Proposed changes to the Industrial Emission Directive (IED) will impact a larger proportion of EU farms than previously thought.

However, this does not mean that a higher number of farms will be impacted; the number of farms to be affected looks like it will be lower than expected.

This discrepancy – of a higher proportion but lower number of EU farms being affected by the proposed changes – is due largely to the concentration of farming activity on fewer farms over the years, as well as better statistical methodology that prevents mixed farms being counted as more than one farm.

The changes to the IED could see farms above 150 livestock units (LU) requiring a permit to operate.

A livestock unit it based on a coefficient and does not necessarily refer to one animal. For example, 1LU would equate to one dairy cow or one male bovine over two years, while 0.8LU would refer to a heifer or non-dairy cow over two years.

The European Commission had been using data from the 2016 Farm Census – which was carried out by its statistics agency Eurostat – in working out how many farms would be impacted by the changes.

However, preliminary data from the 2020 Farm Census – the most recent census – paints a different picture than the commission had thought, according to a presentation, seen by Agriland, that was given by the commission to an environmental working group of the Council of the EU.

On cattle farms (both dairy and beef), a threshold of 150LU would bring 12.5% of the those farms in the EU under the remit of the IED revisions according to 2020 data, accounting for 46% of the number of cattle in the EU.

Originally, according to 2016 data, it was thought that the new regulations would account for 10% of farms and 41% of the number of cattle.

However, the actual number of farms that would now be impacted has decreased from around 84,000 to between 67,000 and 68,000.

Pig and poultry

The different impact of the two data sets is more stark in the pig sector.

The proportion of pig farms in the EU that would be affected was originally thought to be 18%, representing about 48,500 farms.

According to 2020 data, the proportion of effected farms would rise significantly to 61%, but the number of farms would fall to just over 37,000 (the current IED rules already impact 4% – or just over 11,000 – of EU pig farms).

The number of pigs in the EU that would be affected is 91% according to the 2020 census data, an increase on the 80% figure according to the 2016 census (at present, 35% of the EU’s pigs are under the IED).

In the poultry sector, it now looks like the proportion of farms to be affected is 15%, an increase from 3.7% as originally envisaged.

This 15% of EU poultry farms, as of 2020, represents some 20,300 farms, which is down considerably from the roughly 51,700 farms that, according to the older data set, would have been impacted.

This somewhat counterintuitive situation – the increase in the percentage of EU farms that will be impacted but a decrease in the actual number of farms – is explained in the commission’s presentation by a concentration of the sector between 2016 and 2020, and improved methodology to reduce double counting of mixed farms.

On all farm types taken together, 20% of them will be under the remit of the IED, according to 2020 data, as opposed to 13% according to 2016 data.

This 20% of EU farms equates to around 134,700 farms, a decrease on the 184,200 farms that would have been impacted according to the 2016 census.

IED’s impact

This new outlook for the IED’s impact on farming is regarded positively by the commission. Its presentation said that the 2020 data shows the IED covering a higher share of polluting emissions and a lower number of farms altogether.

These changes would also mean that – as larger farms will be affected – the emission mitigating measures these farms can put in place will be more effective. The 2020 data also indicates a better social benefits to cost ratio of the proposed changes to the IED, according to the commission.

However, Copa-Cogeca, the umbrella group for EU farm organisations, has criticised the commission’s handling of the IED review in light of recent census data.

In a statement, the farming organisation said: “This shows, if it were still necessary to demonstrate it, that these approaches to targets and thresholds…are political, punitive and disconnected from field realities.”

Copa-Cogeca said it hopes EU policy makers “will seriously take into account this new data and re-assess the proposal from the commission”.