The net margins of high-yielding dairy systems would be halved in comparison to the levels achievable at 250kg organic N/ha if the nitrates derogation were to be lost completely.

That was the warning given by Irish Co-operative Organisation Society (ICOS) president Edward Carr to the Oireachtas Joint Committee on Agriculture on Wednesday evening and based off the assumption that farmers would drop cows, rather than source extra land.

Carr cited figures showing a 56% reduction - equivalent to a €983/ha hit - in margins when the figures are crunched on herds in the highest bands at 250kg N/ha versus 170kg N/ha.

Similarly, the ICOS boss stated that a well-run herd of 94 average-yielding dairy cows would have to slash cow numbers by 34% to comply with a stocking rate of 170kg N/ha.


Particular concerns were raised by the co-op group on the impact a derogation loss would have on the medium-sized family dairy farms which represent two in every five of the 2,150 of the farms affected by the cut from 250kg N/ha to 220kg N/ha.

“A reduction in cow numbers on these farms will put into question their future viability. These are family farms which have been passed on from one generation to the next,” TDs and senators were told.

Carr stated that the dairy processing sector invested €1.6bn in facilities to process the three billion additional litres of milk produced per year since the abolition of milk quotas, with this investment made on the back of the “very legitimate aspiration” of farmers to increase farm output.

'Cumbersome' regulations

Agricultural Consultants Association (ACA) president Noel Feeney told the committee that the nitrates action programme has become “too cumbersome and extremely difficult for any farmer to comply with”.

The ACA warned that the risk of an administrative burden kicking a farmer out of derogation and incurring penalties is heaping pressure on derogation advisers. / Philip Doyle

“Minor administrative breaches of the derogation regulations today will result in rejection of a derogation application, exclusion from derogation for two years and significant cumulative penalties across all support payments,” the head of the private advisers’ association said.

He added that some of these administrative mistakes can be the result of “simple errors” made by farm advisers on a Department of Agriculture IT system “needing a complete overhaul”.

Reporting to Brussels

Wednesday evening was the third successive week that the committee heard views on the topic of Ireland’s nitrates derogation; the first sitting heard farming organisations air their views, while last week heard from environmental groups.

The Irish Farmers' Association (IFA) previously warned the committee that the loss of the 220kg N/ha stocking rate would hit the land market if derogation dairy farmers were to maintain stocking rates, as an additional 86,000ha of land would enter dairying to the loss of forestry, anaerobic digestion and forestry.

Last week, an Taisce claimed that a reduction in the nitrogen loading of catchments was the main tool which should be the focus of efforts to cut nitrates losses to waterways.

The committee intends to compile a report to be sent to the European Commission on the importance of the derogation to Irish farming and the implications of losing the allowance provided for under EU law.

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IFA warns losing derogation would hit climate targets

Current water quality measures on farms ineffective for nitrate – An Taisce