Sustainable Water Network (SWAN) CLG
SWAN
SWAN is network of 25 of Ireland’s leading local & national environmental groups, working together to protect Ireland’s rivers, lakes, bays, seas & groundwaters.
ID: 296970651291-01
Lobbying Activity
Meeting with Maxi Espeter (Cabinet of Commissioner Christophe Hansen) and Irish Environmental Network
1 Oct 2025 · Discussion on the environmental and climate aspects of Commission's Post-2027 CAP proposal of 16 July 2025
Meeting with Lynn Boylan (Member of the European Parliament)
9 Apr 2025 · Offshore wind and biodiversity protection
Response to Commission Directive amending Annex III of the Nitrates Directive
17 May 2024
1. Objective of the Nitrates Directive It is important, when considering potential changes to the rules governing nitrates, that the context must be the primary objectives of the Nitrates Directive of reducing water pollution caused or induced by nitrates from agricultural sources and .. preventing further such pollution. In Ireland, water quality decline over the past decade is linked to increased nitrogen pollution from increased intensification of dairy farming, in particular in the South and Southeast of the country. It is therefore clear that in Ireland, the primary objectives of the Directive are currently not being met so any change to the Nitrates Directive must ensure that it does not further exacerbate nitrate pollution from agriculture. In light of these ongoing declines, SWAN does not believe it is a suitable time to relax the rules on nitrogen application, and that only changes to the Directive which would deliver better water protection should be permitted. We do not believe that evidence has been provided that this proposal will do this. 2. Renure as a substitute for chemical fertiliser It is unclear from the proposal how Renure will displace synthetic fertiliser. As worded, the amendment could be interpreted as allowing the application of 100 kg of Renure in addition to farmers existing nitrogen load; there is no requirement in the proposal that the use of Renure should be strictly utilised only as a replacement for synthetic fertiliser. This is of significant concern to SWAN given that agricultural nitrogen load is already a significant source of water pollution across Europe. It is SWANs firm position that if Renure products were to be approved (but only after the evaluation see 3. below - if it were deemed appropriate against a range of indicators) it is critical that the wording of the legal amendment includes a very clear requirement that they only be used strictly as a substitute for chemical fertilizer and that it does not entail the application of any additional nitrogen. 3. Unorthodox timing SWAN questions the strange timing and claimed urgency for the introduction of this change, at the very same time as a full evaluation of the Nitrates Directive is taking place. This is an unorthodox and very questionable decision. We dont agree that an interim solution is necessary while the evaluation is progressed, given that this is not an excessively lengthy process. This would appear to us to be very fragmented and ill-judged governance. Therefore, SWAN is calling for no changes to be made to the Directive until the evaluation is complete. 4. Scientific basis for 100 kg We support An Taisces analysis that no basis is provided for the 100kg/N/Ha of Renure figure, which does not appear to stem from the JRC research. We also support their call on the Commission to provide the scientific basis for this limit, in light of the environmental issues outlined in the JRC report, which may arise depending on the farm system, application method/timing etc. It is unclear to us how a uniform 100 kg/N/Ha is deemed to be applicable across all member states and farming systems, and the scientific basis for that, and how this proposed amendment has been demonstrated to be compliant and in line with the obligations and objectives of the Water Framework Directive and the Habitats Directive. 5. Summary In view of the concerns set out above our position is that: i. This proposed amendment is premature and lacking evidence that it is in line with the requirements of the Nitrates Directive or of the Water Framework Directive. ii. No changes should be made to the Nitrates Directive until the full evaluation is complete and iii. The use of 'Renure' products can only be permitted then, if it includes a clear requirement that they can only be used strictly as a substitute for chemical fertilizer and that it does not entail the application of additional nitrogen.
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