Specific Details
Industrial Emissions Directive (IED)
Intended results
To seek clarity on some discrepancies in the Directive 2010/75/EU on Industrial Emissions, in advance of the vote in the European Parliament's Environment Committee on January 11th 2024.
To highlight the discrepancies between Annex 11 of the final text from the trilogue negotiations and article 2 of the Council Directive 2008/120/EC which is referenced in the Article 1, first paragraph, point (3)(e) of the agreed text on the Industrial Emissions Directive (IED) in the trilogues regarding the pig definition.
1. The final text references the Directive 2008/120/EC explicitly for the definition of ‘pigs'.
2. The final text in Annex II, paragraph (2), identify the 3 following categories with their coefficients a. Breeding sows >= 50 kg … 0,500 b. Piglets <= 20 kg … 0,027 c. Other pigs … 0,300
3. Council Directive 2008/120/EC defines “piglet” in its article 2.7 as “pig from birth to weaning;” (around 3 weeks)
4. However, by definition, a piglet of up to 20 kg would include both ‘piglets' and, ‘weaners' as per Directive 2008/120/EC article 2.8, where weaner is defined as ‘pig from weaning to the age of 10 weeks' (around 30kg).
To propose substituting the word “piglets” for “weaners” in order to make this newly agreed text legally compatible with existing legislation, In this regard, the text should read as follows “weaners <= 20 Kg/ 0.027” in Annex II paragraph (2) of the revision.
To propose that, in addition, the scope of the original Directive 2010/75 for breeding sows already accounted both the sows and their piglets. Thus, the higher co-efficient associated to this category “0.5 LSU”. For operational reasons, unweaned piglets should therefore not be accounted on top of the breeding sows.
To propose that the word “piglets" is substituted for “weaners” in Annex II of the IED.
To highlight that through our dialogue with Teagasc (Irelands National Agricultural Research Body), we have established that the revisions for production pigs decided upon through the trilogue negotiations and integrated units will also bring significant financial harm to the sector.
To highlight that, based on a piglet being 0.027 LU under the proposed revision, the new licensing is for 94 sows on integrated units. Farrowing- to - finish = 0.3 LU / pig Sow = 0.5 LU / sow Therefore @10.5 places per sows = 10.5*0.3 = 3.1 5 + sow = 3.65 Say 2.4 piglets per 100 sows = 2.4 * 0.027= 0.06 LU LU per integrated sow Therefore 350 LU limit / 3.71= 94 integrated sows.
This will pull in practically all Irish integrated farms into licensing. The cost of both attaining licensing and adopting all BAT's is unattainable for smaller scale producers and will only result in a reduction in farm numbers and the concentration of the industry into larger units.
IFA welcomed the exclusion of cattle from the scope of the revision following trilogue negotiations but feel that an unfair level of burden has been placed on our Pig and Poultry producers through the downward revision of the thresholds for compliance.
To point out that this revision will make no overall improvement to ammonia emissions profiles in Ireland, given the low proportion of ammonia pig and poultry farming currently accounts for and therefore the revision serves as only a disproportional financial punishment for these specific producers.
To emphasise that the economic contribution of these sectors can also not be underestimated, especially in the context of rural areas. Poultry farming is delivering around €700 million in output and supports over 5,000 jobs. Around 800 farms are involved in commercial poultry production in the Republic of Ireland and due to the revision of the threshold to 300 LSUs for layers, this drop from 40,000 birds to 21,500 will have a serious economic fallout.
Based on a survey of our IFA members we can estimate up to 45% of the current egg producers will be affected by this costly revision. Poultry exports were valued at €350 million in 2022 according to Bord Bia's Export Performance & Prospects report. The poultry sector (poultry meat & eggs) has a multiplier effect of 1.8 which means that every €10 million increase in the value of domestic output results in €18 million of additional output in the wider economy
To highlight the sectors role in driving the rural economy. Equally, a retraction in the sector could result in the same.
To call for a restoration of the 40,000 bird threshold for both layers and broilers.
To emphasise that, under the Clean Air Strategy announced by the Irish Government outlining how Ireland would aim to reduce its ammonia emissions from Agriculture, a revision of the IED was not considered a necessary measure required for Ireland to meet its 2030 targets for ammonia reductions which we are currently on track to meet.
Farmers are actively taking on measures to improve air quality and there are extensive measures included in policies such as Ag-Climatise, the Climate Action Plan and the Nitrates Action Programme which will support the delivery of the necessary compliance in the 2020 and 2030 periods.
To request a restoration of the status quo for the Industrial Emissions directive (IED), for both these measures relating to pigs and poultry, based on the fact that the measures are already in place for Ireland to meet its ammonia reduction targets, independent of this highly burdensome financial tool that is incompatible with true ammonia mitigation strategies that will make tangible differences to emissions profiles in Ireland.
Name of person primarily responsible for lobbying on this activity
Francie Gorman IFA President, Alice Doyle IFA Deputy President, Liam MacHale IFA Director of European Affairs, Noel Banville IFA Brussels Policy Executive, Nigel Sweetnam IFA Poultry Chair, Roy Gallie IFA Pig Chair, Brendan Soden IFA Poultry Vice-Chair, Sarah Hanley IFA Pig & Poultry Executive, Noel Banville IFA EU Affairs Policy Executive
Amii McKeever
Adviser to Minister (Department of Agriculture, Food and the Marine)
Barry Andrews
MEP (European Parliament)
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)
Luke Ming Flanagan
MEP (European Parliament)
Lynn Boylan
Senator (Seanad)
Maria Walsh
MEP (European Parliament)
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)
Sean Kelly
MEP (European Parliament)
Tim Lombard
Senator (Seanad)
Victor Boyhan
Senator (Seanad)