017

1,466

1,378

4.2

3.9

210,061

205,874

8.6

8.4

443,134

439,114

Mill. kg

N spread

(org.

fert.)

19.4

19.3

of total

kg N

spread

(%)

18.1

17.8

16.8

14.5

14.1

14.0

2017/2018

2018/2019

2019/2020

2020/2021

2021/2022

2022/2023

1,312

1,284

1,197

945

883

818

3.9

3.7

3.0

3.1

3.0

198,195

195,804

182,950

163,732

161,132

154,009

8.2

8.1

7.6

6.8

6.7

39.6

39.1

36.8

32.9

32.8

29.7

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 8,554 Danish agricultural holdings had cattle as livestock in

2022/2023. These holdings spread total 98.8 million kg N from organic fertilisers and covered

an agricultural area of 751,401 hectare. This gave an average of 11,547 kg N spread from

organic 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 9.6 % of

all cattle farms were derogation farms in 2022/2023, and the derogation (cattle) farms spread

30.1 % of all cattle-kg N in Denmark, covering 20.5 % of the total Danish cattle farm area.

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

expressed 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

Average livestock size

(LU/holding)

115.78

117.07

118.97

124.14

131.53

143.76

Average livestock density

(LU/ha)

1.74

1.76

2.06

1.91

1.89

2.02

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

agricultural land within the farm, as this amount can be different from the amount of livestock manure

produced 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.

Ministry of Green Transition of Denmark / Nitrates Directive / Derogation Report 2024

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2008/2009

2009/2010

2010/2011

2011/2012

2012/2013

2013/2014

2014/2015

2015/2016

2016/2017

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)

30,171

30,475

30,769

34,772

37,176

36,365

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

204

193

2017/2018

2018/2019

2019/2020

2020/2021

2021/2022

2022/2023

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 Green Transition of Denmark / Nitrates Directive / Derogation Report 2024

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FIGURE 2.1 Derogation holdings in percent of total number of agricultural holdings in Denmark in 2022/2023.

The location of each holding is determined by the address of the owner.

Ministry of Green Transition of Denmark / Nitrates Directive / Derogation Report 2024

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FIGURE 2.2 Agricultural land encompassed by the derogation in 2022/2023 in percent of

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

address of the owner.

Ministry of Green Transition of Denmark / Nitrates Directive / Derogation Report 2024

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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 2022/2023 in Denmark. The location of each holding is determined by the

address of the owner.

Ministry of Green Transition of Denmark / Nitrates Directive / Derogation Report 2024

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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

Funen and the island of Bornholm.

2.6

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

category 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

derived from the data shown in

Table 2.3.

Over the planning periods from 2014/2015 to

2022/2023, the number of herds have decreased for each livestock category, except for

poultry and others in 2022/2023. The total number of Danish herds of livestock has decreased

by approximately 32 % in between the planning periods of 2014/2015 and 2022/2023. 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 Green Transition of Denmark / Nitrates Directive / Derogation Report 2024

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TABLE 2.3 Number of Danish herds of livestock and production of manure in livestock

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

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

No. herds

9,800

1,200

3,000

1,700

1,900

5,100

21,500

Kg N, mill.

117.2

36.8

80.2

16.7

1.0

2.1

217.2

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 Green Transition of Denmark / Nitrates Directive / Derogation Report 2024

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2020/2021

No. herds

9,500

900

3,000

1,700

1,900

5,000

21,100

Kg N, mill.

117.1

44.1

85.1

11.8

1.0

2.1

217.1

2021/2022

No. Herds

8,900

900

2,800

900

1,800

4,600

19,000

Kg N, mill.

115.9

43.5

81.2

6.8

1.0

2.0

206.9

2022/2023

No. Herds

8,600

800

2,500

900

1,700

4,700

18,400

Kg N, mill.

115.3

39.8

67.1

7.2

1.0

2.1

192.6

Ministry of Green Transition of Denmark / Nitrates Directive / Derogation Report 2024

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3. Controls at farm level

Lars Paulsen & Lene Kragh Møller, the Agency for Green Transition and Aquatic

Environment, Ministry of Green Transition, December 2024

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

Commission 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

compliance 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 fertiliser

accounts.

3.2

Summary of inspection results 2024

Compliance with management conditions:

• Inspection at the farm in January and February 2024: 60 inspections were carried out. 56

holdings complied with the derogation management conditions. Four holdings got a remark

(Table

3.1).

Compliance with the harmony rules for holdings using the derogation:

• Administrative inspections of the submitted fertilizer accounts for 64 inspected farms in

January and February 2023: 60 holdings complied with the specific rules for derogation

holdings. One holding had a minor violation. Three holdings are still under investigation

(Table 3.2).

• Administrative control of the submitted fertilizer accounts: 46 inspections were carried out,

out of which 32 holdings complied with the rules. Ten holdings got a remark and four

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 Agency

for Green Transition and Aquatic Environment has inspected the fulfilment of the Danish

derogation conditions on derogation holdings from 2002/2003 through 2023/2024. 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),

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

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

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

hectare 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 next planning

period?

If the answer is “yes” in question 7: 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

abovementioned questions. At the end of the inspection, the farmer is informed whether the

holding is allowed 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 Agency for

Green Transition and Aquatic Environment for possible further administrative inspection. The

Agency for Green Transition and Aquatic Environment verifies the data. Additional remarks

made by the inspector, if any, are examined. This includes a process where the parties of

interest are allowed to make statements on the case if an infringement is discovered.

3.4

Results

From

of January until 1

of March 2024, the Agency for Green Transition and Aquatic

Environment carried out 60 inspections on derogation holdings to inspect whether the

conditions requirements were met. The control refers to the fertilizer accounts for the planning

year 2022/2023 where some conditions are controlled in the next planning period 2023/2024.

Table 3.1

shows the results of the inspection for the last 21 years. Only very few remarks have

been given and in general a good compliance with the rules has been noted.

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

during winter.

Control

planning-

period

2003/2004

Total number of

inspections

Inspections without

remarks

Inspections with

remarks

The respective controls during the planning period 2023/2024, which have been performed in January

and February 2024 are related to the fact that the farmer has made use of the derogation in the previous

planning period, i.e. 2022/2023. This applies also to all previous control years.

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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

2022/2023

2023/2024

3.5

3.5.1

General inspection of the harmony rules

Harmony rules

Control of the harmony rules (i.e. the amount of organic 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

inspector visits the farm to inspect the production based on various production and fertilizer

account 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

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

Administrative inspection included submitted fertilizer accounts concerning the year

2021/2022, for 64 inspected farms in January and February 2023 for violation of the harmony

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

set of “risk criteria”. The Agency for Green Transition and Aquatic Environment has therefore

no direct influence on how many derogation holdings ware selected for “harmony rules

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inspection”. Out of these administrative inspections, 60 holdings (93.8 %) complied with the

specific rules for derogation holdings. Three holdings (4.7 %) are still under investigation, one

holding had a minor violation (1.6 %) (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

without

remarks

Inspections

with minor

violations

Inspections

with fines

Inspections

still under

investigation

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

3.5.2

Soil analysis

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

where phosphorus and nitrogen levels in the soil are examined. One sample per five hectares

must be provided.

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

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

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

prior to 2021/2022 are not updated. Thus, these inspections may have been finalized.

Administrative inspections of the submitted fertilizer accounts for 64 inspected farms in January and February

2023 (Table 3.1)

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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 phosphorus content of the soil. A P-tal between 2 and 4 is generally accepted

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.

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,

depending 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 mineralization 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

expected 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

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

Table 3.3.

The inspection of derogation farms for 2021/2022 showed that 43 holdings out of the 64 (67.2

%) inspected holdings had to provide soil analysis. None 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

planning period

Number of

inspections for soil

analy-

sis

Inspections without

remarks

Inspections with

remarks/still under

investigation

2004/2005

2005/2006

2006/2007

2007/2008

2008/2009

2009/2010

2010/2011

2011/2012

2012/2013

2013/2014

2014/2015

2015/2016

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2016/2017

2017/2018

2018/2019

2019/2020

2020/2021

2021/2022

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

analyses, given as average of all inspected holdings (n=43 in 2021/2022) and with the

lowest and highest average values at holding scale, respectively.

