The Irish Farmers’ Association (IFA) has outlined a series of proposals, including a commitment by farmers to increase slurry storage capacity on farms, in a bid to maintain Ireland’s current nitrates derogation.

It is among the submissions made by members of the Department of Agriculture, Food and the Marine (DAFM) Agriculture Water Quality Working Group.

Minister for Agriculture, Food and the Marine Charlie McConalogue asked stakeholders in the group for their views on potential “flexibilities” in the face of a likely reduction of the nitrates derogation.

This followed a report from the Environmental Protection Agency (EPA) identifying areas where farms will likely have to reduce their application rate of organic manure nitrogen (N) from 250kg N/ha to 220kg N/ha from 2024.

The review of Ireland’s water quality was required by the EU Commission as part of the conditions attached to the latest nitrates derogation for Ireland.

Nitrates

The IFA said that it wanted to “provide workable solutions that can potentially deliver greater improvements to water quality than what could be achieved by reducing the stocking rates on derogation farms and decimating farm incomes”.

The association states that any measures outlined in its submission are conditional on maintaining existing stocking rate thresholds of 250kg N/ha on derogation farms.

The IFA argued that a two-year period is insufficient to determine water quality trends, adding that a longer time frame is needed to allow improvement measures to have an impact.

It also pointed to the need for the commission to consider the impact of urban waste water, particularly in estuaries.

Farmers and water quality report

The Agricultural Catchments Programme (ACP) has demonstrated that 50% of nitrate loss occurs in 25% of the year, specifically over winter months.

“To reflect this reality, farmers could make enhanced commitments to prevent nutrient loss over the closed period,” the IFA said.

The association said it understands that the technical tables governing the level of slurry storage required by farmers during the closed period is under review.

“This is likely to result in the requirement for additional slurry storage on many dairy and livestock farmers.

“With state financial support via appropriate grant aid, the required additional slurry storage could be put in place over a phased period of time,” it said.

Alternative farm measures

The IFA said that if the stocking rate threshold were to be reduced to 220kg N/ha, this would equate to a total nitrogen load of 445kg N/ha.

The association suggested that farmers would be allowed to determine how they would reduce the overall nitrogen load on their farm to meet the reduced overall nitrogen load target.

“If a farmer wants to maintain their stocking rate, the reduction can be achieved by reducing the maximum allowance for nitrogen fertiliser allowance on their holding,” it said.

The IFA also said that the maximum allowance for current crude protein content of concentrates fed from April 15 to September 30, could be reduced from 15% to 14% in the short term, and “with appropriate scientific guidance could possibly be further reduced to 13%”.

The association said that the new €60 million Water European Innovation Partnership (EIP) scheme is a “further positive measure that will be undertaken as an alternative to reducing organic N stocking rates”.

“These alternative measures can further minimise nutrient loss to catchments, deliver improvements in water quality without the devastation that a reduction in organic N stocking rates would cause to farm livelihoods, in particular smaller family farms,” the IFA said.