The European Commission is set to propose that farms with 100 cows or more will require permits, as part of the EU’s Industrial Emissions Directive (IED).
A leaked document drafted by the commission shows that, under a review of the IED that has recently been undertaken, it is now recommended that the permit system – which already exists for large pig and poultry operations – would be extended to cover larger cattle (including dairy) enterprises.
As well as that, the recommendations include a proposal to increase the number of pig and poultry farms that would be subject to permits by lowering the threshold of livestock units (LUs) at which permits are required.
The document – which lumps larger farms and industrial activity together as ‘agro-industrial installations’ – is set to be published next week. However, the document’s own timeline suggests that, even if these changes are passed and agreed at all necessary levels in the EU, they would not be implemented until sometime after 2027.
As well as that, sectoral sources have expressed the view that this proposal – or certainly parts of it – will not come to pass in its current form.
But what exactly has the commission proposed?
The proposed thresholds of LUs for which permits would be required in the different sectors are: 100 LUs for cattle or a mixed cattle, pig and poultry operation; and 125 LUs for pigs, poultry or a mixed pig and poultry operation.
However, it’s important to note that one LU does not always refer to one single animal, i.e. for smaller animals, several of them equate to one LU.
So, according to a separate EU regulation, the conversation rate of animals to LUs is as follows:
- Bulls, cows and other cattle over two years old – one LU;
- Cattle aged between six months to two years – 0.6 LU;
- Cattle below six months of age – 0.4 LU;
- Sheep and goats – 0.15 LU (not covered in this proposed regulation);
- Breeding sows over 50kg – 0.5 LU;
- Other pigs – 0.3 LU;
- Laying hens – 0.014 LU;
- Other poultry (except broilers) – 0.03 LU;
- Although an ‘official’ LU conversion rate does not exist for broilers, the new recommendations propose setting a rate of 0.007, based on “scientific evidence”.
To determine the number of LUs a farm holds, the number of animals on the farm in the categories outlined above can be multiplied by corresponding LU conversation rate.
So on cattle farms, for example, the bulls, cows and other cattle over two years old each count as one livestock unit; the number of cattle aged between six months to two years can be multiplied by 0.6 to determine the number of LUs that these animals equate to; and the number of cattle below six months of age can be multiplied by 0.4.
If the combined number of LUs from those three categories is 100 or greater, than that farm would require a permit if these regulations come to pass.
This same formula can be applied to the various categories of animals on a farm to determine the total number of LUs a farm holds.
Obviously, most cattle farms have a mix of cattle from across those three categories, but some pig and poultry farms may only consist of one of the categories outlined, such as ‘other pigs’ or laying hens.
So for these farms, it may be easier to work out the actual threshold of animal numbers for which permits will be required. This can be done by reversing the process – dividing the LU threshold in the proposal by the LU conversion rate.
In this case, the animal numbers above which a permit would be required are as follows:
- Breeding sows over 50kg – 250 (125/0.5);
- Other pigs – 416 (125/0.3);
- Laying hens – approximately 8,900 (125/0.014);
- Other poultry (except broilers) – approximately 4,150 (125/0.03);
- Broilers approximately 17,850 (125/0.007).
The proposal contains various other notable changes to the Industrial Emissions Directive, including around enforcement and monitoring.
However, it is important to note that this is only a proposal at this stage; is unlikely to come into effect for several years; and is likely to be altered before it is ultimately enacted.
The commission is set to formally publish the proposal next week. Stay tuned to Agriland for further coverage.