Control planning

period

Average

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

2020/

2021

4.29

2.00

7.03

0.26

0.13

0.78

2021/

2022

4.11

1.94

6.49

0.20

0.11

0.30

P-tal

(mg

P/100 g

soil)

3.6

Control of fertiliser accounts

Each year, the farmers submit their fertilizer accounts to the Agency for Green Transition and

Aquatic Environment. The accounts include key data on:

• total arable land on the farm

• arable land available for application of organic manure

• data on catch crops

• type and number of livestock

• production of livestock manure (kg N and P)

• usage of organic 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

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For the year 2021/2022, 887 (3.2 %) of the submitted fertilizer accounts were subject to

administrative control. 92 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 2021/2022, 110 (12.4 %)

derogation 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.

3.6.1

Results

Out of the 46 administrative harmony controls, 32 holdings (69.6 %) were closed without

remarks. Ten holdings (21.7 %) were closed with remarks and four (8.7 %) inspections are still

under investigation (Table

3.5).

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

farms using the derogation.

Control planning

period

Number of

inspections

Inspections without

remarks

Inspections with

remarks

Inspections still

under

investigation

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

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4. Agricultural practices and

water quality

Mette Thorsen & Gitte Blicher-Mathiesen, Department of Ecoscience, DCE, Aarhus University, February

2025

4.1 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, especially 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 subsequent action programmes to ensure efforts are made to reduce the loss of nitrogen (N) and

phosphorus (P) to the aquatic environment.

In 1998, the Action Plan on the Aquatic Environment (APAE) II was accepted by the EU Commission 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 second 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 targets 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 approximately 10 m from the

edge of open streams and lakes larger than 100 m

. In 2014, the buffer zone area was adjusted from 50,000 to 25,000

ha. Since the beginning of 2016, the additional 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. From 2023, for applicants of basic payment, the buffer zones are required to have a width of 3 m.

The Political Agreement on Food and Agricultural Package from December 2015 includes a range of measures aimed

to change the environmental regulation of the agricultural sector. The first part of this political agreement was

implemented in 2016.

In 2016, farmers were allowed to use more N fertiliser. According to the APAE II agreement (from 1998), farmers were

restricted in the application of N fertilisers 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 adjustment 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 increase as well. However, due to

the suspension of set-aside in 2008, higher yields and increases 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, meant to counteract the

potential increase in nitrate leaching due to the extra application of N fertiliser from 2016 and onwards.

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 requirement for targeted catch crops

was approximately 114,000 and 139,000 ha, respectively. For 2020, 2021 and 2022 this area was increased to

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approximately 373.000 ha. The targeted catch crops scheme was introduced to ensure that the status of coastal waters

and groundwater 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 farmers who either own or lease fields

for cultivation in such catchments.

The second River Basin Management Plans (RBMPII) covers the period 2015-2021 and was adopted in June 2016. It

proposes schemes for implementation of mitigation measures, such as re-establishment of riparian areas, construction

of wetlands, set-aside of organic soils, afforestation and adjustment of greening elements. The national reduction target

for the annual marine N input in 2021 was estimated to 13,100 t N compared to the average normalized marine N input

of 56.800 t N for the period 2010-2014. However, the RBMPII only included mitigation measures to obtain an annual

reduction of the marine N input 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 marine N input of 6,200 t N was postponed to after 2021.

The third River Basin Management Plans (RBMPIII) covers the period 2021-2027 and was adopted in June 2023

(Miljøministeriet, 2023). The national reduction target for the annual marine N input from land-based sources in 2027

was estimated to 12,955 t N compared to the average normalized marine N input of 56,300 t N for the period 2016-

2018. The RBMPIII includes mitigation measures to obtain an annual reduction of the marine N input of 7,441 t N in the

period 2021-2025 for coastal waters with N mitigation demands. An effort regarding part of the remaining reduction

amounting to 3,000 t N was postponed and should be decided in 2023/2024 and implemented after 2025.

In November 2024 a new political agreement implementing “The deal for a Green Denmark” was decided, with a

national reduction target of 13,800 t N compared with a mean load of 56.200 t N for 2021 and a baseline estimated

reduction of 3.700 t N (Finansministeriet, 2024). The plan for mitigation measures to reach the target nitrogen load will

be listed in a revised version of the third River Basin Management Plan (RBMPIII) in the beginning of 2025. All

mitigation measures to fulfil the reduction target should be initiated in 2027 at the latest. On this basis, it is expected

that the majority of Danish water bodies will meet the required nitrogen efforts by 2027.

The N input to marine waters has been reduced incrementally along with implementation of measures to reduce

loadings from point sources and agriculture. Since 1990, approximately half of the Danish land area is located within

catchments equipped with stream water gauging stations where the N input 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 input 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 input

to coastal areas has been updated and since 2017 includes a higher proportion of gauged catchments (about 65%) as

well as an improved and more detailed calculation of discharge from ungauged catchments (Thodsen et al., 2021).

In 2023, the total actual load from land was calculated to about 65,000 tons of nitrogen. For most months, these

amounts were significantly lower than the average for the period 1990-2021. The normalised diffuse nitrogen load for

2023 was calculated to 44,000 ton N compared with 48,000 ton N in 2022. The normalised mean diffuse load for the

presiding five years (2018 – 2022) was 51,000 ton N, ranging between 46,000 and 58,000 ton N. Adding the point

source load of 6,200 tons N, the total flow normalised load of 2023 is calculated at approximately 50,000 tons N. For the

year 2022, the corresponding value was 53,000 tons N. For the five presiding years (2018 – 2022), the average flow

normalised total N load was calculated to be 56,000 tons N, with a range between 51,000- and 64,000 tons N yr

-1

. The

normalised transport indicate the nitrogen transport that would have been in each year if water runoff had remained

constant over the period 1990-2023 (Thodsen et al., 2024). In wet years with runoff above the average level, the

normalised transport will therefore be lower than the actual transport. In 2023 the runoff was approx. 26% higher than

the average for the period 1990-2022 (Thodsen et al., 2024)

The regulation and effects described in this chapter cover the period 2005-2023. Additional agricultural regulation, such

as requirement to increase the utilisation efficiency of nitrogen in manure (2020/21), a reduced fertiliser application

norm on soil with a high content of organic matter (2020/21) were implemented in 2020. A ban on application of solid

manures in autumn and ban on application of fertiliser on §3 extensive and permanent grasslands were fully

implemented in 2021/22 (Lov om ændring af lov om naturbeskyttelse, 2020). In 2021, the mitigation measures related

to cover crops were adjusted allowing the use of cover crops with N-fixing species and including precision agriculture as

an alternative.

In 2023, the CAP agricultural reform was implemented introducing new rules for agricultural subsidies. Of these, the

extensification of crop rotation with lowland ploughing scheme started in 2022 and aims to promote extensive

management of crop rotation on carbon-rich soils and in river valleys to reduce greenhouse gas and nitrogen emissions

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from the land. With the CAP agricultural reform, some of the existing environmental requirements were replaced with

GAEC 8, which requires all farmers to set aside on at least four per cent of the farm's rotational areas as fallow, i.e.

non-productive areas and landscape elements.

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 period 2005-2023. 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 presented 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 derived by linking data from the basic 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

2023. Modelling of nitrate leaching at national level is carried out by means of the empirical model NLES (version 5)

(Børgesen et al., 2022). The method for data compilation and setup of the NLES5-model at national level is described in

Rolighed, 2023.

Third, measurements of water quality from the National Monitoring Programme are presented for the period 1990/91-

2022/23, with particular reference to the Agricultural Catchment Monitoring Programme (Blicher-Mathiesen et al., 2024).

This section includes:



Modelling of nitrate leaching in the agricultural monitoring catchments as referred to in Article 10(3) in

2020/1074/EU.

Measurements of nitrate and phosphorus in water leaving the root zone and nitrate in upper oxic groundwater,

including fields receiving more than 170 kg N ha

-1

in organic manure as referred to in Article 10(2) in

2020/1074/EU.

Nitrogen in surface water, draining from agricultural catchments as referred to in Article 10(2) in 2020/1074/EU.



Modelling of nitrate leaching for the agricultural monitoring catchments is also carried out by means of the empirical

model NLES (version 5) (Børgesen et al., 2020, 2022). This model is partly based on data from the Agricultural

Catchment Monitoring Programme (Blicher-Mathiesen et al., 2024). 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 – DMI), 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 authorisation 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 manure are presented.

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

2023

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Crop distribution

The development in crop distribution for 2005-2023 was analysed on the basis of the basic payment registration.

