BirdWatch Ireland is warning Ministers Darragh O’Brien, Malcolm Noonan and Charlie McConalogue that changes to nitrates regulations, which require tillage farmers to cultivate over-winter stubbles, "could have catastrophic impacts on farmland birds that use this vital habitat".
The group described the changes as rushed and blunt and stated research should come before implementation.
There are several farmland bird species which rely on winter stubbles that are already listed as red or amber on the birds of conservation list and BirdWatch Ireland has said the future of these birds is "precarious".
The organisation has asked the Government to halt the proposed changes until research can be carried out to determine the effects they will have on threatened farmland bird species.
In a statement to the Irish Farmers Journal, BirdWatch Ireland explained: "Any proposed legal changes to winter stubble on arable land must be assessed for impacts on these species before being implemented."
The statement went on to say that the Government was implementing the new rules "without any assessment of the impacts on farmland birds that rely on this habitat".
"BirdWatch Ireland supports real and significant cuts in chemical and organic nitrogen on all farmland, but the planned new measure will not result in cuts in fertiliser and will have a disproportionate adverse impact on farmland bird populations."
Research shows that over-winter stubble is important for up to 30 bird species, including skylark, European golden plover, northern lapwing, linnet, common snipe, pied wagtail and meadow pipit during winter when food is in short supply.
The group commented that fertiliser is causing pollution to water and affecting other bird species, but that changes need research.
However, BirdWatch Ireland described the change as "a rushed, blunt national-level instrument with no mitigation measures in place and risks further blows to already declining farmland bird populations".
BirdWatch Ireland head of advocacy Oonagh Duggan stated: “Winter stubbles are a lifeline for hungry birds in the winter. Seeds left over after the harvest and invertebrates present in the soil are a hugely important source of winter food for at least 30 bird species, many of which are already red-listed and already in serious trouble.
“Government is putting the cart before the horse and proposing to undertake research on the effect of this policy change after it comes into effect. This poses real risks to farmland birds that rely on winter stubbles.
"Every sector must play its part in cutting chemical and organic fertiliser use, but with livestock farming accounting for most of the pollution of our waterways, the focus should be there until research has been undertaken to determine the effects of cuts in winter stubble.
"Despite messaging that addressing pollution must be evidence-based and targeted at farm and catchment level, the proposed change is at national level, is untargeted and lacking the scientific underpinning to ensure no unintended consequences.”