assessment of the application of the agri-environmental policy in...

Assessment of the application of the Agri-Environmental Policy in Serbia

PhD Dragana Vidojević

Ministry of Environmental Protection

Serbian Environmental Protection Agency

PhD prof. Jovica Vasin

Institute of Field and Vegetable Crops

Laboratory for soil and agroecology

PhD Nenad Brkić

Agency for consulting services - ND Consulting15 May 2018, Podgorica

15 May 2018, Podgorica

INTRODUCTION

• Republic of Serbia was granted EU candidate status on March 1, 2012.

• Stabilisation and Association Agreement entered into force on September 1, 2013 between

Serbia and EU.

• Chapter 11 - Agriculture and rural development has not been opened yet.

• Explanatory screening for Chapter 12 -Food safety, veterinary and phytosanitary policy was held

in March 2014. Bilateral screening for Chapter 12 was held in May 2014.

• Sector for International Cooperation includes the Department for European Integration,

Multilateral and Bilateral Cooperation in the field of agriculture


Main country indicators

• 88,499 km2 (77,589 km2 excluding Kosovo and Metohija).

• 7,186,862 Inhabitants excluding Kosovo and Metohija

• 92.6 inhabitants per 1 km2 excluding Kosovo and Metohija

• GDP for 2016 is 38,295.6 mil USD (Conversion according to annual average exchange rate),

5,426 per capita, USD

• Agricultural land share in total country area (excluding Kosovo and Metohija): 49.8 %

(3,861,477 ha).

• Gross Value Added for Agriculture, forestry and fishing in GDP: 8.67 % (2015).

• Major crops (by area) are Maize, Wheat, Sunflower, Soya, Cabbage and kale, Peppers, Plums,

Tomato, Lucerne, Clover, Sugar beet, Potatoes etc.

• Major livestock (by number) are Pigs, Sheep, Cattle, Goats etc.


AGRICULTURE IN COUNTRY

2010 2015 2016

Share of utilized agricultural land in

total land*

65.11 44.70 44.33

Share of Arable Land in agricultural

land

65.22 74.70 75.52

Share of Permanent Crops in

agricultural land

5.88 5.42 5.46

Share of Agricultural GDP in total

GDP

8.50 8.67 /

Share of Agricultural Labour in total

Labour

/ 6,86 6.09

Share of Agricultural Export in total

Export

7.42 7.07 7.15

Share of Agricultural Import in total

Import

2.59 3.33 3.15

2016 (ha) 2016 in % of total

land

Land Total 7,758,900 100

Forest 2,168,746 27.95

Utilized agricultural land 3,439,887 44.33

Arable land & gardens 2,597,808 33.48

Permanent crops (fruit, grapes,

nurseries)

187,942 2.42

Pastures 311,211 4.01

Wooded pastures No date No date

Agroforestry No date No date

Fallow 16,624 0.21

Abounded land 424,054 - 2012 3 5.47

Agricultural land/capita (ha) 0.48

Arable land & permanent

crops/capita (ha)

0.39

Key agricultural indicators Land Use


AGRICULTURE IN COUNTRY

Farm Structure Agricultural production

2012

Number of holdings Percentage of holdings

Total 631,552 100

No land 10,107 1.60

Up to 2 ha of UAA 293,770 46.52

Above 2 ha to 5 ha 185,090 29.31

Above 5 ha to 10 ha 90,273 14.11

Above 10 ha to 20 ha 32,878 5.21

Above 20 ha to 50 ha 13,133 2.08

Above 50 ha to 100 ha 4,386 0.70

Above 100 ha UAA 1,915 0.052

Above 100 ha to 300 ha 1,456 0.23

Above 300 ha to 500 ha 143 0.02

Above 500 ha to 1,000 ha 135 0.02

Above 1,000 ha to 2,500 ha 125 0.02

Above 2,500 ha to 5,000 ha 44 0.01

Above 5,000 ha UAA 12 0.002

Crop Production (total) Areas (ha) Production (t)Cereals 1,605,215 10,258,245.1Oilseeds (Sunflower, Soya, Rape seed) 396,137 1,236,977Sugar beet 49,237 2,683,859Tobacco 5,256 7,811

