Specific Details
Compliance with the Nitrates Directive : Implications for Ireland
Intended results
To highlight the impact of reduced stocking rate thresholds on the entire agriculture sector.
- IFA analysis estimates that the reduction to a maximum stocking rate of 220kg organic nitrogen will have a cumulative sector cost of up to €60m per annum.
- A complete loss of the nitrates derogation would have massive ramifications both for Irish farmers and the downstream dairy processing sector.
- IFA estimate that the removal of the derogation entirely would reduce dairy income for the impacted farmers by an average of up to €23,000/annum; a huge drop given that average dairy family farm income for the last 5 years was about €87,000/annum.
To also highlight that the wider economic impact of the derogation would be even more significant. Using Dairy Industry Ireland analysis of the economic contribution of the dairy sector, IFA estimate that a loss of the derogation could result in over 1,100 job losses and a potential economic impact of over €1bn/annum when all direct and indirect factors are accounted for.
- Some mistakenly think this is only a dairy issue. In reality, any changes to the derogation impact all land-based sectors given the hugely disruptive impact it has on the land market.
- Drystock and tillage farmers as well as smaller dairy farmers are now being outcompeted in the land market by larger dairy farmers, who can justify paying a higher price for land rental in order to try to maintain their business at current levels.
- In the cases where drystock and tillage farmers do manage to retain rented or leased land, this is generally coming at a higher cost.
To point out that there are approximately 850,000 ha of land rented or leased in Ireland according to the CSO. An average increase of €100/ha (€40/acre) in land rental is an added cost of about €100m/annum to the Irish farming sector.
To highlight that this is effectively a transfer from productive farmers who spend money in the rural economy to inactive landowners whose contribution is significantly less. Between 2022 and 2023, Ireland's cereal area declined by 16,000 ha and now constitutes less than 6% of Ireland's agricultural land. Further changes to the derogation will inevitably lead to a significant further decline in this area.
To stress that while an estimated 3,000 farmers are directly affected by the existing reduction to 220kgN/ha, another 7,000 farmers are estimated to be directly impacted if stocking rates were capped at 170kgN/ha.
- IFA estimate that approximately 55% of milk supplied comes from farms stocked above 170kgN/ha. If these farms had to reduce milk output this would result in increased costs and job losses at processing level as outlined above.
To highlight that the removal of the derogation entirely will jeopardise the viability of thousands of farmers across all sectors. This would have a huge knock-on social impact on rural Ireland.
To outline that the removal of the derogation will directly impact dairy farmers but will have very substantial knock-on impacts on other sectors due to the disruption to the land market. It will also potentially impact the pig and poultry sectors due to increased levels of slurry nutrients that dairy farmers will seek to export, making it more difficult for pig and poultry farmers to find customers for their slurry nutrients.
That a removal of the derogation would also have consequences for Ireland's Climate Action Plan and associated targets. The Climate Action Plan sets out numerous land-based targets.
IFA estimate that the removal of the derogation would result in dairy farmers requiring about 86,000 hectares just to maintain their current dairy cow numbers. To put this in context, this is about 1.2 times the size of the entire county of Carlow. This additional land requirement is not factored into Climate Action Plan targets. Therefore, removing the derogation will make the achievement of Ireland Climate Action Plan more difficult.
To show that it is possible to maintain Ireland's derogation at it's current level while ensuring that there are improvements to water quality. Despite the narrative that is out there, the impact of stocking rate on nitrates loss is not proportionate to the load of Nitrogen applied to the land. Factors such as soil type, hydromorphology and weather play a significant role in the rate of nitrates loss from our farms in addition to the source load of N.
- Teagasc research has shown that the stocking rate reduction to 220kgN/ha will only reduce N loss to 1m by circa 4kg/ha - a minimal reduction when we consider that the influence of year (i.e. weather patterns) can impact nitrogen losses to 1m by up to 46kgN/ha.
- Tailoring management practices to the specific needs of a local catchment as demonstrated in the Agricultural Sustainability Support and Advisory Programme (ASSAP) is more beneficial for water quality than blanket regulatory changes to stocking rate.
To highlight that the ambition of the Nitrates Action Programme (NAP) has accelerated in the last two reviews of the programme with farmers obliged to undertake up to an additional 30 measures on farms to protect water quality.
To highlight what the Nitrates Action Programme (NAP) and government agencies fail to acknowledge is the realistic lag times that exist for these management practices to demonstrate improvements in water quality. The mitigation of nitrates loss to water can vary from seconds to decades upon the application of a new management practice. Work needs to be carried out to outline estimated lag times in the most vulnerable catchments.
To emphasise that it also must be considered that the expansion in the dairy herd in the past 10 years has not resulted in a proportionate decline in water quality. In fact, at national level water quality trends show minimal increases in nitrates, similar to what you would expect in year-to-year variation alone.
