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An Taisce - The National Trust for Ireland

An Taisce aims to take a lead in public interest advocacy and community education for all aspects of sustainable development including human health and wellbeing, climate action, protection of ecosystems, and land, marine and resource use, community resilience, and cultural heritage to cooperate with civil society and other organisations, internationally, nationally and locally.

Lobbying Activity

Response to Commission Directive amending Annex III of the Nitrates Directive

17 May 2024

An Taisce is the National Trust for Ireland. We have a number of serious concerns regarding this proposed amendment to the Nitrates Directive. While we have pasted some of our points below, given the character limit we could not cover all of our points, and would direct the Commission to the attached document for our full submission. 1. Objective of the Directive It is important at the outset to outline the primary aim of the Nitrates Directive, which is provided in Article 1: This Directive has the objective of: reducing water pollution caused or induced by nitrates from agricultural sources and preventing further such pollution. In an Irish context, we are in the midst of a decade long decline in water quality on foot primarily of agricultural pollution, with a marked increase in nitrogen pollution on foot of agricultural intensification on our free draining soils. To put it simply, Ireland is already failing to abide by the obligations of both the nitrates directive and the water framework directive. The safeguards put in place under the Nitrates Action Programme (NAP) are failing, and there is governmental acknowledgement that previous NAPs have failed in their aim to protect water quality from agricultural pollution, and that there is widespread lack of compliance and a failing of enforcement. We are aware of similar issues with nitrogen pollution in other member states. While we acknowledge the benefit of replacing artificial fertiliser with a less fossil intensive renure products in terms of climate benefits, any change to the Nitrates Directive must be cognisant of the nitrogen crisis which is unfolding in many Member States. Now is not the time to loosen the rules on nitrogen application, and any change to the Directive must be one which would bring about greater compliance and better outcomes for water quality. The ultimate scope of the Directive is governed by its objective, and this proposal has not been evidenced to be consistent with the Article 1 objective of the Directive. We would support the points raised on this specific point in the submission by Environment Law Ireland. 2. Renure as substitute for chemical fertiliser There is a distinct lack of clarity regarding how Renure will displace synthetic fertiliser. As worded, the amendment could be interpreted as allowing member states to apply 100 kg of Renure on top of their existing nitrogen load, bearing in mind that the agricultural nitrogen load is already a significant source of pollution for water quality across Europe. However, there is no stipulation in the proposed wording that the use of Renure products should be strictly utilised only as a replacement for synthetic fertiliser. The wording of point 7 of the preamble outlines that: The use of RENURE fertilisers above the amount of 170 kg N per hectare for livestock manure should be authorised with the appropriate safeguards to improve substitution of chemical fertilisers by organic fertilisers This does not strictly require a direct substitution, which could be interpreted as allowing for 100kg/n/ha of Renure additional to the nitrogen load already going onto farmland. If Renure products are to be approved, notwithstanding our other concerns, it is absolutely critical that it is abundantly clear in the wording of the legal amendment that they should only be used strictly as a one for one substitute for chemical fertiliser. Anything less than this could give rise to additional nitrogen load with dire consequences for water quality. 3. Conclusion In light of these concerns we submit that this proposed amendment is premature, ill considered and lacking in an evidential basis that it will be in keeping with the requirements and intention of the Nitrates Directive, the Water Framework Directive, the Habitats Directive and the NEC Directive.
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Response to EU Methane Strategy

12 Aug 2020

+ IPCC SR15 illustrative pathways (see table under Figure SPM.3.b) show near-term agricultural CH4 reduction relative to 2010 & by 2030 is critical to equitable, Paris-aligned climate action. Cutting EU agri CH4 quickly to 2030 would avoid high risk, high cost dependence on afforestation & BECCS CO2 removal that could have severe impacts on land use & farming. + However, CH4 (& N2O) emissions from EU agriculture have failed to decrease since 2010 after earlier reduction. EU policy reversals since 2010 – the removal of milk quotas & increased leveraging of EU CAP subsidies by intensive dairy and beef agriculture for food exports – have resulted in increased use of reactive nitrogen (Nr),in fertiliser & feed, increasing the future contribution of EU agricultural methane to causing global warming. + The Roadmap consultation document fails to mention the important role of Nr inputs as a primary driver for total feedstock mass that in turn drives methane emissions from ruminant & biogas plant (fugitive emission) sources. Reducing total Nr inputs at EU and Member State (MS) levels, as per the European Nitrogen Assessment recommendations, is a critical CH4 Roadmap lever to mitigate agricultural & biogas-fugitive CH4. + In Ireland, agri CH4 emissions are highly correlated with policy: 1990–1997, rising CH4, as EU CAP subsidies enabled greater animal numbers; from 1998–2011, falling CH4 & total GHGs cut due to falling as Nr inputs & dairy cattle numbers; then 2012–2020, rising CH4 again due to an policy change to promote agricultural expansion by increasing Nr inputs to drive dairy herd and milk production increases. Industry-driven Irish agricultural strategies & Government policy since 2010 have therefore been directly contrary to meeting Ireland’s EU ESD and NECD targets. Ireland’s per capita emissions of CH4 & N2O are each three times the EU average, & over 92% of each gas in the national totals are from agriculture. Rising CH4, N2O and NH3 emissions are strongly correlated with inefficient Nr use on grass & cattle numbers as increased feedstock results in more emissions. Per head annual CH4 emissions for dairy cattle have trended steadily up from 1990 to 2020, an inevitable result of greater intensification. Ireland is now also importing > 5 megatonnes of animal feed annually, much from the global South, to supplement domestic production. + Contrary to industry-related feedback to this consultation, TOTAL ruminant emissions are in fact highly responsive to policy, that is by limiting total Nr inputs to the combined agriculture-biomass system. Given that it is changes in total CH4 that affect climate forcing, any emphasis on intensity measures (per unit product etc) is highly misleading. + Relatedly, GHG leakage can ONLY be claimed as a valid issue if MS agri emissions reductions are aligned with existing ESD targets. Irish agri emissions are going up & failing to meet climate targets therefore leakage to other nations is not a primary issue. In fact, Ireland is benefiting from GHG leakage by failing to meet its national targets. + Proponents of using GWP* analysis as a GHG metric for agri CH4 fail to show detailed analysis or that cumulative emissions from a base year or lag effects are key; & also repeatedly fail to explain how reversing recent dairy & beef intensification offers society a very large & highly cost-effective mitigation lever (in addition to energy CO2 reduction). Using GWP* starkly reveals the full extent of Irish policy reversal in agriculture due to strategy since 2010 as being equivalent to adding an additional 380 MtCO2 to atmosphere relative to mitigation from 2005 (see attached pdf). + Expanding biogas production (based on grass) as is planned in Ireland as planned in Ireland risks increased CH4 leakage, Nr use & N2O emissions sufficient to cancel out fossil GHG savings. + Any EU Methane Roadmap must stress substantial & sustained near-term CH4 cuts across all anthropogenic sources, including agriculture.
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