Fruits (Apples, Plums, Sour Cherries, Raspberries, Grapes) 147,918 1,079,784

Vegetables (Beans, Cabbage, Kale, Peppers, Tomatoes) 37,451 447,744

Potatoes 31,594 528,070

Meadows 313,690 671,317Pastures 230,109 392,067

Other crops (Lucerne, Clover, Maize for fodder)152,200 909,305

Livestock (total) Heads Number Number of farmsCattle 893,000 177,252Pigs 3,021,000 355,052Ships and goats 1,865,000 217,902Horses 15,000 10,095Poultry 16,242,000 327,445Other animals (Beehives) 792,000 /


ENVIRONMENT AND ENVIRONMENTAL POLICY

IN THE COUNTRY

The Republic of Serbia is characterized by high genetic species, and ecosystem diversity. The

Republic of Serbia hosts:

・ 39 % of European vascular flora,

・ 51 % of European fish fauna,

・ 49 % of European reptile and amphibian fauna,

・ 74 % of European bird fauna,

・ 67 % of European mammal fauna.

Contribution to the total quantity of emissions of GHG - agriculture (92% for NH3).

According to the latest data, methane emissions (CH4) in the agricultural sector and other land use

declined, and nitrous oxide (N2O) emissions are with slight fluctuations in the period 1990-2013.


ENVIRONMENT AND ENVIRONMENTAL POLICY

IN THE COUNTRY

• Surface and ground water quality monitoring, performed by the Serbian

Environmental Protection Agency, shows that in most cases concentrations of nitrates.

and orthophosphates remain within range defined as excellent or good ecological status.

• The results from fertility control show that the largest number of samples has low content

of organic carbon. Average content of soil organic carbon in agricultural land is 1.98%.

Very low content has 5.24% of samples.

• The total area of agricultural land on which the conversion is made into artificial surfaces

in the period 1990-2012 is 11,367ha.


Implementation of EU Directives

• The Water Framework Directive (WFD) has been partially transposed by the Water

Law and several implementing acts. The main responsible institution is MAFWM.

Responsible institutions for monitoring are Ministry of Environmental Protection -

Environmental Protection Agency and Republic Hydrometerological Service of Serbia.

Implementation of the WFD is in an initial stage.

• The Nitrates Directive has been partially transposed by the Water Law. MAFWM is the

authority responsible for determining the vulnerable zones and their boundaries,

proposing for adoption the action programs with mandatory measures for protected areas

designated as vulnerable zones, proposing for adoption the Code of good agricultural

practice. Proposal for the Nitrates Vulnerable Zones and draft of the Code of Good

Agricultural Practice has been developed.


Implementation of EU Directives

• Transposition of Directive 86/278/EEC on the protection of the environment, and in particular of

the soil, when sewage sludge is used in agriculture into the legislation of the Republic of Serbia

is in progress.

• The Habitats Directive is almost fully transposed except of the Article 8, which refers to

financing, and articles, which refer to the reporting. Main legal act transposing Directive - Law

on Nature Protection. Competent authority for transposition and implementation - Ministry of

Environmental Protection. The implementation of the provisions of the Directive is ongoing.

• In accordance with the Regulation on Ecological Network established ecological network

includes 101 international and national ecological important sites.

• The Birds Directive is almost fully transposed through following national legislation: Law on

Nature Protection and Law on Game and Hunting and the accompanying by-laws.

• Regulation EU Monitoring Mechanism - Regulation 525/2013 (MMR) is not aligned, however

the draft Law on Climate Change and accompanying by-laws that transpose MMR are prepared.


AGRI-ENVIRONMENTAL STATE IN THE COUNTRY

• Strategy for Agriculture and Rural Development of the Republic of Serbia for the period

2014-2024 (2014) includes, in particular, sustainable resource management and climate change.

• Operational goals for the implementation of the priority area related to the protection and

improvement of the state of the environment include:

protection of waters against the negative effects of agriculture; greater application of sustainable

agricultural practices that are environmentally friendly; establishing and promoting an integrated

production system; improvement of integral pest management and organic production, system of

control, certification and control in organic production; raising awareness about the importance of

using renewable energy sources and the production of energy crops; controlled waste and effluent

management from primary agricultural production; development and improvement of the system of

managing by-products of the food industry; conservation and sustainable management of plant and

animal genetic resources; preservation of landscapes and agroecosystems, agricultural areas of high

natural value and their resources.