FIGURE

4.1

presents the results for cash crops, fodder crops and non-cultivated 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 2,586,000 ha in 2023.

The decrease in agricultural area is due to road construction, afforestation, urbanisation etc. During the years 2006-07,

set-aside comprised about 160,000 ha. In the period 2008-2014, 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 2015-2022 as set-aside is an element in the Danish implementation of the

EU Greening. In 2023 the area of set-a-side increased to 92,000 ha following the implementation of EU CAP in

Denmark. In addition, the area with other environmental agreements has increased from approx. 30,000 ha in 2020-

2022 to 49,000 ha in 2023. The area with cash crops and fodder 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

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,

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faba 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 counterbalance 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

adjustment of catch crop area was made to 10.7% and 14.7%, respectively, 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.

FIGURE 4.1 Development in crop distribution at the national level from 2005 to 2023,

data from the basic payment register.

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



Reduction of the farm nitrogen fertiliser 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 manure)

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

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

than 100 m

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 2024 the substitute area was decreased further to 1,9 ha.

From 2016, substitution of one ha of catch crop by one ha of set-aside. From 2024 one ha of catch crop can be

substituted by 0,5 ha of set-aside.

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

From 2022, substitution of one ha of catch crop by one ha of catch crop with N-fixing species and a deduction

of 50 kg N ha

-1

from the N-quota due to expected effect of fixed nitrogen taken up by 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 119.000-138,000 ha in

2005/06-2007/08 to about 481,000-505.000 ha of catch crops in 2020/21-2022/23 (Fejl! Henvisningskilde ikke fundet.2).

In 2023/24 the area with catch drops decreased to about 445.000 ha, which may be related to the increased area with

set-a-side and other environmental agreements. The introduction and use of catch crop alternatives were equivalent to

the effect of 13,900-95,000 ha catch crops in the period 2011/12-2023/24.

FIGURE 4.2 Area with catch crops and catch crop alternatives (1,000 ha of catch crop equivalents) reported by

the farmers in the annual fertiliser accounts in the period 2005/06-2023/24.

In 2017, a new regulation of animal husbandry was implemented. With this regulation, additional 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. 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 derogation 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

4.1).

The application of animal manure N varied between 216,000 and 227,000 t N from 2005 to

2022. In 2023 the application of animal manure decreased to 204.000 t N. 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 areas. 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 followed by an equivalent reduction in nitrogen standards. Administratively, however, this reduction is based on

statistical data on the cultivated area, resulting in a delay of two years. Thus, in 2010-2014, the use of inorganic

fertilisers decreased again, reaching 198,000 to 203,000 t N year

-1

. 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, respectively, after the

implementation of the Food and Agricultural package, according to which farmers were allowed to use more fertiliser

after 2015. 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

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

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 approx. 4 kg N ha

-1

less as a significant amount of mineral 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 4.1 Development in the use of inorganic nitrogen fertiliser and of nitrogen in animal manure as reported

by the farmers in the annual fertiliser accounts for the period 2005-2023 (1,000 t N yr

-1

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023

Fertiliser

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

196

224

195

204

The use of N in inorganic fertiliser increased to 230,000 t N in 2020, partly due to a recommended 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,

2022 and 2023, the use of inorganic N decreased to 200,000, 196,000 and 195,000 t N, respectively, partly due to the

requirement to increase the utilisation efficiency of nitrogen in manure.

4.3 Modelled nitrate leaching for farm types and geographical areas and the

impact of derogation farms at the national level – 2023 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 these parameters. Regarding crop distribution and nitrogen

input, the analyses are based on the national datasets from the basic payment register and the fertiliser accounts.

However, before the data can be used for this purpose, a detailed compilation of multiple datasets must be made

(Rolighed, 2023). The basic payment register contains information on crops at field level, and the fertiliser accounts

contain information on the use of nitrogen (inorganic fertiliser and organic manure) at farm level. The 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 obtain a dataset with coherent data on crops and nitrogen application at field level. Data on

catch crops and grass-ley are derived from field maps for 2023 as well as the previous and the following year.

The field maps 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, the standard harvest yield may be estimated. Furthermore, nitrogen

fixation is included using standard values for each crop. This final dataset now contains all information necessary for

geographically distributed computation 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 produced manure originate from pigs, and a cattle farm is defined as a

farm where at least 2/3 of the produced manure originate from cattle. An arable farm is a farm with a production of

organic fertiliser of less than 20 kg N ha

-1

. The farms may import raw animal manure or manure treated in biogas plants,

which will appear in the fertiliser account and is therefore included in the analysis. Other farm types are not included in

this analysis. The area occupied by organic farms constitutes about 303.600 ha in 2023 (Landbrugsstyrelsen, 2023).

Figure 4.3

shows that arable farms and pig farms grew cereals, particularly winter wheat, on most of the agricultural

area (54 and 67%) in 2023. Other major cash crops were oilseed rape, peas, root crops (potatoes and sugar beet) and

grass for seeds (23-26%). Cereal silage, grass and maize constituted a lesser part of the area (5-14%). Catch crops

were grown on 17-20% and newly established grass-ley on 1-2% of the agricultural area on arable and pig farms as an

autumn-winter plant cover.

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FIGURE 4.3:

Crop distribution for three main farm types in 2023. Combined dataset from the basic payment

Cattle farms have a different crop rotation. Cereals and other cash crops were grown on 39% of the area, whereas

cereal silage, grass and maize were grown on 56% of the area. In addition, grass-ley was found on 7% and catch crops

on 18 % 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, 100 kg N ha

-1

and 122 kg N ha

-1

(Table

4.2).

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 atmospheric deposition amounted to 175, 199 and

235 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 66, 86 and 94 kg N ha

-1

for arable farms, pig

farms and cattle farms, respectively. Modelled nitrate leaching was lower from arable farms (on average

kg N ha

-1

)

than from animal husbandry farms (59 kg N ha

-1

from pig farms and 58 kg N ha

-1

from cattle farms). In 2023, the

calculated N leaching for the pig farms and the cattle farms were, on average at the same level.

TABLE 4.2 N inputs, N balances, nitrate leaching and nitrate concentration at the bottom of the root zone for

three main farm types in 2023 based on model calculations using NLES5. Combined dataset. Organic farms

were not included in the analysis.

N balance

Inorganic

fertiliser

Animal

manure

Other

org.

Seeds Total

fix. depos.

input

(kg N ha

-1

)

Har-

vest

balance

Perco-

lation

(mm a

-1

)

Root zone water

Nitrate

leaching

(kg N ha

-1

)

conc.

(mg l

-1

)

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Arable

Pigs

Cattle

100

122

4.5

1.6

1.3

8,1

6.0

24.1

2.0

2.1

1.6

175

199

235

108

113

141

346

388

417

On arable farms, the modelled nitrate leaching amounted to 61% of the N balance, whereas the value was 78%

calculated for pig farms and 69% for cattle farms.

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 located 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 nitrate concentration in the soil water. Thus, the

modelled average nitrate concentrations in soil water were 66 and 67 mg NO

-1

on arable and pig farms, respectively,

and 62 mg NO

-1

on cattle farms for the year 2023.

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.).

FIGURE 4.4 Farming regions in Denmark used in the analysis and the location of the six monitored agricultural

catchments.

TABLE 4.3

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.

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TABLE 4.3 Distribution of farm types and soil types in Denmark divided into five main geographical areas –

2023.

Arable

Pig

Cattle

Other

Sand

Organic

soils

% of agricultural area

Loam

% of agricultural area

Zealand

Jutland E+ Funen

Jutland N

Jutland NW

Jutland W

FIGURE 4.5 Crop distribution for five farming regions in Denmark in 2023. Combined dataset from the basic

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.).

The input of nitrogen with animal manure, the total nitrogen input and the field nitrogen balances are lowest on Zealand,

higher in E Jutland and on Funen and highest in W, NW and N Jutland (TABLE

4.4).

In the latter three areas, the

average nitrogen input varied between 194 and 213 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 concentrations of the soil water,

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resulting in an average nitrate concentration in soil water of 69, 65, 71, 59 and 60 mg NO

-1

on Zealand, Funen + E

and N Jutland, and NW and W Jutland, respectively.

TABLE 4.4 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 2023. Combined dataset from the basic payment

N balance

Inorganic Animal Other

fertiliser manure org. N

N-fix.

