Relevant Matter
Public policy or programme
Public Policy Area
EU Affairs
Period
1 May, 2024 to 31 Aug, 2024
Specific Details
European Commission Public Consultation on Nitrates Directive - RENURE
Intended results
To acknowledge the proposed revision of the Nitrates Directive announced by the European Commission to allow for an increase rate of 100kg /Ha of RENURE to be applied to land to increase nutrient circularity and improve on farm economics.
Given the increasing importance of digestate as a fertiliser, especially in the context of volatile mineral fertiliser prices and to the overall economics of Anaerobic Digestion Schemes, it is essential to ensure that the Nitrates Directive is amended in a suitable way that does not only promote the interests of a few member states with considerably larger capacities to refine manures.
The process of Anaerobic Digestion releases nutrient elements from feedstock previously bound up in complex organic compounds and thus are unavailable for plant uptake when material such as slurry is used as a fertilizer. Thus, the anaerobic digestion process not only produces a nutrient rich residual material which can be used as a fertilizer but increases nutrient availability in this material when compared with the original feedstock.
To highlight that while it is a pragmatic decision to revise the Directive to allow for an increased rate of digestate based products to be spread on land to improve the environmental and economic efficiency of farms, the criteria which digestate will have to meet to be spread on land as per the proposed revision is highly restrictive and there is little capacity in Ireland to process digestate to the required standard established by the Commission.
To highlight that the revision of the Nitrates Directive will therefore not allow Irish farmers to fully utilise processed manure with an increased nitrogen use efficiency rating and reduce their dependency on inorganic manures. It is therefore essential that the treatment processes outlined in the revised Directive below are expanded to account for the specifics of all member states so that farmers across the EU can improve nutrient circularity.
To highlight that the criteria outlined contradicts the findings of the 2020 Joint Research Committee Report ‘Technical proposals for the safe use of processed manure above the threshold established for Nitrate Vulnerable Zones by the Nitrates Directive (91/676/EEC)', which states that the liquid fraction of digestate should qualify as a RENURE product
(i) the livestock manure component of the fertilising material has undergone a treatment process that increases the concentration of nitrogen in mineral form, urea nitrogen or crystal-bound nitrogen, expressed as a percentage by weight of the total nitrogen compared to the input to the treatment process, resulting in any of the following
(1) an ammonium salt (scrubbing salt), stemming from a gas purification or emission control process designed to remove ammonia from off-gases;
(2) a mineral concentrate obtained through reverse osmosis;
(3) a nitrogen-rich phosphate salt (struvite), precipitated out of livestock manure;
‘The results indicate that scrubbing salts (14 out of 14 material samples compliant), mineral concentrates (7 out of 8 material samples compliant), and some liquid digestate fractions obtained through centrifugation and/or advanced solids removal (8 out of 10 material samples compliant) can meet the proposed RENURE criteria on agronomic value (Table 3).
Although not taken up in the JRC measurement campaign, also specific P-fertilisers that contain N (e.g. struvite) could meet the proposed criteria.
It is indicated that more scrubbing salts and liquid digestates meet the criterion on TOC TN than the criterion on mineral N TN, whereas for mineral concentrates 7 out 8 candidate materials meet both criteria (Figure 18). In order to provide some flexibility for compliance, both criteria are maintained in the RENURE proposals.'
To propose that the revised Directive should respect the findings of the JRC Report and allow for digestate that has been separated into its liquid fraction to be spread on land as long as it has been quantified for its macro nutrient content and assured to be free of risk related pathogens.
To propose that, in addition to this, that it is spread with an application method that is appropriate and in compliance with regulations such as the Animal by-products Regulation (EC Regulation No 1069/2009) and Statutory Instrument No. 605 of 2017, Good Agricultural Practice for Protection of Waters and its amendment.
To highlight that Irish farmers are already applying manures in accordance with a strict National Nitrates Action Programme and therefore possess the capacity to spread nutrient quantified digestate in an environmentally responsible manner.
To propose that there should also be an allowance for farmers utilising a Nitrates Derogation in Ireland to also access digestate as a RENURE product as the amended directive lacks clarity on how the changes will help these farmers in improving nutrient balances.