AGRI-ENVIRONMENTAL STATE IN THE COUNTRY

National Program for Agriculture for the period 2018-2020 (2017) (NPP) is an operational

program for implementation of agricultural policy, which contains measures classified as direct

payments, measures for market regulation, as well as special subsidies and credit support in

agriculture.

Draft of National Program for Rural development for the period 2018-2020 is submitted for

adoption and it includes set of various agri-environmental measures under the group of rural

development measures intended for environmental protection and sustainable rural development.

National Environmental Protection Program (2010)

Biodiversity Strategy of the Republic of Serbia for the period 2011-2018 (2011) defines the

objective to improve the integration of biodiversity concerns into all relevant sectors.

National Strategy for Sustainable Use of Natural Resources and Goods (2012) defines the main

goals that include the goals related to agriculture. (Renewable Energy Sources, Land Resources)

Waste Management Strategy for the period 2010-2019. (2010) is the basic document that

provides the conditions for rational and sustainable waste management in the Republic of Serbia.


Institutional and Legal Settings

• Ministry of Agriculture, Forestry and Water Management

Agriculture Land Directorate

Veterinary Directorate

Plant Protection Directorate

Water directorate

Forest Directorate

• Ministry of Environmental Protection

Environmental Protection Agency


Agri-environmental policy

Water Law ("Official Gazette of the RS" No. 30/10, 93/12, 101/16) is in line with the

recommendations of the Water Framework Directive of the European Union (Directive 2000/60/EC of the

European Parliament and Council, WFD) - protection of water quality.

Law on Agricultural Land ("Official Gazette of the RS" No. 62/06, 65/08, 41/09, 112/15, 80/17), set

rules about planning, protection and management of using agricultural land. Further, the law prescribes

prohibition of discharge and disposal of hazardous and harmful substances on agricultural land, drainage

canals and irrigation system.

Law on Agriculture and Rural Development ("Official Gazette of the RS" No. 41/09, 10/13, 101/16)

set the basic definitions, rights and responsibilities of agricultural producers, involving a duty for

protection of environment, animal health, animal welfare and soil protection.


Agri-environmental policy Law on Subsidies for Agriculture and Rural Development ("Official Gazette of the RS" No. 10/13, 142/14,

103/15, 101/16) – define measures to support agriculture and rural development:

Article 3. - type of subsidies:

1) direct payments;

2) rural development measures;

3) special subsidies;

4) credit support in agriculture;

Law on Organic Production ("Official Gazette of the RS" No. 30/2010) set criteria for organic production,

controlling and certification of organic production, processing, labelling, storage, transport, export and import. The Law

is mostly in the line with Council Regulation (EC) on organic production and labelling of organic products and

Commission’s implementing Regulation No. 834/2007 on organic production and labelling of organic products.

Law of Animal Welfare ("Official Gazette of the RS" No. 41/2009), set up: prevention and treatment of disease and

injury of animals; prevention and mitigation of pain, distress and other negative states; and provision of diets and living

conditions that are suited to the needs and nature of animals.

Law of Animal Husbandry ("Official Gazette of the RS" No. 41/09, 93/12, 14/16) regulate the treatment of animal

waste (feces and urine) and using as an organic fertilizer.


Agri-environmental policy Law on Veterinary ("Official Gazette of the RS" No. 91/05, 30/10, 93/12)

Rulebook of veterinary, sanitary conditions of facilities for breeding and keeping ungulates,

poultry and rabbits (“Official Gazette of the RS”, No. 81/2006)

Law on Environmental Protection ("Official Gazette of the RS" No. 135/04, 36/09, 36/09 –

other low, 72/09 – other low, 43/11 – decision of the Constitutional Court and 14/16) regulates

the integral system of environmental protection to ensure healthy environment. Among issues

relevant for agricultural policy, the Law specifically relates to protection of natural value

(landscapes), biological diversity, species and ecosystems diversity, public natural goods as water-

fronts, forests.


Agri-environmental policy

Law on Nature Protection ("Official Gazette of the RS" No. 36/09, 88/10, 91/10 -

cor. and 14/16), include NATURA 2000 strategy and the protection of special areas

for conservation of habitats and species and areas of special protection for

conservation of habitats and certain species of birds.

Law on Forest ("Official Gazette of the RS" No. 30/10, 93/12, 89/15). The Forest Law

covers the conservation, protection, planning, cultivation, forest use, management of

forests and forest lands, monitoring the implementation of this law and other issues

relevant to forests and forest land.