N-

Seeds

depos.

kg N ha

-1

1.8

1.9

Total

input

Har-

vest

balance

Root zone water

Perco-

lation

mm a

-1

245

338

Nitrate

leaching

kg N ha

-1

conc

mg l

-1

Zealand

Jutl. E

+Funen

Jutland N

Jutland NW

Jutland W

112

3.0

3.1

8.1

10.9

171

187

113

112

105

107

2.4

0.7

4.3

16.3

13.9

15.1

1.7

1.8

2.0

194

200

213

114

118

125

360

439

512

Derogation farms

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

There is a trend indicating a decrease in areas with cereals and an increase in the areas with catch crops with

increasing livestock density. In addition, the area with fodder crops including maize increases with increasing livestock

density. The area with roughage (cereal silage, rotation grass and permanent grass) amounted to 34, 30 and 37% 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 48% of the area in average. The area with grass-ley or catch crops amounted to 20, 27 and

34% for the three groups, 0-100, 100-140, 140-170 use of organic N including manure ha

-1

, respectively, whereas

grass-ley or catch crops on derogation farms grew catch crops or grass-ley on 36% of the area in average.

The effect of derogation on nitrate leaching was evaluated separately for the three geographical areas. The nitrogen

input as well as the field nitrogen balances increased with increasing livestock density (

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TABLE

4.5).

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

leaching due to increased nitrogen input and a decrease in leaching due to an increased area with roughage and catch

crops.

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TABLE

4.5

shows that the modelled nitrate leaching generally increased with increasing livestock density and hence

with increasing nitrogen input. Thus, differences occurred in the modelled annual nitrogen leaching of 2, 5 and 7

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 Jutland regions N, NW and W, respectively. Modelled nitrate concentrations in the soil water

leaving the root zone were 3-6 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 fertilisers for the three regions.

FIGURE 4.6 Average crop distribution for four groups of livestock density in N, NW and W Jutland in 2023.

Combined dataset from the basic 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 4.6.

The general trend is that

derogation farms grow less legumes than non-derogation farms. Thus, clover or alfalfa (max. 50% share) in rotation

grass was used on 72% of the rotation grass area for derogation farms and on 77-84% for non-derogation farms. For

permanent grass including legumes, the equivalent values were 54% for derogation farms and 51-54% for non-

derogation farms. Cereal silage with peas amounted to 26% of the silage area for derogation farms and 21-34% for

non-derogation farms.

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TABLE 4.5 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, 2023. Combined dataset from the basic payment register and the fertiliser accounts. Organic farms

were not included in the analysis.

N balance

Annual use

Total

of organic Inorganic Animal Other N fix.

Seeds

Harvest Balance

depos.

input

fertiliser manure org.N

kg N ha

-1

Jutland N

0-100

100-140

140-170

170-230

Jutland NW

0-100

100-140

140-170

170-230

Jutland W

0-100

100-140

140-170

170-230

Root zone water

Perco-

lation

Nitrate

leaching

conc

Region

kg N ha

-1

106

145

181

111

145

179

112

150

184

2.1

0.7

0.1

0.0

1.7

1.0

0.1

0.0

7.2

2.4

0.5

0.0

1.2

1.4

1.3

1.6

1.7

1.5

1.4

1.8

1.9

1.7

1.5

158

205

257

298

167

209

251

292

161

221

263

297

120

150

173

108

122

146

176

106

130

155

176

107

125

105

116

108

121

mm a

-1

kg N ha

-1

mg l

-1

355

366

358

436

440

435

443

500

524

532

535

TABLE 4.6 Use of legumes in grass and cereal silage at cattle farms for derogation and non-derogation farms

2023. Organic farms were not included in the analysis.

Use of organic N, including manure (kg N ha

-1

)

0-100

100-140

140-170

170-230

share of agricultural area (%)

Rotation grass

9.8

13.8

share of rotation grass (%)

No clover/alfalfa

< 50% clover/alfalfa

> 50% clover/alfalfa

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Table 4.6 (continued)

share of agricultural area (%)

Permanent grass

16.5

11.0

6.9

share of permanent grass (%)

No clover/alfalfa

< 50% clover/alfalfa

> 50% clover/alfalfa

share of agricultural area (%)

Cereal silage

1.2

2.0

3.5

share of cereal silage (%)

No legumes

< 50% legumes

100% legumes

7.3

5.4

4.4 Development in modelled nitrate leaching in the Agricultural Catchment

Monitoring Programme 1990-2023

This section deals with the general development in nitrate leaching from 1990/91 to 2022/2023 for measured nitrated

concentrations in soil and ground water and 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 practises (FIGURE

4.).

The farmers are

interviewed every year about livestock, crops and fertilisation and cultivation practises.

Modelled nitrate leaching presented for these five catchments was in the former derogation reports (reports compiled

before 2023) modelled using the NLES3 and NLES4-models. The model was updated and recalibrated to a new

NLES5-model using a larger dataset in 2020 (Børgesen et al., 2020, 2022). Since 2023, the time series of nitrate

leaching for the agricultural catchments (fig 4.7) has been modelled with the NLES5 model. The modelling results are

therefore not directly comparable to the results in the former derogation reports (before 2023).

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 2023, 118 farmers participated in the investigation. Of all the investigated farms, 17 were cattle farms. Two of the

cattle farms were registered as derogation farms. These derogation farms covered 6,6% of the total area in the

Agricultural Monitoring Catchments in 2023. In addition to the cattle farms registered as derogation farms, three farms

without cattle production were registered as connected to a cattle derogation farm. This means that these farms also

have permit to apply more than 170 kg N ha

-1

organic fertiliser if they comply with certain terms and conditions. Only

one of these farms have actually exploited this permit. This connected derogation farm covered additional 3,5% of the

total area in the Agricultural Monitoring Catchments.

The modelled nitrate leaching from the agricultural areas in the catchments was calculated using collected data for

crops and fertilization for the period 1990 to 2023 (representing the hydrological years 1990/91 to 2023/24). The

modelled leaching is shown in

FIGURE 4.7

as an average for sandy and loamy catchments, respectively.

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FIGURE 4.7 Simulation of the nitrate leaching using the NLES5 model in a standard climate for the fields of

three loamy and two sandy catchments within the Agricultural Catchment Monitoring Programme 1990/91-

2023/24.

With the present model calculation with NLES5, a decrease in the modelled nitrate leaching of 46 % has been achieved

for the entire period 1991/92 to 2023/24, 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 corresponding decrease was approx. 43% (Blicher-Mathiesen et al., 2021). The model calculation in LOOP

only has data after 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) with 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 below 40 kg N ha

-1

in the period 2015-2022. In 2022/23 and 2023/24 the simulated

leaching decreased to 32-33 kg N ha

-1

for the loamy catchments, which are the lowest values simulated for the entire

period 1990/91-2023/24, which is caused by the modelled effect of an increased area with catch crops. For the sandy

catchments, the modelled annual nitrate leaching was relatively stable around 70 (kg N ha

-1

during the period 2003-

2022. In 2023/24 the simulated leaching decreased to 60 kg N ha

-1

for the sandy catchments. The lower modelled

leaching after 2013 is mainly due to more cover crops after cereals and maize.

The purpose of the root zone modelling is to show the effects of measures introduced to mitigate nutrient losses from

agriculture. The modelling is therefore carried out for climate normalised 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 measurements depend on the actual

climate. The period 1990-2010 covers a period where the Danish precipitation data were measured using the same

method. From 2011, there was a change in both the measurement method and the number of stations available, which

may influence the modelled water balance, and thereby influence the modelled nitrate leaching (Svendsen & Jung-

Madsen 2020).

4.5 Measurements of nitrate in water leaving the root zone and in upper

oxic groundwater

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 and on a loamy soil in 2020 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

values of measured nitrate leaching in some of the monitored years. Out of the remaining 26 sites on agricultural areas,

13 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

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representative 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 (autumn, winter and spring) and monthly in

summertime when percolation is scarce or zero. Percolation is modelled because it is difficult to perform to

measurement of water content and flow in soil covering soil variability at field level (Blicher-Mathiesen et al., 2014). The

annual flow-weighted nitrate concentration is calculated by dividing the annual nitrate leaching by the annual

percolation.

