Specific Details
Water Quality - Ireland's Nitrates Derogation
Intended results
To stress the importance of Ireland retaining its nitrates derogation at current levels as part of the ongoing negotiations on the sixth Nitrates Action Programme (NAP), and that the conditionality attached to the retention of the derogation must be practical at farm level, not contribute to further fragmentation of land, and be scientifically proven to deliver improvements to water quality.
To point out that failure to secure Ireland's nitrates derogation at current stocking rates in the next programme would have a hugely negative impact on not only dairy farmers, but would also indirectly impact farmers in other sectors, not to mention the negative economic impact it would have in rural Ireland.
That IFA estimates that the loss of the derogation would result in a potential drop of €35k/annum in average dairy farmer incomes and a drop in national milk production of up to 1.2bn litres. When the downstream economic impact of this drop in milk production is factored in, the estimated annual cumulative economic impact is well in excess of €1.5bn per annum.
To highlight that there are no guarantees that the removal of the derogation will directly lead to an improvement in water quality as research has shown that the amount of manure applied on land is not the primary driver of nitrate concentrations in water
However, the removal of the derogation is guaranteed to seriously impact dairy farmer incomes thus lessening the capacity of the farm business to invest in further measures to improve water quality. In essence, the removal of the derogation could in fact be counter-productive to water quality.
To highlight that the removal of the derogation would not only impact dairy farmers; it would have serious negative impacts on other farming sectors, as it would massively increase the demand for land as dairy farmers try to acquire additional land to maintain cow numbers. This would drive up land rental prices for all farmers and likely lead to a further shrinkage in Ireland's tillage area which runs counter to a key objective of Ireland's Climate Action Plan.
To point out that a suite of additional new measures were introduced in February 2025 (S.I. 42 of 2025) as part of the interim review of the current NAP. These measures must be given time to demonstrate their beneficial impact on water quality. Farmers understand their responsibility to comply with regulations to protect and improve water quality.
They will continue to engage positively with measures that are scientifically proven to improve water quality. However, farmers are hugely frustrated at the potential introduction of further regulations that will undermine the viability of the sector yet may do little to improve water quality.
To stress that Ireland is fortunate that our current water quality standards are good in an EU context. Furthermore, the recent EPA 2024 early indicator analysis shows a significant reduction in river nitrate concentrations with average levels now similar to 2016 levels.
This is proof that the huge amount of work and effort on protecting water quality undertaken by the sector is now bearing fruit. Retaining the derogation is essential to securing the future of the dairy sector and eliminating the potential sizeable negative impact on other farming sectors.
To question the proposal that the Irish Government received from the EU to make a commitment to undertake ‘appropriate assessments' at catchment or sub catchment level under the EU Habitats Directive in order to improve our chance of securing the derogation. IFA has made it clear to the Minister that farmers need far more clarity on this aspect of the Government's plan, which is very significant and logistically very difficult.
To highlight that based on the Minister's briefing farmers could be looking at doing hundreds of Appropriate Assessments around the country, even with the State paying for them, and this will cause huge uncertainty for individual farmers.
To urge the Minister for Agriculture to provide a copy of the letter sent by the EU Commission last month. The Minister cited this letter as the reason why he is now looking for Appropriate Assessments at catchment and/or sub catchment level.
To challenge the Minister for Agriculture on putting forward some very onerous pre-conditions to applying for the derogation which he said was based primarily on a letter from the EU Commission.
To question the Department of Agriculture who are saying that this requirement comes about because of a court judgment in the Netherlands. The Minister said that the Irish Attorney General has provided a view on this, and this should also be published. The Irish system of farming is very different from the Netherlands and the comparison is not justified.
To highlight that when Ireland previously secured the derogation, it was based on Appropriate Assessment at national level. The Commission has to explain why this approach is now to change.
To emphasise that for farmers who are now in limbo, the Minister has to provide full transparency on the process to date and have real engagement with the IFA on the way forward.
Name of person primarily responsible for lobbying on this activity
Francie Gorman IFA President, Damian McDonald IFA Director General, Tadhg Buckley IFA Director of Policy & Chief Economist, Mark McElearney IFA Dairy Chair, Mark Connors IFA Environment Vice-Chair, Louise Crowley IFA Limerick Chair, Geraldine O'Sullivan IFA Policy Executive, Áine O'Connell IFA Policy Executive
Aodhán Ó Ríordáin
MEP (European Parliament)
Barry Andrews
MEP (European Parliament)
Barry Cowen
MEP (European Parliament)
Bill Callanan
Chief Inspector (Department of Agriculture, Food and the Marine)
Billy Kelleher
MEP (European Parliament)
Ciaran Mullooly
MEP (European Parliament)
Cynthia Ní Mhurchú
MEP (European Parliament)
Jack Chambers
Minister (Department of Public Expenditure, NDP Delivery and Reform)
James Browne
Minister (Department of Housing, Local Government and Heritage)
Kathleen Funchion
MEP (European Parliament)
Luke Ming Flanagan
MEP (European Parliament)
Lynn Boylan
MEP (European Parliament)
Maria Walsh
MEP (European Parliament)
Martin Heydon
Minister (Department of Agriculture, Food and the Marine)
Michael McNamara
MEP (European Parliament)
Micheál Martin
An Taoiseach (Department of the Taoiseach)
Nina Carberry
MEP (European Parliament)
Paschal Donohoe
Minister (Department of Finance)
Regina Doherty
MEP (European Parliament)
Sean Kelly
MEP (European Parliament)
Simon Harris
Tánaiste and Minister (Department of Foreign Affairs)
Brendan Gleeson
Secretary General (Department of Agriculture, Food and the Marine)
Barry Cassidy
Special Adviser (Department of Agriculture, Food and the Marine)
Brian Purcell
Special Adviser (Department of Agriculture and the Marine)
Jack O'Donnell
Special Advisor to the Tanaiste (Department of Foreign Affairs)
Niall Collins
Minister of State (Department of Justice)
Richard O'Donoghue
TD (Dáil Éireann, the Oireachtas)