Agri-environmental measures in place

The Ministry of Agriculture, Forestry and Water Management for 2018 allocated funds to support

agricultural production. Subsidies are allocated for the following activities:

1. direct payments; 177,791,122.00 eur;

2. rural development measures; 44,310,362.00 eur;

3. credit support in agriculture; 6,751,054.00 eur;

4. special subsidies; 2,154,852.00 eur;

IPARD subsidies; 20,542,278.00 eur, of which MAFWM budget is 5,135,569.00 eur and

15,406,708.00 eur supporting from EU funds;



Rural development measures include support of the following agro-environmental measures:

1. improvement of competitiveness in the amount of 12,057,560.00 eur, of which for:

1.1. investments in physical assets of agricultural holdings - the amount is

9,957,805.00 eur,

2. subsidies for the preservation and improvement of the environment and natural

resources in the amount of 1,721,518.00 eur, of which for:

2.1. organic production in the amount of 928,270.00 eur, of which for:

2.2. preservation of plant and animal genetic resources in the amount of 793,248.00

eur



In accordance with the objectives of the Strategy for Agriculture and Rural Development of the Republic

of Serbia for the period 2014-2024 it was identified in the line with IPA II and IPARD II Programme

investments with focus on the following measures:

• support the competitiveness of the agri-food sector, alignment with EU veterinary, phytosanitary, food

safety and environmental standards, as well as its restructuring and modernization;

• contribute to the development of sustainable land management practices by supporting organic farming

and other agro-environmental practices;

• contribute to sustainable rural development by supporting diversification of economic activities and

strengthening the LEADER approach;

• support the efficient Programme implementation, monitoring, evaluation and publicity under the

Technical Assistance measure.


Agri-environmental measures in place Ministry launched first advertisement for IPARD II, Measure 1 - Investments in the physical property of

agricultural holdings, on 25. December 2017. and 04. January 2018.

The Ministry of Agriculture, Forestry and Water Management through IPARD II will support the

following measures:

- Measure 1 - Investments in the physical property of agricultural holdings;

- Measure 3 - Investments in physical assets relating to processing and marketing of agricultural products

and fishery products;

Objective of IPARD II, Measure 1, is to support investments in technical improvements and investments in

new machinery and technologies can increase the productivity and competitiveness of agricultural

production. In addition, the farms should to be harmonized with a set of national requirements and as well as

EU standards for the protection of the environment and animal welfare.

Objective of IPARD II, Measure 3, is to support investments in processing and marketing of agricultural

products and fishery products. This measure should to increase the overall performance of the milk, dairy,

meat, fruit and vegetable sector, as well as products of these Sectors.



Connection of IPARD and national measures:

- National measures under the new NPRD (2018-2020) will support small holdings and farms to up-grade

to a more competitive agriculture production and to diversify to non-agriculture activities.

- IPARD II programme will mainly support viable agricultural holding and private recipients (farmers,

small and medium enterprises (SME) from agro-food sectors etc.).

Farms/households above the IPARD II limits will be eligible only for investment in manure management or

for farm investment in energy production from renewable sources.

Large companies are not considered for support neither from the national budget nor from the IPARD II

Programme.


Agri-environmental indicators

MAFWM, Ministry of Environmental Protection, Statistical Office of the Republic of Serbia,

Institute for Nature Protection and Environmental Protection Agency.

Sector for rural development of the MAFWM monitors result/output and impact indicators for

every measure being designed and implemented both under National program of rural

development or IPARD.

Sector for rural development is also entitled to monitor measures of local rural development

programmes implemented in the municipalities and Autonomous province of Vojvodina

Animal genetic diversity of autochthonous breeds of domestic animals is monitored by the

MAFWM.



Rulebook on the National List of Environmental Protection

Indicators ("Official Gazette of the RS", No. 37/2011)

Areas under organic production; Consumption of mineral

fertilizers and plant protection products; Irrigation of

agricultural land; Agricultural areas of high natural value.