It is critical that Ireland uses the opportunity of the European Commission currently undertaking a European-wide public consultation on the Nitrates Directive to stress the critical importance of the derogation to Ireland and also emphasise that its long-term retention is vital to our whole industry.
To recommend that to mitigate the risk of nitrogen loss in winter time, ample slurry storage is required on all farms.
- Currently, only farmers that are importing slurry can avail of the increased grant-aid rate of 70%. To grapple with this issue 70% grant aid needs to be made available to all farms, in combination with the continued provision of accelerated capital allowances for slurry storage and the ability to continue to reclaim VAT on such structures.
To highlight that investing in slurry storage is a long-term investment – therefore farmers need certainty on how many dairy cows they will be milking in 4 years' time if we are seeking them to make long-term investments in storage.
To insist that the difficulties encountered in obtaining planning permission for such investments must be rectified. Many in need of additional slurry storage are being denied planning permission.
To stress the need for application of the regulations for water quality risk-based farm inspections, as part of the National Agricultural Inspection Programme, to be harmonised across the Local Authorities and the Department of Agriculture, Food, and the Marine (DAFM).
To recommend that,where issues are found during an inspection, the penalty applied should be proportionate to the breach by the farmer, this practice is fully endorsed by IFA.
To point out that, without discounting farmers' responsibilities to improve water quality, wastewater treatment plants and urban runoff via storm overflows play a significant role in determining the water quality of our catchments.
To emphasise that we cannot underestimate how vital it is that Ireland retains its nitrates derogation for this decade and beyond. Its removal would have a massive direct economic impact on the dairy sector but also very significant indirect impacts on other farming sectors, in particular the tillage sector who rely heavily on rented or leased land. In addition, its removal would have a substantial long-term economic impact on the wider rural Irish economy.
- It will also make the achievement of Ireland's climate action plan targets more difficult to attain. Removing the derogation will not automatically result in improvements in water quality but the economic damage it will do is guaranteed.
To meet with the Taoiseach Leo Varadkar to discuss the Nitrates Derogation and it's negative effects on the Irish economy.
To meet with the Minister for Agriculture, Food, and the Marine to discuss the importance of the retention of the Nitrates Derogation for Ireland.
To invite the Taoiseach Simon Harris to meet with IFA to discuss Ireland's Nitrates Derogation.
Barry Andrews
MEP (European Parliament)
Barry Cassidy
Special Adviser (Department of Agriculture, Food and the Marine)
Billy Kelleher
MEP (European Parliament)
Brian Leddin
TD (Dáil Éireann, the Oireachtas)
Chris MacManus
MEP (European Parliament)
Ciarán Cuffe
MEP (European Parliament)
Claire Kerrane
TD (Dáil Éireann, the Oireachtas)
Clare Daly
MEP (European Parliament)
Colm Markey
MEP (European Parliament)
Deirdre Clune
MEP (European Parliament)
Denis O'Donovan
Senator (Seanad)
Frances Fitzgerald
MEP (European Parliament)
Grace O'Sullivan
MEP (European Parliament)
Jackie Cahill
TD (Dáil Éireann, the Oireachtas)
Joe Flaherty
TD (Dáil Éireann, the Oireachtas)
Johnny Mythen
TD (Dáil Éireann, the Oireachtas)
Leo Varadkar
Taoiseach (Department of the Taoiseach)
Luke Ming Flanagan
MEP (European Parliament)
Lynn Boylan
Senator (Seanad)
Maria Walsh
MEP (European Parliament)
Martin Heydon
Minister of State (Department of Agriculture, Food and the Marine)
Michael Collins
TD (Dáil Éireann, the Oireachtas)
Michael Fitzmaurice
TD (Dáil Éireann, the Oireachtas)
Michael Ring
TD (Dáil Éireann, the Oireachtas)
Mick Wallace
MEP (European Parliament)
Paul Daly
Senator (Seanad)
Paul Kehoe
TD (Dáil Éireann, the Oireachtas)
Paul Savage
Assistant Secretary (Department of Agriculture, Food and the Marine)
Philip O'Callaghan
Special Adviser (Department of the Taoiseach)
Sean Kelly
MEP (European Parliament)
Tim Lombard
Senator (Seanad)
Victor Boyhan
Senator (Seanad)
Simon Harris
An Taoiseach (Department of the Taoiseach)
Barry Cassidy
Special Adviser (Department of Agriculture, Food and the Marine)
Jack O'Donnell
Special Adviser (Department of Agriculture, Food and the Marine)
Amii McKeever
Adviser to Minister (Department of Agriculture, Food and the Marine)
Brendan Gleeson
Secretary General (Department of Agriculture, Food and the Marine)
Leo Varadkar
Taoiseach (Department of the Taoiseach)