Relevant Matter
Public policy or programme
Public Policy Area
Environment
Period
1 May, 2023 to 31 Aug, 2023
Specific Details
Agriculture Water Quality Working Group
Intended results
IFA's Submission
- to participate in the Department of Agriculture, Food, and the Marine's working group on Agriculture Water Quality.
- to address the flaws associated with Article 12 of the EU's Implementing Decision on 29th April 2022 granting Ireland a derogation included the requirement to conduct a two year review of water quality (2021, 2022) to take place in 2023, to determine maximum stocking rate thresholds based on nitrates concentrations, eutrophic status and their respective trends .
- to highlight how a two year period for assessment is not not sufficient to capture water quality trends. A minimum of four years is used to establish trends within the science community. To ascertain true trends, all data should be subjected to statistical scrutiny over a sufficiently valid period of time rather than the simple reporting of annual means.
- to insist that consideration must also be given to established lag times as to when we can expect a measure to deliver improvements in water quality. Lag times refer to the delay between the time when a particular agricultural practice or activity occurs and the time when its impact on water quality is observed. This delay is due to a range of factors
- The time it takes for nutrients to move through the soil and into the groundwater.
- The time it takes for groundwater to move through the aquifer.
- The time it takes for monitoring data to be collected and analysed.
To highlight that it can be difficult to attribute changes in water quality to specific agricultural practices or activities, as the effects of individual practices or activities accumulate over years or decades.
To emphasise that is not possible to make meaningful conclusions about national or regional trends based on a limited number of monitoring sites over a short-term period of two or three years. Recent modelling work by Teagasc indicated that there was significant year-to-year variability in Nitrogen leaching loss to one metre below surface with no change in management.
To demonstrate that the current terms of the Commission Decision for Ireland ignores this reality. A recent review of seventeen studies concluded that it could take between four and twenty years for mitigation measure to have a positive impact on surface water quality and acknowledges that the presence of lag times explain why positive effects are not always evident within defined cycles.
It also concluded that the response time between implementation of measures and the delivery of water quality improvement broadly increased with catchment size. Under the terms of the Commission Decision, catchment size is only considered at a macro level. Determining trends at this level over a two year period is too narrow to demonstrate the positive impact of mitigation measures that farmers have adopted.
It also ignores, and in fact penalises farmers, in areas where improvement has been demonstrated at sub-catchment level but the catchment at macro level has not yet improved.
To highlight that relying on water quality and the trends in water quality of estuaries to determine maximum stocking rate thresholds is not valid, as it ignores the contribution of wastewater treatment plants and other pressures to declining water status. When understanding the water quality of estuaries it is vital that the pressures posed by urban waste water are considered, given their significance.
To highlight that the expectation that bovine stocking rate is solely responsible for the nitrate and eutrophication status of an estuary is not justified. Estuaries, by their nature, represent the cumulative load of all pressures, both urban and agricultural throughout the catchment.
To emphasise that a longer time period is required to capture water quality trend that are statistically verified and that the status of the estuaries, in particular toe eutrophication status of estuaries, is removed from the assessment as improvements in eutrophication are dependent on a much greater range of factors than the stocking rate alone.
To suggest alternative farm measures that could be undertaken as an alternative to reducing organic Nitrogen stocking rate from 250kg to 220kg/ha.
To recommend that farmers are permitted to use combined organic and inorganic Nitrogen measures, to determine how they would reduce the overall nitrogen load on their farm to meet the reduced overall nitrogen load target of 445kgN/ha. For example, if a farmer wants to maintain their stocking rate at 250kgN/ha, the reduction in total nitrogen load can instead be achieved by reducing the maximum allowance for nitrogen fertiliser allowance on their holding to 195N/ha.
To propose that farmers could make enhanced commitments to prevent nitrate loss over the closed period (winter months). With the technical tables that govern the levels of slurry storage required by farmers during the closed period under review, which will likely result in the requirement for additional slurry storage on many farms, State financial support via appropriate grant aid would result in the required additional slurry storage being put in place over a phased period of time.
To suggest that the maximum allowance for crude protein content of concentrates could be reduced from the current 15% to 13% with appropriate scientific guidance.
To highlight that the recently announced €60m Water European Innovation Partnership (EIP) scheme, which will target 15,000 farmers by 2027, will help to drive further improvements in water quality. This scheme, which was not in place at the time of the awarding of Ireland's current derogation, is a further positive measure that will be undertaker to protect water quality as an alternative to reducing organic nitrogen stocking rates.
To provide workable solutions that can potentially deliver greater improvements to water quality than what could be achieved by reducing the stocking rates on derogation farms and decimating farm incomes.
Name of person primarily responsible for lobbying on this activity
Tim Cullinan IFA President, Tadhg Buckley IFA Director of Policy & Chief Economist, Áine O'Connell IFA Senior Dairy 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.
Brian Leddin
TD (Dáil Éireann, the Oireachtas)
Denis O'Donovan
Senator (Seanad)
Jackie Cahill
TD (Dáil Éireann, the Oireachtas)
Joe Flaherty
TD (Dáil Éireann, the Oireachtas)
Lynn Boylan
Senator (Seanad)
Martin Browne
TD (Dáil Éireann, the Oireachtas)
Matt Carthy
TD (Dáil Éireann, the Oireachtas)
Michael Collins
TD (Dáil Éireann, the Oireachtas)
Michael Fitzmaurice
TD (Dáil Éireann, the Oireachtas)
Michael Ring
TD (Dáil Éireann, the Oireachtas)
Micheál Martin
Tánaiste and Minister (Department of Foreign Affairs)
Paul Daly
Senator (Seanad)
Paul Kehoe
TD (Dáil Éireann, the Oireachtas)
Tim Lombard
Senator (Seanad)
Victor Boyhan
Senator (Seanad)
Charlie McConalogue
Minister (Department of Agriculture, Food and the Marine)
Brendan Gleeson
Secretary General (Department of Agriculture, Food and the Marine)
Amii McKeever
Adviser to Minister (Department of Agriculture, Food and the Marine)