If Ireland loses the nitrates derogation then over 200,000 dairy cows would need to be culled, according to a new report by Teagasc.
The report, which was prepared at the request of the Department of Agriculture, is based on National Farm Survey data and looks at a number of mitigation measures in response to the loss of the derogation.
If cow numbers are to be reduced, the average reduction will be 27 cows per dairy farm, or a 14% reduction in cow numbers.
This will have the impact of reducing the national herd by over 200,000 dairy cows, a figure previously suggested as being required in order to meet Ireland’s climate change targets.
The impact on family farm income will be stark, with a reduction of over €43,000 or 39% in family farm income forecast. Nationally, a reduction in cow numbers of 14% will result in a 15% reduction in milk production, with the report stating that each 1% reduction in the national milk pool will result in a €64m reduction in export revenue.
Therefore, a 15% reduction in the national milk pool will result in a loss of export revenues of almost €1bn each year.
According to the report, reducing cow numbers is the simplest of all the scenarios to implement and the only scenario that does not require the cooperation of other farmers to implement.
Leasing land and slurry exports
The report also looked at the impact of leasing additional land in order to maintain cow numbers. It found that dairy farmers will require an additional 15ha of land to be leased at an average cost of €10,928 per farm which is 15% of the average family farm income.
A total of 112,983ha of land will be required by dairy farms if taking on more land to dilute nitrates is the sole measure adopted in the event that the derogation is lost. Interestingly, the report pours cold water over the slurry exporting option.
Compliance
It says that over 94 tankers of slurry with a capacity of 2,500 gallons each would need to be exported off the average dairy farm if it is to be compliant in the event that the derogation goes.
This is more than the amount of slurry produced on these farms, with the report suggesting that the requirement is 169% of the total slurry produced on average.
Furthermore, the report does not take into account farms that are already exporting slurry in order to be compliant with existing rules. The impact on soil fertility with the loss of phosphorus and potash contained in the slurry is also seen as a negative to this approach. This report will be a blow to proponents of anaerobic digestion (AD), some of whom claim that AD will be a viable option for farms affected by potential cuts to the derogation.
On removing non-dairy stock and instead contract rearing replacements, the report states that the average costs will be €11,257 per farm, presuming cow numbers stay the same.
This represents 9% of family farm income.
Over 50% of slurry to be moved on higher-stocked farms
The Teagasc report on nutrient distribution states that 50% of the slurry needs to be spread on outfarms where the milking platform stocking rate exceeds 3.5 cows/ha for herds in the middle band for nitrate excretion.
For herds in the highest band, the same amount of slurry needs to be moved to outfarms where the milking platform stocking rate exceeds 3 cows/ha.
Where the stocking rate exceeds 3.4 cows/ha, 100% of the slurry needs to be moved to outfarms for herds in the top band.
These recommendations form part of the Department of Agriculture plan to ensure better distribution of nutrients within farms.
Last month, the leaked nitrates expert group report recommended that where farmers cannot prove that the slurry has been moved to outfarms should get a lower nitrogen allowance.
That report suggested farmers who are required to move slurry should use the same reporting system as used when exporting slurry to other farms.
This involves notifying the Department of Agriculture within four days of the movement.
The Teagasc report which was published last week states that farms with a lower milking platform stocking rate will have no requirement to move slurry to outfarms.
No mandatory slurry movements to outfarms will be required for herds in band one that are stocked at up to 3.6 cows/ha on the milking platform.
The same applies for herds in band two stocked at up to 3.1 cows/ha while for herds in band three, any farm stocked greater than 2.7 cows/ha will have to prove that some or all of the slurry is being moved to outfarms. According to the report, there is 18kg of nitrogen per cow per year captured in slurry during the housed periods.
By distributing the nutrients produced during the housed period across the farm holding it is expected that the risk of nutrient losses will be reduced.
However, the report states that the implementation and enforcement of any changes will result in a significant challenge at farm level.
Slurry production 24% higher than the current storage rules in place
The final Teagasc report on slurry storage stops short of suggesting what increase in slurry storage is required over the winter months. However, the report states that on average over the winters of 2023/2024 and 2024/2025 that the average amount of slurry produced was 409l/cow/week.
Present regulations state that 330l of storage is required per cow each week. If the figure of 409l was adopted by the Department of Agriculture, then this would represent a 24% increase in slurry storage requirements.
Changes to slurry storage regulations has previously been flagged by both the Department of Agriculture and Teagasc.
The nitrates expert group recently recommended that a sufficient lead-in time should be applied before any changes to the rules come into force.




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