Since the publication of the annual derogation report for 2018, inconsistencies in the precipitation time series have been

detected (Svendsen & Jung-Madsen (Ed.) (2020); Andersen (Ed.) (2021)). These inconsistencies affect the reported

flow-weighted concentrations as the precipitation 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 when

comparing data from before and after 2010, respectively. The precipitation is measured at several rain gauge stations

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 decreased 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 derived 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 4.8

and

Figure 4.12

represent this uncertainty from variation in precipitation on field

level but tabulated as an average uncertainty from ten precipitation grids (Blicher-Mathiesen et al., 2024).

The nitrate concentrations in the root zone (flow-weighted) and upper oxic groundwater are shown as annual average

values for loamy and sandy soils, respectively, for the period 1990/91 to 2022/23 (FIGURE

4.8).

In upper oxic groundwater there is a large variation in the measured nitrate concentrations between the monitoring

points. In general, there is a significantly higher nitrate content in the groundwater in the sandy compared to the clay

catchments. In 2023, in the oxic upper groundwater in the sandy and clay catchments, there are respectively approx.

74% (14 out of 19) and approx. 26% (6 out of 23) of the monitoring points where the nitrate content on average is above

50 mg/l.

Generally, measured data on nitrate leaching from the root zone at only 26 sites cannot be used directly for estimating

the effect of a single variable as the input of fertiliser or manure because 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 from the 26 fields included in the agricultural monitoring catchments, together with leaching data from

other agricultural monitoring programmes, were used for development of the nitrate leaching model, NLES5, which was

subsequently used for calculating the leaching from all the fields in the catchments accounting for agricultural practises.

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FIGURE 4.8 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), in the Agricultural Catchment Monitoring Programme 1990/91 to 2022/23. Error bars on the

root zone data indicate variation in percolation as precipitation varied on local scale within a DMI 10 x 10

precipitation grid. Further details om the variation in data, i.e. standard deviations on measured

groundwater concentrations, are presented in the annual report for the Agricultural Monitoring Programme

(Blicher-Mathiesen et al., 2024).

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 besides the choice of crop rotation, management and application of fertilisers. 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 of the development in annual flow weighted nitrate concentrations and nitrate leaching was

made (Blicher-Mathiesen et al., 2024). The analysis covers the period 1990/91-2022/23 and is further divided into two

sub-periods, i.e. before and after 2003/04 where Action Plan for the Aquatic Environment (APAE) II was implemented.

The analysis was carried out at catchment level and in addition, the analysis was supplemented with trend analyses of

the climate data used to calculate the percolation used for converting measured soil water concentrations to annual flow

weighted nitrate concentrations and nitrate leaching.

In the three catchments located in the western part of the country (Jutland), the trend analysis showed a significant

reduction in both nitrate leaching (1-2 kg N ha

-1

per year) and concentration (1-2 mg NO

-1

per year) seen over the

entire period (1990/91-2022/23). Looking at two sub-periods, the downward trend can be related to the first period

1990/91-2003/04. In the second period 2004/05-2022/23, no significant changes in either nitrate concentrations or

nitrate leaching can be detected in two of the catchments whereas a significant increase in both nitrate concentrations

and nitrate leaching was seen in one of the catchments during the last period. The increase in nitrate leaching and

runoff-weighted nitrate concentration in this catchment cannot be explained by similar changes in climate data and

percolation.

In the two catchments located on the Southern Islands of Denmark (Funen and Lolland) a significant downward trend in

nitrate leaching (1 kg N ha

-1

per year) was seen over the entire period, which is not reflected in a corresponding trend in

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the nitrate concentrations. Looking at the two sub-periods, the downward trend for these two catchments can also be

related to the first period 1990/91-2003/04. In the second period, a significant upward trend in nitrate concentrations

(1,7 mg NO

-1

per year) was seen in one of the catchments and a similar non-significant trend (2,5 mg NO

-1

per year)

was seen in the other catchment. The trends in nitrate concentrations are not reflected in similar trends in the nitrate

leaching. This may be related to the development in the water balance in these two catchments, as the trend analysis

also shows that percolation calculated over the entire period 1990/91-2022/23 has decreased significantly by 4-5 mm

per year in these two catchments. This decrease in percolation is caused by increased evapotranspiration and

decreased precipitation in these regions in the latter part of the period (2004/05-2022/23) (Blicher-Mathiesen et al,

2024).

Supplementing analysis has shown a general correlation between calculated percolation and nitrate leaching on the

clay soils which are dominating in these two catchments (Blicher-Mathiesen et al., 2024). The observed changes in

percolation can thus contribute to the observed increase in nitrate concentrations.

In the loamy catchments, the measured nitrate concentrations in root zone water decreased from 61-155 mg NO

-1

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

-1

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

2018/19-2022/23 the concentrations have varied from 66 to 116 mg NO

-1

. In the sandy catchments, the nitrate

concentration decreased from 73-192 mg NO

-1

in 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 2018/19-2022/23 the concentrations have varied from 61 to 113

mg NO

-1

(Figure

4.8).

High nitrate concentrations were measured in the hydrological year 2018/19 after the dry

growing season in 2018 with drought and low yield as well as low percolation in the winter period. In contrast, low

nitrate concentrations were measured in 2019/20 due very high percolation diluting the nitrate leaving the root zone. It

should be noted that the measurements of nitrate leaching originate from a small number of sampling stations (26

stations). Furthermore, the measurements are affected by crop yields 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. 118 farms.

In the upper oxic 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 between the bottom of the root zone and the

uppermost groundwater (FIGURE

4.8).

In 2023, the average nitrate content is 72 mg NO

-1

and 36 mg NO

-1

in the sand and loamy catchments, respectively.

There is a trend of increasing nitrate concentrations in the oxic groundwater since around 2015 in the loamy catchments

and since around 2007 in the sandy catchments.

In the oxic groundwater, the largest decrease in nitrate concentrations is observed in the first half of the monitoring

period. For the loamy catchments, the average nitrate concentration is below the groundwater limit value of 50

mg NO

-1

in the whole monitoring period. For the sandy catchments, the average nitrate concentration in the oxic

groundwater is above the limit value of 50 mg NO

-1

for most of the monitoring period.

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 2012-2022

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

-1

in the recent 10 years

(2013/14 to 2022/23), and six sites received an average of more than 170 kg organic 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 recent 20-year period

2003/04 to 2022/23 (Figure

4.9A

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 2001-2011 to a lower input (<170 kg N ha

-1

) in the following years (FIGURE

4.9.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 nitrate concentrations varied at a lower level than “st 604” in the period

where the annual average manure application was more than 170 kg N ha

-1

, (2003/04 to 2012/13) and showed

increased concentrations in the period where the annual average manure application was less than 170 kg N ha

-1

(2013/14 to 2022/23).

At two other sites, station “st 201” and “st 608”, the manure input changed from a low annual input (<170 kg N ha

-1

) in

the period 2003-2014 to a higher input (>170 kg N ha

-1

) in the following years (FIGURE

4.9.B).

In the period with an

annual average manure application of less than 170 kg N ha

-1

, nitrate concentrations were low at “st 608” compared to

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the following period. 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

, (2003/04 to 2012/13).

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 (2013/14 to 2022/23) varied between 47 and 130 mg

-1

(during the same period (Figure

4.9D).

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 40 and 111 mg NO3 l-1 for the recent ten hydrological years

(2013/14 to 2022/23) (Figure 4.9C). 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.

FIGURE 4.9 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 application of organic manure N is shown in brackets).

Annual averages for the measured stations, average application of 130-170 kg ha

-1

kg N ha

-1

in manure and other organic fertilisers (D). All data from the period 2002/03 to 2022/23 are

shown. The annual variation in application of organic fertiliser on the individual fields is large because

the amount depends on the type of crop grown in the field.

Annual variations in measured concentrations at the individual monitoring stations were expected, 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 2013/14 to 2022/23 and the sites that received an average >170 kg N in

manure ha

-1

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

4.9).

High nitrate concentrations are most likely a result of crop rotation, especially turnover of grass-clover 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 inFIGURE

Generally, the concentrations

varied between 0.005 and 0.050 mg PO

-P l

-1

, irrespective of the use of organic manure. In all the sites, P

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concentrations were much more variable in the first part of the period (until 2011/12) and in three fields (“st 601”,

“st 607” and “st 608”) P concentrations exceeded 0.05 mg PO

-P l

-1

in some years. The soil texture in these fields is

coarse sand, and they are located in an area with high rainfall. Since 2011/12, the max. annual P concentrations at all

monitored stations have been below 0.020 PO

-P l

-1

FIGURE 4.10 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

2002/03 to 2022/23 are shown.

