Differences in NAP north to south

At the end of October, the Minister for Housing, Local Government and Heritage, James Browne, opened a month-long public consultation on proposed changes to the nitrates action programme (NAP) in the Republic of Ireland (ROI).

It is the sixth iteration of the NAP in the South, and it will have to first be approved by the European Commission before coming into effect in 2026. The NAP in ROI was last reviewed and updated in 2022. A similar four-year process is supposed to happen in NI, although our last NAP update was in 2019.

Stocking rate

Given the NAP was originally enforced under EU legislation, there are a lot of similarities between north and south, especially around a stocking rate limit of 170kg manure nitrogen (N) per ha per year. In NI, most farmers above this limit prefer to export slurry to reduce their manure N load, although around 400 have availed of a derogation which allows them to operate at up to 250kg N/ha.

In the Republic, over 7,000 farmers operate under a derogation, which had also been at up to 250kg.

However, since January 2024, most of the country has been at a limit of 220kg, with significant fears the derogation, which is ultimately granted by the European Commission, could be lost from 2026 onwards. If that happened, farmers would either need to access more land or cut livestock numbers.

Despite the furore surrounding the NAP which engulfed NI agriculture this summer, there are actually no plans within DAERA to remove the 250kg manure N derogation in NI.

But instead, what has been proposed are new phosphorus limits for more intensive farms in NI of 10kg P/ha in 2027 falling to 8kg P/ha in 2029. Those limits would probably have a similar impact as the loss of the derogation in ROI.

Either way, it reflects the fact that excess P getting into watercourses is seen as the major contributor to poor water quality in NI, while in ROI, the key issue is actually loss of nitrates to water.

Proposals

While the main focus around the NAP in ROI continues to be on the future of the derogation, there are a number of important changes outlined in the latest NAP proposals. They include a 21% increase in the amount of slurry assumed to be produced each week by a dairy cow.

It effectively means any dairy farms operating at the minimum requirement for slurry storage, will have to add 21% capacity by 1 October 2028.

In addition, fragmented farms will be targeted to ensure there isn’t a surplus of nutrients on land around the yard due to intensive grazing and also spreading of slurry.

Where the main grazing block is highly stocked, the farm must prove that slurry is being spread elsewhere.

Crossover

There are also a few policies already operational in ROI, which were included within the DAERA proposals published this summer. For example, since January 2025, the South has had an online register in place, with farmers required to notify the export of organic nutrients to other farms within four days of the export taking place.

ROI farmers have also had to submit information to comply with the requirements of a national fertiliser database since September 2023.

A similar database was included in the DAERA NAP proposals this summer, along with a suggestion it should also track movements of feed. However, the inclusion of feed is not being pursued within the latest NAP plan in ROI due to the “significant resources that would be required and the need to use those resources to address other matters”.

Chemical N

Also notable is confirmation in the ROI document that there are no plans to further restrict chemical fertiliser N use on farms, despite concerns around nitrates entering water.

In recent years, the maximum N allowance has been cut by 15% to 240kg N/ha. However, the latest ROI NAP consultation warns of a risk of forage deficits if N use is further curtailed, leading to an increasing reliance on imported feed, “which would be environmentally damaging”.

That position contrasts to the DAERA NAP plan which suggested that allowance should be made for the N in slurry, effectively cutting the maximum amount of chemical N that could be applied on local farms. Currently, a dairy farmer in NI can apply up to 272kg N/ha, but if the changes were enforced, this would be cut to 182kg N/ha in most cases.

Earlier this summer, leading NI scientist, Dr Sinclair Mayne warned of “unintended consequences” if new N fertiliser limits are put in place in NI. It looks like authorities in ROI have heeded those warnings.