The decision by the EU this week to signal the end, or at least the possible beginning of the end of current derogation conditions in Ireland under the nitrates directive cannot be construed as anything but bad news.
The narrative around the decision ranges from a criticism that the case made by Ireland and the Department of Agriculture, Food and the Marine (DAFM) was not vigorous, to a very real concern that the EU Commission is not listening – because it has tuned out of any notion of environmental derogations having placed all its future bets on the EU Green Deal.
All of this is moot it seems to me.
The regulatory process under which the derogation was reviewed was first and foremost administered not through DAFM, but through the Department of Housing and assessed by the Environment Protection Agency (EPA).
Ireland’s obligations under the nitrates directive are clearly set out on the Department of Housing’s website.
The criteria for the mid-term 2023 review outline:
“An interim review will be undertaken in 2023, that will include an assessment of water quality.
“If this water quality assessment indicates average water quality above a threshold of 50 mg/L nitrates (NO3), or increasing trends, or eutrophic water bodies or water bodies that could become eutrophic, the derogation application limit of 250kg nitrogen (N)/ha will be reduced to 220kg N/ha in farms in these catchment areas from 2024.”
So what is the major concern with reference to this process?
It seems to me it is the omission, in the water quality assessment process, of any cause and effect determination.
So the threshold of 50mg/NO3 might have been exceeded, but is it clear that this was solely due to cow numbers or even agricultural activity in the various catchment areas?
What Ireland urgently needs is the development of a clear and concise template that assesses the impacts on particular catchments including housing and other non-agri impacts.
We also need a template that provides clearer guidance to farmers on the impact of specific production measures and one that can only help to clarify the specifics of environmental impacts and every bit as importantly debunk some of the anti-agri noise of recent years .
Scientific investigation and verification is also badly needed to rebuff some of the ‘too many cows in Ireland’ nonsense that we have heard incessantly over the last three years.
I have said before that the anti-agri trope in Ireland currently reminds me of the relentless anti-EU dirge that ‘misinformed’ the UK debate on Brexit and while we might snigger and feel superior at the mess the British made of Brexit, we are not beyond making our own similar-scaled mess with Irish agriculture.
Based largely on incredible – as in an unbelievable – relentless case made by the shrill lobby that suppression of Irish agri output is the key to tackling global climate challenges and that a shrinking agri sector would not be missed because we have an endless pipeline of foreign direct investment (FDI) projects.
The recent fiasco in the some parts of the media about 2014 surveys that portray farmers as climate deniers and the faux outrage around the EPA decision to remove its X (formerly known as Twitter) statement on red meat consumption are a reminder of a number of facts that are excluded in some quarters but are absolutely key to delivering a progressive Irish agri sector into the future.
These include that Irish agriculture, not exclusively, but in the majority based on the Teagasc Marginal Abatement Cost Curve (MACC) will go far closer to reaching its 2030 targets than any other sector of the economy.
Also that Article 2 of the Paris accord on climate change, commits all signatories, including Ireland, to “increasing the ability to adapt to the adverse impacts of climate change and foster climate resilience and low greenhouse gas emissions development, in a manner that does not threaten food production”.
It must also be taken on board that carbon leakage is a real dilemma – not just some greenwashing excuse dreamed up by the agri lobby – as is recognised in the 2019 Intergovernmental Panel on Climate Change (IPCC) report that calls for specific requirements in World Trade Organisation trade deals to avoid the replacement of low carbon.
What this comes down to is that Irish and EU highly regulated production should not be replaced with production from non-regulated high-carbon producing areas – Brazil Beef, India, Pakistan Dairy – and repeatedly highlighted in Organisation for Economic Co-operation and Development (OECD) and Food and Agriculture Organisation (FAO) forecasts of future production trends.
Finally, and perhaps most simply or succinctly – we cannot all live in Dublin “or the greater pale”.
So a “policy” of relentlessly undermining and constraining Irish agriculture – which currently supports in excess of 220,000 jobs across the rural and regional Irish economy, largely outside the “pale” – is extraordinarily daft and small-minded in a regional economy and national economy context.