4.6 The nitrogen cycle in agricultural catchments

This chapter gives an overview of the nitrogen pathways in the hydrological cycle and describes the trends for nitrate in

water for the period 1990 to 2022. Continued monitoring within the framework of the Agricultural Catchment Programme

and the Stream Programme will provide indicators for the future development.

When percolating water leaves the root zone, it can conceptually be partitioned into a component 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 or coastal areas. In Denmark, the pathways for water and nutrients in

agricultural catchments are analysed in the Agricultural Catchment Monitoring Programme. The circles are described

based on the nitrate concentrations measured in soil water, water from tile drains, upper groundwater and surface water

from the 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 integrate the effects of all activities in the catchment.

However, the monitoring programme will provide 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 response to precipitation (

TABLE 4.7)

(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 deeper often reduced groundwater.

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TABLE 4.7 Partitioning of water flow in streams into three components – rapid, intermediate 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%

Intermediate

16%

Slow

43%

20%

23%

57%

FIGURE 4.11 Measured means of nitrate concentrations in the hydrological cycle in three loamy catchments

and two sandy catchments included in the Agricultural Catchment Monitoring Programme. Values in streams,

groundwater 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 2018/19 to 2022/23.

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

4.11)

(Blicher-Mathiesen et al., 2024).

Figure 4.12

illustrates measurements of nitrate concentrations (mg NO3 l

-1

) in soil root zone water, upper oxic

groundwater (1.5-5 m below ground level) and in streams.

When water percolates from the root zone to the groundwater, denitrification processes take place in anoxic nitrate

reducing zones. The location and depth to the anoxic nitrate reducing zone in groundwater are depending on the local

hydrogeology and biogeochemical potentials for denitrification. Thus, nitrate concentrations in the groundwater can be

lower than in the root zone water, however on sandy soils the concentrations in the root zone and oxic groundwater are

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at the same level. When the water passes through the deeper part of aquifers the probability for reduction is higher than

with more near-surface flow paths.

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FIGURE 4.12 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,

1990/91-2022/23.

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

to the streams has often been exposed to reduction processes. Thus, nitrate concentrations 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 located in the western and

northern parts of Jutland that are characterised by sandy soils and subsurface layers, leading to deeper groundwater

flow with relatively high nitrate removal and resultant lower nitrogen concentrations in the streams. However, the upper

oxic groundwater under sandy soils is more pronounced contaminated with nitrate.

Trends in nitrate concentrations and transport in the hydrological cycle

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

FIGURE

Statistical analyses of the trend in annual flow weighted nitrate concentrations and nitrate leaching showed a significant

reduction in nitrate leaching (1-2 kg N ha

-1

per year) seen in all five monitoring catchments over the entire monitoring

period (1990/91 to 2022/23). A similar reduction trend in flow weighted nitrate concentrations concentration were seen

in the catchments located in the Western part of Denmark (Jutland) (1-2 mg NO

-1

per year), whereas no significant

reduction in nitrate concentrations was seen in the two catchments located on the islands in the Southern part of

Denmark (Funen and Lolland). The downward trends are primarily related to the first part of the period (1990/91 to

2003/04). In the second part of the period (2004/05 to 2022/23) no significant reductions were seen in any of the

catchments.

In the oxic groundwater, the largest decrease in nitrate concentrations is observed in the first half of the monitoring

period. For the loamy catchments, the average nitrate concentration is below the groundwater limit value of 50

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mg NO

-1

. For the sandy catchments, the average nitrate concentration in the oxic groundwater is above the limit value

of 50 mg NO

-1

for most of the monitoring period.

In the Stream Monitoring Programme, the trend is analysed for a larger number of streams. This programme reported

that during the period 1989-2023 in 36 agriculturally dominated catchments representing both loamy and sandy soils,

there was an average reduction of 40% (±9%) in the flow weighted nitrogen concentrations (Thodsen et al., 2024).

4.7 References

Abrahamsen, P., & S. Hansen. (2000). Daisy: An open soil-crop-atmosphere system model. Environ. Model. Softw.

15(3): 313–330. doi: 10.1016/S1364- 8152(00)00003-7

Andersen R.C. (Ed.). (2021). Undersøgelser af DMI’s nedbørsdata til anvendelse for hydrologiske formål.

Afrapportering til miljøministeriet. Danmarks Meteorologiske Institut.

https://www.dmi.dk/fileadmin/Rapporter/2021/Undersoegelser_af_DMI_s_nedboersdata_til_anvendelse_for_hydrologis

ke_formaal.pdf

Blicher-Mathiesen, G., Thorsen, M., Wienke, J., Petersen, J., Andersen, H.E., Frederiksen,

R.F., Jensen, P.G., Hansen, B. & Thorling, L. 2024. Landovervågningsoplande 2023.

NOVANA. Aarhus Universitet, DCE - Nationalt center for Miljø og Energi, 291 s. -

Videnskabelig rapport nr. 628.

https://dce.au.dk/fileadmin/dce.au.dk/Udgivelser/Videnskabelige_rapporter_600-

699/SR628.pdf

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 suction cup-measured N

leaching in Danish catchments. Agriculture, Ecosystems and Environment 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 agricultural land. European Journal of Agronomy 134,

126465.

Finansministeriet, 2024. Second opinion. Evaluering af det faglige grundlag for kvælstofindsatsen. Finansministeriet,

Ministeriet for Grøn Trepart og Ministeriet for Fødevare, Landbrug og Fiskeri. 126 s.

https://www.ft.dk/samling/20231/almdel/mof/bilag/672/2909893.pdf

Grant, R. & Waagepetersen, J. (2003). Vandmiljøplan II – slutevaluering. Faglig udredning fra Danmarks

Miljøundersøgelser og Danmarks JordbrugsForskning. 32 s.

https://www2.dmu.dk/1_viden/2_Publikationer/3_Ovrige/rapporter/VMPII/VMPII_Slutevaluering.pdf

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.

Kronvang, B., Andersen, H.E., Børgesen, C., Dalgaard, T., Larsen, S.E., Bøgestrand, J. & Blicher-Mathiesen, G.,

(2008). Effects of policy measures implemented in Denmark on nitrogen pollution of the aquatic environment.

Environmental Science & Policy 11, 144-152.

Landbrugsstyrelsen (2023). Statistik over økologiske jordbrugsbedrifter 2023. Landbrugsstyrelsen, Ministeriet for

Fødevarer, Landbrug og Fiskeri.

https://lbst.dk/Media/638501567069502812/Statistik_over_oekologiske_jordbrugsbedrifter_2023.pdf

Ministry of Green Transition of Denmark / Nitrates Directive / Derogation Report 2024

MOF, Alm.del - 2024-25 - Bilag 454: Orientering om rapport jf. ophørt undtagelse fra nitratdirektivet (kvægundtagelsen), fra ministeren for grøn trepart

Lov om ændring af lov om naturbeskyttelse. (2020, L nr. 1057 af 30/06/2020).

https://www.retsinformation.dk/eli/lta/2020/1057

Miljøministeriet. (2023). Vandområdeplanerne 2021-2027. 276 s.

https://mim.dk/media/235166/vandomraadeplanerne-

2021-2027-5-7-2023.pdf

Rolighed, J. (2023). Oparbejdning af landbrugsregisterdata og beregning af referenceudvaskning for nitrat med NLES5.

Aarhus Universitet, DCE – Nationalt Center for Miljø og Energi, 34 s. - – Fagligt notat nr. 2023|62

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 stoftransport. NOVANA. Aarhus Universitet, DCE –

Nationalt Center for Miljø og Energi, 74 s. - Videnskabelig rapport nr. 452

Thodsen, H., Tornbjerg, H., Larsen, S.E., Conradsen, A.R., Muff, E. & Blicher-Mathiesen, G. 2024. Vand- &

Stoftransport 2023. Aarhus Universitet, DCE – Nationalt Center for Miljø og Energi, 71 s. - Videnskabelig rapport nr.

