Relevant Matter
Public policy or programme
Public Policy Area
Agriculture
Period
1 May, 2023 to 31 Aug, 2023
Specific Details
Water Quality Monitoring Report on Nitrogen and Phosphorous concentrations in Irish Waters 2022
Intended results
To highlight how, both the environmental and economical sustainability of Irish agriculture is underpinned by our temperate climate which allows us to produce beef and dairy produce from pasture. 92% of all agricultural land in Ireland is grassland, compared with an EU average of 31%.
To emphasise that our grass-based system is unique among Europe where livestock are typically reared indoors. Irish agriculture is dominated by small to medium-sized family farms, with an average farm size of 33 hectares. The average stocking rate (livestock units per ha) in Ireland is 1.3 units per hectare (2.1 units per hectare for dairy herds) per hectare which is relatively low compared to other EU countries including the Netherlands (3.4 units), Malta (3.2 units) and Belgium (2.7 units).
To demonstrate that, in order to maximise the amount of pasture utilised in livestock production systems Ireland avails of a Nitrates derogation. The justification for having the derogation in Ireland is based on objective criteria, such as the long growing seasons, which ranges from 330 days per year in the south-west to around 250 days per year in the north-east, and the high yields of grass with high nitrogen uptake.
To highlight how the Commission's condition granting Ireland a derogation included the requirement to conduct a two-year review of water quality (2021 and 2022), to take place in 2023, to determine maximum stocking rate thresholds based on nitrates concentrations, eutrophic status and their respective trends was introduced without consultation with stakeholders and will have a significant economic impact on derogation farmers livelihoods and deliver negligible improvements to water quality.
To outline that the competitive advantage of grass-based systems is based on maximising grass utilisation. Where stocking rate is not sufficient relative to pasture growth potential on a farm, it will result in lower grass utilisation, lower sward quality and reduced animal performance
To highlight how the imposition of a lower organic N limit per ha could move farmers away from pasture-based systems to a higher input system (more bought in feed) in an attempt to maintain milk output from the farm.
To demonstrate how the "Red Map" (Water Quality monitoring report on nitrogen and phosphorus concentrations in Irish Waters 2022) is nonsensical - this is not a criticism of the EPA but a criticism of the framework they were requested by the Commission to use when categorising areas for a reduced stocking rate threshold. Those that have studied this rather than the headlines would understand that the Targeting Agricultural Maps is the preferred option of the EPA for targeted actions.
To highlight the flaws associated with the Environmental Protection Agency (EPA) measurement of water quality to determine stocking rate thresholds. Most notably
1. An assessment of trends between two years is too short as it ignores the reality of lag times. 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, including 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; and the time it takes for monitoring data to be collected and analysed.
As a consequence, 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.
It is therefore 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. These delays must be quantified in order to establish realistic deadlines, thresholds and policy expectations, and to design effective best management practices.
2. The Eutrophication status of a water body is impacted by a multitude of pressures and associated nutrients. Thereby improving its status is dependent on a variety of measures and not just simply a reduction in stocking rate. In addition, the Nitrates Directive itself requires the Eutrophic status of surface, estuary and coastal waters every four years, while the Commission decision insists that a comparison be made between 2021 and 2022. This is not consistent.
3. A reduced stocking rate threshold of 220kgN/ha will have a negligible impact on water quality. It is modelled by Teagasc to reduce nitrate loss to 1m soil depth by 2.2kg N/ha.
However, due to Irelands heterogenous landscape, its contribution to catchments with be variable and inconsistent. While its benefit to water quality is questionable the economic impact of the reduction is guaranteed. IFA estimate that the loss to the rural economy will likely be €236m. However, the impact it will have on the impacted family farms will be much more devastating.
4. Given that our estuaries capture significantly large catchment areas and pressures, the use of their status to determine stocking rate thresholds is not valid, as it ignores the contribution of wastewater treatment plants and other pressures to declining water status.
27% of transitional water bodies (estuaries & coastal lagoons) are at risk of not achieving good status and are impacted equally by the combined effects of urban wastewater & runoff (40%) and agriculture (43%).
5. Over 30 measures have been included in the Nitrates Directive since 2018 which need to be given time to demonstrate improvements. Of critical importance, the introduction of banding and its impact on stocking rates was only introduced in 2023 and hence this very costly measure adopted by farmers is ignored within Article 12.
To emphasise the seriousness of the issue, an IFA delegation met with the Nitrates Unit of the European Commission in February to outline our concerns relating to the details of Article 12. Subsequently, IFA made a submission to the EU Commission In March, the Minister for Agriculture reflected on our concerns and informed the Seanad that he would be seeking further flexibility on Article 12. This flexibility needs to be obtained as a matter of urgency.
To point out that, in the past two months the Minister for Agriculture has put together an Agriculture Water Quality Working Group which he consistently refers to since its establishment. This Group is in its infancy with its fourth meeting held yesterday and it may well prove to be a useful vehicle in helping protect water quality in the medium-term.
However, the current issue relating to a possible reduction to 220kg organic N is far too pressing and urgent to hand over to a working group just formed in the past six weeks
To demonstrate that the most recent National Farm Survey data reveals that the average dairy farmer (who is most affected by any changes to the derogation) has €127,477 of bank borrowings with 77% of this classed as medium to long term debt. This debt is typically present on younger farmers whose repayment capacity is based on the premise that a 250kg organic N limit is applicable.
If a 220kgN/ha stocking rate threshold is introduced, it will likely place some of these farms in financial jeopardy. How could we agree to more costly measures when we find our farmers in this situation?
To emphasise how farmers are very aware of their responsibility towards protecting water quality and have made significant investments on their farms to mitigate their pressure on local catchments. An assessment of water quality must be scientifically robust, fair and justified.
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 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.
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)