There is growing confusion over the methodology used by the Environmental Protection Agency (EPA) in its latest report on Ireland’s water quality for the European Commission.

The report was published as part of the midterm review of the Nitrates Action Programme and will result in the derogation being cut across most of the country.

However, the derogation is not going to change for large parts of the Bandon and Blackwater river catchments in Cork and the Slaney catchment in Wexford, even though each of these rivers were previously flagged as being too high in nitrates in a 2021 EPA report.

More extensively farmed regions such as Leitrim, Sligo, Roscommon and Mayo will see the derogation nitrates limit there cut to a new maximum of 220kg N/ha.

The EPA has confirmed to the Irish Farmers Journal that the report is based on a subset of data, which is what was requested by the European Commission.

Speaking at the Moorepark open day on Tuesday, Ted Massey from the Department of Agriculture said he expects that the map will be revised to include new areas in the coming weeks.

The cut to the derogation will directly impact over 3,000 dairy farmers who are estimated to be currently stocked greater than 220kg N/ha but the full impact will be far greater as farmers seek to lease additional land in order to retain existing cow numbers, thus increasing the demand for land.

Previous analysis by the Irish Farmers Association said that in order to comply with the new measures an additional 28,000ha would be required by directly impacted dairy farmers to avoid having to cull over 50,000 dairy cows.

Case study

Mary and John are milking 105 cows on their 100ac farm. Heifers are contract-reared and all the land is in one block.

Their cows produce 5,000 litres of milk per year and so they are in the middle band for nitrates at 92kg N/cow. They are availing of a nitrates derogation as their organic nitrogen stocking rate is 242kg N/ha. With the reduction in the derogation to 220kg N/ha, they have three options:

  • Reduce cow numbers by 10 cows to 95 cows.
  • Lease an additional 15 acres of land.
  • Export 121,000 gallons of slurry to farms stocked less than 170kg N/ha who have soil sample results to prove they are at phosphorus index one or two.
  • Concerns raised

    The head of the nitrates division within the Department of Agriculture has conceded that there are “stark anomalies” in the EPA water quality report submitted to the European Commission.

    Ted Massey went as far as describing the report as not including the latest data on water quality improvements.

    He described how the Irish Government had pushed the Commission for more time to allow on-farm measures to improve water quality to take effect.

    However, Massey said that the Commission could not give more time, which forced the Department to submit a report which does not include the impact of measures such as banding, which was only introduced this year.

    Teagasc findings

    Teagasc research has shown that reducing stocking rate from 250kg N/ha to 220kg N/ha would have only a small impact on nitrate leaching, but a substantial impact on farm profit, with profit dropping by between 16% and 29%, depending on what band the herd is in.

    The Teagasc report went on to say that reducing stocking rate carries a risk of system shift on dairy farms.

    It said: “Reducing the maximum stocking rate from 250kg N/ha to 220kg N/ha may result in a move away from a pasture-based system in Ireland towards a European model of forage maize/high concentrate feeding system as some farmers may want to increase output while restricted with cow numbers.

    “International experience has shown that these high-input systems are more detrimental to the environment.”

    Speaking at the Moorepark open day on Tuesday, Massey said he has concerns about what the Commission will look for when the derogation is up for renewal in 2025 and is unsure if Ireland will have a derogation by 2030.