629.

https://dce.au.dk/fileadmin/dce.au.dk/Udgivelser/Videnskabelige_rapporter_600-699/SR629.pdf

SVANA (2016). Vandområdeplaner 2015-2021. Styrelsen for Vand og Naturforvaltning. Miljø- og Fødevareministeriet.

https://mst.dk/natur-vand/vandmiljoe/vandomraadeplaner/vandomraadeplaner-2015-2021/vandomraadeplaner-2015-

2021/

Svendsen, L.M. & Jung-Madsen, S. (Ed.) 2020. Homogenitetsbrud og potentielle fejl i nedbørsdata. 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/fileadmin/dce.au.dk/Udgivelser/Notatet_2020/N2020_51.pdf

Wiberg-Larsen, P., Windolf, J., Bøgestrand, J., Larsen, S.E., Thodsen, H., Ovesen, N.B., Bjerring, 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.

Ministry of Green Transition of Denmark / Nitrates Directive / Derogation Report 2024

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5. Indicator and monitoring

system for application of

phosphorus in Denmark

The Agency for Green Transition and Aquatic Environment, Ministry of Green

Transition, December 2024

5.1

Introduction

In consultation with the European Commission, the Ministry of the Environment and Food

(since September 2024 the Ministry of Green Transition) has agreed that Denmark must

monitor the use of phosphorus (P) in organic fertiliser and commercial fertiliser, so that it is

ensured that the average use does not exceed the national phosphorus ceiling. The

monitoring is based on data from the fertiliser accounts, which is available approximately one

year after a planning period is completed, when the farmers submit their fertiliser accounts to

the Agency for Green Transition and Aquatic Environment (until September 2024 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

established, where data from the NOVANA monitoring program in Agricultural Catchments

(LOOP) in combination with available data on livestock production and sales of fertiliser 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. It was agreed, that the total amount of phosphorus used should

be divided by the total agricultural area in order to calculate the average fertiliser rate per year

per ha on agricultural land. No requirement was set for the first planning period, 2017/2018,

but for the subsequent planning periods a gradually declining requirement has been set.

In 2018/2019 the average use should be below 34.7 kg P/ha, in 2019/2020 it should be below

34.1 kg P/ha, in 2020/2021 and 2021/2022 it should be below 33.2 kg P/ha and in 2022/2023 it

should be below 32.0 kg P/ha.

In 2023/2024 and 2024/2025 the average use must be below 32.0 kg P/ha. From the planning

period 2025/2026 and onwards the average use must be below 30.0 kg P/ha. If the average

use exceeds 33.2 kg P/ha, the phosphorus ceilings must be lowered.

5.2

Results from the P monitoring system

The Danish Agricultural Agency compiled data from the fertiliser accounts with data from the

planning period 2022/2023. 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 fertiliser accounts can have an important influence on

the overall results, so the results represent a “worst case” scenario of phosphorus use.

Table 6.1 Compiled data from fertiliser accounts 2022/2023 (rounded numbers).

Ministry of Green Transition of Denmark / Nitrates Directive / Derogation Report 2024

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Produced P

(tons)

Poultry/fur

Finishers

Sows and piglets

Cattle (non-derogation)

Cattle (derogation)

Manure – Total

Waste and other P

Manure + waste

Chemical fertilisers

Used P – Total

2,300

7,400

7,300

12,100

7,100

36,200

Used P

(tons)

37,500

3,400

40,900

10,300

51,200

Mio. ha

Agricultural area

Harmony area

The average national phosphorus ceiling in

2022/2023

Kg P/ha agricultural area

Kg P/ha harmony area

2,600

2,300

32,0

19.9

22.6

5.3

Results from P indicator system

The following table shows the phosphorus inputs as reported in the NOVANA report "Land

Surveillance Survival 2022" from 2024

. The table shows an increase as expected in the use

of phosphorus 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

phosphorus is not expected to continue.

Source: Blicher-Mathiesen, G., Thorsen, M., Wienke, J., Petersen, J., Andersen, H.E., Frederiksen, R.F., Jensen, P.G., Hansen, B. &

Thorling, L. 2024. Landovervågningsoplande 2023. NOVANA. Aarhus Universitet, DCE - Nationalt center for Miljø og Energi, 291 s. -

Videnskabelig rapport nr. 628.: https://dce.au.dk/fileadmin/dce.au.dk/Udgivelser/Videnskabelige_rapporter_600-699/SR628.pdf

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Table 6.2 The use of P-input in Danish agriculture in 2013-2023

2013

Use of P (1,000

tons) in different

inputs:

- Chemical fertiliser

- Livestock manure

- Seed

- Sludge

- Waste from

industry

- Other organic

fertiliser

- 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]

0.3

70.5

2,610

27.0

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

2.8

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

3.5

0.26

61.3

2,588

23.7

33.2

14.8

44.3

1.0

14.6

44.9

1.0

16.0

43.8

1.0

14.9

43.8

1.0

11.0

45.5

1.0

10.3

41.3

1.0

2014

2015

2016

2017

2018

2019

2020

2021

2022

2023

3.3

0.26

56.2

2,586

21.7

32,0

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

prepared an annual status on the size of livestock production in various catchments. This

annual status is now done instead on the basis of the fertiliser accounts, which is why the best

data material on the development in livestock production is the annual status of the livestock

population, which is made by Statistics Denmark. Statistics Denmark's information on livestock

in 2017-2021 can be seen in

Table 6.3.

From 2018 onwards, amount of other organic waste, such as sludge and waste from industry, is derived

from the fertiliser accounts.

Agricultural area for the years 2016, 2017 and 2018 has been updated after submission of the Derogation

Report 2019.

This figure indicates the average phosphorus protection level in 2016 expressed as a theoretical P-

ceiling, 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, 2020, 2021, and 2022

change

Number of

animals

2017

Number of

animals

2018

Number of

animals

2019

Number of

animals

2020

Number of

animals

2021

Number of

animals

2022

Number of

animals

2023

in total

number

animals

2017-

2022

Number

of all

kinds of

cattle

and

dairy

cows

on all

farms

Number

of all

kinds of

pigs on

all farms

12,307,667

12,781,247

12,298,993

13,162,627

13,168,466

12,373,343

10,823,382

-12.06

1,545,417

1,540,446

1,491,433

1,498,713

1,488,421

1,471,383

1,442,502

-6.66

Number

of all

kinds of

poultry

on all

farms

21,483,698

19,973,164

23,059,881

22,132,858

21,891,757

23,057,926

22,633,916

5.35

Number

of all

kinds of

mink on

all farms

3,429,472

3,379,931

2,489,751

2,234,101

-100

The manure production based on data from the fertiliser accounts (table 2.3) shows that 4 % of

the total manure production comes from poultry, 35 % from pigs and 60 % 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 2024, 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

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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2019, 33.2 kg P/ha in 2020 and 2021 and further reductions set for 34 kg P/ha in 2022 and 33

kg P/ha in 2025.

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6. Targeted catch crops

scheme and targeted

nitrogen regulation

The Agency for Green Transition and Aquatic Environment, Ministry of Green

Transition, December 2024

6.1

Introduction

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

develop a new nitrogen regulation, the “targeted nitrogen regulation”, which was to be

implemented 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

uncompensated 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 nitrogen reducing 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 subsidized by de minimis in 2019 and by

RDP funds in 2020, 2021, 2022 and 2023. In 2024, the subsidy is funded by CAP 2023.

After the application deadline in the voluntary crop scheme, the farmer is bound by any

commitment 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 of the voluntary scheme after the application deadline, or if non-

compliance is detected during control, the nitrogen quota for the farm (calculated on the basis

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of the composition and distribution of crops and the soil and crop-specific nitrogen standards)

is reduced. The reduction corresponds to the non-compliance with the voluntary requirement.

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 Directive.

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,

political agreement increased the effort of the targeted nitrogen regulation in 2020 for

additional contribution to meet the objectives of The Water Framework Directive. In 2020,

2021, 2022, 2023 and 2024, the targeted nitrogen regulation has contributed to a nitrogen

reduction of 3,500 tons in coastal waters each year. The reported reduction is contingent on

the farmers fulfilling their obligations, however, based on control results, a minor loss of effect

is assumed. The ministry is currently working on estimating this loss of effect.

6.2

Results from 2017 to 2024

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

required 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 retention in the water catchment area. Since 2019,, the targeted nitrogen regulation

has been dimensioned to comply with the Danish implementation of The Water Framework

Directive.

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

geographical distribution of the catch crops was not optimal in relation to the efforts needed.

Calculations 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.