To highlight that the requirement for digestate to be transformed into Ammonium Sulphate or Nitrate via the methods outlined above are excessive and financially compromising for farmers given that the digestion process itself already converts organic nitrogen into ammonium which is more available for plant uptake.
Utilising digestate can lead to a reduced risk of pollution, decreased odour and pathogens compared to untreated slurry. Research conducted by Irish institutions including National University of Galway, University College Dublin, Green Generation and Teagasc funded by the Department of Agriculture, Food and the Marine have all highlighted the key environmental benefits of digestate which should encourage its adoption as an organic fertiliser under RENURE.
According to the Anaerobic Digestion and Bioresources Association, “1 tonne of artificial fertiliser replaced with digestate, saves 1 tonne of oil, 108 tonnes of water and 7 tonnes of CO2 emissions”. Digestate can reduce fossil-based emissions from chemical fertiliser production which can be up to 5.3 kgCO2 e/ kg N.
To emphasise that the nutrient release of digestate needs to be considered further with an examination of digestate quality from different feedstocks and a coherent conversion methodology established for farmers to better understand their nutrient balances and substitutions. Once the nutrient and pathogen profile of the digestate is identified, it should qualify as a RENURE resource.
To encourage the Commission to allow for nutrient quantified liquid digestate to qualify as a RENURE product and the extra 100kg/Ha allowance given the restrictive barriers associated with further processing of manure and the low base of Anaerobic Digestion facilities currently present in Ireland compared to other Member States to fully support farmers towards a transition to more novel fertilising products.
To emphasise that the proposed revision of the Nitrates Directive is evidence that the directive needs adaptability when it comes to regulating fertiliser products for farmers. IFA has previously requested the Commission to consider a proposal of combining the inorganic Nitrogen allowance for farmers with their organic Nitrogen load and allowing farmers the freedom to choose which one they wish to reduce.
This needs to be considered further as we progress forward with the Nitrates Directive, particularly in relation to optimisation of organic fertilisers and volatile fertiliser market conditions.
To call for an expansion of the definition of RENURE to allow farmers spread liquid digestate that has been nutrient quantified and has a similar nutrient profile to RENURE. This would make the amendment to the Nitrates Directive much more accessible to Irish farmers, as in its current form it places financial barriers to the uptake of RENURE as a viable fertiliser for reducing inorganic nitrogen outputs.
To seek clarity on the position of Irish farmers utilising a Nitrates Derogation on their ability to utilise RENURE as an additional fertiliser product as it is not specified within the amendment on their position to do so.
Name of person primarily responsible for lobbying on this activity
Francie Gorman IFA President, Liam MacHale IFA Director of European Affairs, Noel Banville IFA European Policy Executive
Did any Designated Public Official(DPO) or former Designated Public Official(DPO) carry out lobbying activities on your behalf in relation to this return? You must include yourself, and answer Yes, if you are a current DPO or a DPO at any time in the past. (What is a Designated Public Official?)
No
Did you manage or direct a grassroots campaign?
No
Was this lobbying done on behalf of a client?
No
Lobbying activity
The following activities occurred for this specific Subject Matter Area.
Informal communication (2-5)
Designated public officials lobbied
The following DPOs were lobbied during this return period on this specific Subject Matter Area. These DPOs were involved in at least one of the Lobbying Activities listed above, but not necessarily all of them.
As returns are specific to a Subject Matter Area the above Lobbying Activities may be associated with multiple returns.
Barry Andrews
MEP (European Parliament)
Billy Kelleher
MEP (European Parliament)
Chris MacManus
MEP (European Parliament)
Ciarán Cuffe
MEP (European Parliament)
Clare Daly
MEP (European Parliament)
Colm Markey
MEP (European Parliament)
Deirdre Clune
MEP (European Parliament)
Frances Fitzgerald
MEP (European Parliament)
Grace O'Sullivan
MEP (European Parliament)
Luke Ming Flanagan
MEP (European Parliament)
Maria Walsh
MEP (European Parliament)
Mick Wallace
MEP (European Parliament)
Sean Kelly
MEP (European Parliament)