An Taisce highlights the worsening water quality crisis and need for substantial changes in the management of nitrogen inputs to agricultural land to comply with the Nitrates and Water Framework Directives.

Read our full submission here.

Summary of Recommendations

1. We recommend that Ireland should not seek a further derogation, as water quality data indicates that to date we clearly do not have the necessary safeguards in place, nor are they proposed in the consultation documentation for the next Nitrates Action Programme (NAP).
   
   
2. Model the exact load reduction as a result of measures proposed in the new NAP to clearly demonstrate that they will result in the load reductions the Environmental Protection Agency (EPA) has indicated are necessary. Set reducing limits on total N (fertiliser and feed) imported inputs into catchments.
   
   
3. Increases in phosphorus application/build-up should be determined on a case by case basis, with a reliance on the latest EPA data and their Pollution Impact Potential (PIP) maps to indicate potential risk based on soil type and pathway analysis.
   
   
4. The timeframe for banding should be clearly outlined, and expedited.
   
   
5. The requirement for nutrient management planning should be applied to all farmers, starting with all landowners in the most highly nutrient enriched and at-risk catchments. These nutrient plans should be spatially based on the PIP maps.
   
   
6. Nutrient management plans should result from modelling work to determine the level of N which can be safely applied in order to reach the EPA reduction targets. That allocation should then be spatially targeted in keeping with the nutrient management plan and the PIP maps.
   
   
7. Modelling should be carried out to determine the volume of nitrogen deposited by the herd when they’re at pasture, particularly in regard to urine patches. The length of the grazing window should then be limited by the N threshold (<170 kg/N/ha).
   
   
8. An awareness raising campaign should be considered, including highlighting new increased penalties, and the establishment of a confidential reporting mechanism.
   
   
9. The restricted period for soiled water spreading should be temporally aligned with that for slurry spreading, and the storage capacity for soiled waters be sufficient, taking into consideration changing weather patterns.
   
   
10. Interim measures for the reduction of ammonia should be implemented until the infrastructure and measures needed to meet legally binding ammonia thresholds are in place.
    
    
11. Drinking and bathing water protection from pathogens should form an integral part of the new NAP and GAP regulations.

Read our full submission here.