Greenhouse gas emissions

Nutrient in surface and groundwater

Diversity of species

Endangered and protected species

Land use change

Soil erosion

Soil organic carbon content

Water exploitation index (WEI)

Areas of degradated lands

Final energy consumption by sector

Figure 1. Trend and average of NO3

concentration in the groundwater

monitoring sites of the Republic of Serbia

(2007-2016)

Figure 2. Trend of median of NO3 concentration

in the groundwater of the Republic of Serbia

(2007-2016)

Figure 3. Frequency distribution of NO3 in

groundwater monitoring sites of Serbia (2007-

2016)


Agri-environmental indicators Domain

Sub-

domain Nr Title

Available Frequency Spatial

reference/

resolution

Responsible

institutions

How to

access the

data

Responses

Public

policy

1 Agri-environmental

commitments

NO - - - -

2 Agricultural areas under

Natura 2000 (Archived)

Yes/nation

al

methodolo

gy

Yearly National

scale

INC, SEPA SEPA

Technolog

y and skills 3

Agri-environmental

indicator - farmers’

training and

environmental farm

advisory services

(Archived)

Yes/nation

al

methodolo

gy

Yearly National

scale

SORS SORS

Market

signals and

attitudes

4

Area under organic

farming (see Organic

farming statistics)

Yes Yearly National

scale

MAFWM MAFWM,

SEPA,

SORS

Driving

forces

Input use

5 Mineral fertilizer

consumption

NO - - - -

6 Consumption of

pesticides

NO - - - -

7 Irrigation

Yes Yearly National

scale

SORS SORS,

SEPA

8 Energy use

Yes Yearly National

scale

MME SEPA

Land use

9 Land use change

(Archived)

Yes 6 years

period

National

scale

SEPA SEPA

10.1 Cropping patterns

Yes Yearly National

scale/region

al

SORS SORS

10.2 Livestock patterns

Yes Yearly National

scale/region

al

SORS SORS

Farm

manageme

nt

11.1 Soil cover

Yes Yearly National

scale/region

al

SORS SORS

11.2 Tillage practices NO - - - -

11.3 Manure storage

Yes/nation

al

methodolo

gy

Periodically National

scale

SORS SORS

Trends

12 Intensification/extensificati

on

NO - - - -

13 Specialisation NO - - - -

14 Risk of land abandonment

(Archived)

Yes Yearly National

scale

SORS,

MAFWM

SORS,

MAFWM

Pollution

15 Gross nitrogen balance

(Archived)

NO - - - -

16 Risk of pollution by

phosphorus

Yes/national

methodolog

y

Yearly National

scale

MAFWM MAFWM,

SEPA

17 Pesticide risk NO - - - -

18 Ammonia emissions

Yes Yearly National

scale

SEPA SEPA

19

Agri-environmental

indicator - greenhouse gas

emissions (see Climate

change - driving forces)

Yes Yearly National

scale

SEPA SEPA

Resource

depletion

20 Water abstraction

(Archived)

Yes Yearly National

scale

SORS SORS,

SEPA

21 Soil erosion

Yes/national

methodolog

y

Periodically National, no

digital map

MAFWM,

MEP

MAFWM,

SEPA

22 Genetic diversity

Yes/national

methodolog

y

Periodically National

scale

MAFWM,

INC

MAFWM,

SEPA, INC

Benefits

23 High Nature Value

farmland

Yes

(preliminary

map)

Periodically National,

digital map

SEPA, INC

MAFWM

SEPA

24 Renewable energy

production (Archived)

Yes Yearly National

scale

MME MME, SEPA

Biodiversity

and habitats 25

Agri-environmental

indicator - population

trends of farmland birds

(see Biodiversity statistics)

Yes/national

methodolog

y

10 years National SEPA, INC SEPA, INC,

NGO

Natural

resources

26 Soil quality (Archived)

Yes/national

methodolog

y

Yearly National

scale

MAFWM MAFWM,

SEPA

27.1 Water quality - Nitrate

pollution

Yes Yearly National

scale

SEPA SEPA

27.2 Water quality - Pesticide

pollution (Archived)

Yes Yearly National

scale

SEPA SEPA

Landscape 28 Landscape - state and

diversity (Archived)

NO - - - -



• Serbian Environmental Protection Agency has

published set of indicators for monitoring the integration

of environmental concerns into the common agricultural

policy;

• 19 indicators:

Mineral fertiliser consumption, Irrigation, Energy use, Land use

change, Land cover, Dominant livestock types, Greenhouse gas

emissions, Pesticide risk, Agrobiodiversity, Hight natural value

farmland, Land cover change, Soil ferility, Water quality - Nitrate

pollution, Soil organic carbon, Population trends of farmland

birds, Water consuption in agriculture, Areas under organic

farming, Agricultural land under protected areas, Farmers’

training, Agri-environmental commitments

http://www.sepa.gov.rs/download/publikacije/Poljoprivreda_2016.pdf



0

10000

20000

30000

40000

50000

60000

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

ha

Irrigation

GHG Emissions



Indicative map of

distribution of

HNV farmland

0

2000

4000

6000

8000

10000

2010 2011 2012 2013 2014

haAreas under organic agriculture

Education of

farmers


Conclusions• Common policies in the area of environmental protection and agriculture in the Republic of

Serbia are mainly related to the protection of water and land. Competencies are shared and there

is a lack of a common policy that would integrate problems and challenges, and which would

have an ecosystem approach.

• There is a lack of data, insufficiently defined competencies and exchange of data between

individual bodies and organizations.

• Generally there is a low level of environmental awareness of farmers.

• Another big challenge and issue is LPIS system (Land Parcel Identification System) for all

agricultural plots as major part of agri-environmental payments.

• HNVF area in Serbia might be lower as was expected. The reason is that the large geographical

units of Serbia have not been searched so far and unfortunately data for these regions are

missing.

• During past years Serbia implemented several Projects (DREPR, ENVAP 2, IPPC farms and

DSIP) and has already started with process of implementation the Nitrates Directive

requirements and good agricultural practices.


Conclusions

• Manure management based on data of agriculture census 2012 show that 95% of farms keep

manure in heap on open space without any protection against leakage to surface waters or

groundwater.

• Data of the Agricultural Census 2012 show that mineral fertilizers were used on 67% of

agricultural land, manure from livestock farms - 12% and 21% of agricultural land was receiving

no fertilization.

• Through Agricultural Advisory Extension Services farmers (crop, vegetable and fruit production)

can get assistance and support in controlling fertility of soil and recommendation for fertilizing.

• A lot of farms ("hot spots") discharged illegally wastewater into rivers, channels (water bodies).

• Subsidies (IPARD and NPRD) represent good mechanism for support implementation the ND

and good agricultural practices, involved principles of EU Common Agricultural Policy (CAP),

environment protection rural development measures for farmers.

• The biggest challenges for farmers during implementation ND will be to fulfil the conditions for

manure storage capacity for 6 months period and mechanization for spreading manure on fields.


Recommendations

• The next step towards applying the HNVF concept in Serbia involves developing and applying

indicators to identify the distribution of HNVF and digitalization of all HNVF in LPIS system. It

is necessary to prevent the further loss of high nature value grasslands and associated species

through abandonment, conversion to arable land and other crops, or overgrazing.

• It is necessary to support farmers to plan and implement an appropriate programme of activities

for significantly reducing the risk of soil erosion by water and wind.

• It is necessary to support effective nutrient management including the storage and application of

livestock manures, as well as manure from slaughterhouses and processing industries.

• It is necessary to prevent further erosion of genetic resources by increasing the numbers of

breeding animals of specified endangered autochthonous breeds which are in danger of further

decline in numbers or in danger of extinction.

• It is necessary to increase the area under organic production and the number of farms managed

according to the standards prescribed by the Organic Farming Low.


Recommendations- Education and training of farmers should be improved on: fertilizers land application, rate and uniformity

of spreading of mineral fertlizers and livestock manure, with aim to prevent nutrient losses into surface and

ground water.

- Field book has already obligatory by law for rent state land, but it would be recommended to be obligatory

for all farmers.

- Agricultural strategy should encourage farmers to use organic manure instead of mineral fertilizers.

Organic manure has a lot of advantages, improving the mechanical conditions of soil, increasing level of

soil organic matter and increasing crop yields per ha.

- Subsides for mineral fertilizers should to be decrease from the perspective of years. On this item close

cooperation it is foreseen between Sector for Rural Development, Agriculture Land Directorate and

Directorate for Agrarian Payments.

- Promote the following measures on farms:

• periods when land application of fertilizer is inappropriate;

• land application of fertilizer to steeply sloping ground;

• land application of fertilizer to water-saturated, flooded, frozen or snow-covered ground;

• conditions for land application near watercourses.

Thank you!

15 MAY 2018, PODGORICA

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