2018,

the need for further nitrogen effort was calculated to 114,300 ha catch crops

(including 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

aquaculture (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

nevertheless needed in order to reach the target. This has been implemented as a mandatory

uncompensated requirement in 2018.

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.

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

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specific retention disclosed that an additional

12,493

ha were needed to reach the set national

nitrogen reduction effort. Consequently, this was implemented as a mandatory

uncompensated requirement in 2020. Excluding a minor residual effort of 350 ha of catch

crops, which was decided politically to postpone.

2021,

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

relation 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

for the voluntary phase. 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.

2022,

the need for nitrogen efforts was 3,514 tons of nitrogen, which after allocation to the

individual catchment areas corresponded to 373,500 ha. By the application deadline, the

farmers had applied for 352,500 ha of catch crops and alternatives. A total of 350,150 ha was

approved for the voluntary phase. An additional effort corresponding to

22,200

ha was needed

to meet the national nitrogen effort goal. This remaining effort was implemented as a

mandatory uncompensated requirement in 2022.

2023,

the target for nitrogen reduction efforts was 3,514 tons of nitrogen, corresponding to

about 373,000 ha of catch crops. A total of 352,800 ha was approved for the voluntary phase.

An additional effort corresponding to

12,320

ha was needed to meet the national nitrogen

effort goal. This remaining effort was implemented as a mandatory uncompensated

requirement in 2023.

2024,

the target for nitrogen reduction efforts was 3,500 tons of nitrogen, corresponding to

about 365,000 ha of catch crops. A total of 339,300 ha was approved for the voluntary phase.

An additional effort corresponding to 23,330 ha was needed to meet the national nitrogen

effort goal. This remaining effort was implemented as a mandatory uncompensated

requirement in 2024.

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7. Conclusions

7.1

Cattle holdings and controls on farm level

In the planning period 2022/2023, a total of 818 cattle holdings made use of the derogation.

This corresponds to 3.0 % of the total number of agricultural holdings in Denmark. These

holdings spread 29.7 million kg N corresponding to 14.0 % of the total kg N spread. The arable

land encompassed by the derogation in year 2022/2023 was 154,009 hectares corresponding

to around 6.7 % of the total arable area. Compared to the previous reporting period, in

2022/2023 there has been a decrease in the number of farms and the number of hectares

encompassed by the derogation. The average livestock size was 48,622 kg N produced pr.

holding in 2022/2023.

In January – February 2024, 60 inspections of compliance with the derogation management

conditions were carried out. 56 holdings complied with the derogation management conditions.

Four holdings got a remark.

For the year 2021/2022, 64 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). All 64 inspected farms used the derogation. 60 of these inspections were closed

without remarks. One holding was closed with a remark and three holdings are still under

investigation.

All 28,118 fertilizer accounts submitted in 2021/2022 (100 %) were automatically screened by

the IT-system according to normal procedure. Of these, 887 (3.2 %) were subject to

administrative control or administrative inspections. In all, 110 of these holdings used the

derogation. Of the inspections of derogation farms, 92 (83.6 %) were closed without remarks,

11 (10.0 %) were closed with remarks and 7 (6.4 %) are still under investigation.

For the year 2022/2023, 7.3 % of derogation farms had physical inspections. In total, more

derogation farms have been subject to controls due to the aforementioned administrative

inspections. As holdings are automatically selected - based on a previously agreed set of risk

criteria - for both physical inspections and administrative inspections, the Agency for Green

Transition and Aquatic Environment 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 subject to controls varies from year to year.

7.2

Agricultural practices and water quality

In 1998 the Action Plan for the Aquatic Environment (APAE) II was accepted by the EU

Commission 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

nitrate leaching from the agricultural sector, fulfilling the reduction target set in 1987.

In November 2024 a new political agreement implementing “The deal for a Green Denmark”

was decided, with a national reduction target of 13,800 t N compared with a mean load of

56.200 t N for 2021 and a baseline estimated reduction of 3.700 t N (Finansministeriet, 2024).

The plan for mitigation measures to reach the target nitrogen load will be listed in a revised

version of the third River Basin Management Plan (RBMPIII) in the beginning of 2025. All

mitigation measures to fulfil the reduction target should be initiated in 2027 at the latest. On

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this basis, it is expected that the majority of Danish water bodies will meet the required

nitrogen efforts by 2027.

Modelling of the nitrate concentrations in the soil water leaving the root zone at national level

showed an average concentration of 63-74 mg NO3 l-1 for cattle holdings using 170-230 kg

organic manure N in 2023 and the concentrations were 4-6 mg NO3 l-1 higher for derogation

farms than for cattle farms using 140-170 kg N ha-1 of N in manure and other organic

fertilisers.

Measured average flow-weighted nitrate concentrations in root zone water for the five specific

sites with an average manure application within 170-230 kg N ha-1 during the last 10-year

period varied between 47 and 130 mg NO3 l-1 and 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 40 and 111 mg NO3 l-1 during the same period.

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

concentrations in the water leaving the root zone varied in general between 0.005 and

0.050 mg PO4-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 groundwater from the Agricultural Catchment Monitoring Programme are

that:



Nitrate concentrations in root zone soil water (1.0 m below soil surface) have

decreased from 1990/91 to 2022/23. The main part of the reduction was seen in the

first part of the period (1990/91-2003/04). In the loamy catchments, the measured

nitrate concentrations in root zone water decreased from 61-155 mg NO3 l-1 in the 5-

year period 1990/91-1994/95 to 37-66 mg NO3 l-1 in the 5-year period 2011/12-

2015/16. In the latest 5-year period 2018/19-2022/23 the concentrations have varied

from 66 to 116 mg NO3 l-1. In the sandy catchments, the nitrate concentration

decreased from 73-192 mg NO3 l-1 in the 5-year period 1990/91-1994/95 to 54-73

mg NO3 l-1 in the 5-year period 2011/12-2015/16. In the latest 5-year period

2018/19-2022/23 the concentrations have varied from 61 to 113 mg NO3 l-1.

In the oxic groundwater, the largest decrease in measured nitrate concentrations is

observed in the first half of the monitoring period. For the loamy catchments, the

average nitrate concentration is below the groundwater limit value of 50 mg NO3 l-1

in the whole monitoring period. For the sandy catchments, the average nitrate

concentration in the oxic groundwater is above the limit value of 50 mg NO3 l-1 for

most of the monitoring period. In 2023, in the oxic upper groundwater in the sandy

and clay catchments, there are respectively approx. 74% (14 out of 19) and approx.

26% (6 out of 23) of the monitoring points where the nitrate content on average is

above 50 mg l-1. In 2023, the average nitrate content is 72 mg NO3 l-1 and 36

mg NO3 l-1 in the sand and loamy catchments, respectively. There is a trend of

increasing nitrate concentrations in the oxic groundwater since around 2015 in the

loamy catchments and since around 2007 in the sandy catchments.



In the sandy catchments nitrate concentrations measured in the stream water are significantly

lower than measured in the upper oxic groundwater due to contribution of groundwater from

deeper subsurface layers with low nitrate concentrations due to denitrification.

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7.3

Targeted catch crops and targeted nitrogen regulation

For the year 2017, a total of app. 144,000 ha voluntary targeted catch crops was 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 was 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, targeted nitrogen regulation continued with 359,200 ha of catch crops and alternatives

applied for in the voluntary phase. Of those, 351,800 ha catch crops and alternatives were

approved, and a further 17,200 ha was applied through an uncompensated mandatory effort.

In 2022, targeted nitrogen regulation continued with 352,500 ha of catch crops and alternatives

applied for in the voluntary phase. Of those, 350,150 ha catch crops and alternatives were

approved, and a further 22,200 ha was applied through an uncompensated mandatory effort.

In 2023, targeted nitrogen regulation continued with 352,800 ha of catch crops and alternatives

approved in the voluntary phase, and a further 12,320 ha was applied through an

uncompensated mandatory effort.

In 2024, targeted nitrogen regulation continued with 339,300 ha of catch crops and alternatives

approved in the voluntary phase, and a further 23,330 ha was applied through an

uncompensated mandatory effort.

7.4

The phosphorus indicator and monitoring system

Neither the phosphorus indicator nor the P monitoring system indicate that the average

phosphorus application in Denmark exceeds the average phosphorus ceiling of 34 kg P/ha.

There is currently also no risk for exceeding future P-ceilings, which are reduced compared to

current level.

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Ministry of Green Transition of Denmark

Department