The DAFM have just completed a public consultation on their nitrates derogation, as part of a review process. The derogation is granted to Ireland under the EU Nitrates Directive [1], and allows farmers to spread roughly 50% more manure on their land than the regulations normally allow for. It only applies to farms which are 80% grass, and allows farmers to spread 250 kg/ha manure, up from the standard 170 kg/ha.

There has been a year on year increase in the area farmed under derogation in Ireland, facilitating the 50% increase in milk production since 2010, in line with the ambition of the Departments of Agriculture’s Foodwise 2025 strategy for agricultural expansion. [2]

However, these massive increases in productivity come at a cost. Figures from the EPA indicate that agriculture accounted for 53% of pollution in our rivers, and there is a clear correlation between the areas where agriculture is most intensive, and where water quality is worst. [3]

Ammonia emissions, which can have serious health and environmental impacts, are also increasing, with agriculture responsible for 98% of these emissions. Ireland are breaching the limits set under the National Emissions Ceiling Directive [4], and in light of the agricultural targets under Foodwise 2025, the EPA have highlighted that they look set to continue to do so for the foreseeable future, leaving us open to EU legal action. [5]

Agriculture accounts for over 30% of (non ETS) greenhouse gas emissions according to the EPA, who indicate that the biggest driver of increasing emissions in recent years is the dairy industry. [6]

Ireland’s biodiversity is also suffering, and a recent report by the NPWS highlighted failings in the protection of our species and habitats, and clearly points the finger at agriculture, forestry and aquaculture, and the ambitious growth targets set for these by the Foodwise 2025 strategy. [7]

Farming organisations are becoming increasingly nervous that the EU will revoke Ireland’s nitrates derogation, which underpins the recent boom in Irish bovine agriculture. And they have good reason to be: the Netherlands have culled 190,000 cattle since 2016 to reduce phosphate pollution in order to preserve their nitrates derogation. Indeed, Phil Hogan, European Commissioner for Agriculture and Rural Development warned Irish farmers in 2018 that sustainability isn’t a choice, it’s a must, and that failure to act could potentially have very negative consequences for Irish agriculture. [8]

An Taisce believe it is Ireland’s nitrates derogation which is propping up the unsustainable and environmentally damaging Foodwise 2025 strategy. Intensive agriculture is putting Ireland in breach of multiple EU and international laws and agreements, and is one of the root causes of our recently declared climate and biodiversity emergency.

Without drastic measures to reduce the pollution and ecological damage caused by the intensification of bovine farming on both derogation and non-derogation farms the future of Ireland’s nitrates derogation hangs in the balance.

Dr. Elaine McGoff, Natural Environment Officer with An Taisce stated:

‘Sustainable intensification in an oxymoron. Herd reduction and agricultural diversification, as recommended in the Joint Oireachtas Committee on Climate Action (JOCCA) report, are the only way to protect the environment and avert climate breakdown in any meaningful way. ‘

‘Intensive bovine agriculture is the leading cause of water pollution, habitat and species loss, and ammonia and GHG emissions. The data prove that this intensive agricultural model is environmentally unsustainable, whatever way you look at it, and it will ultimately be the death knell for Irish habitats and wildlife.’

‘Given our environmental record I believe the EU would be right to revoke Ireland’s nitrates derogation. How could they continue to sanction this breakneck pace of agricultural intensification once they see the resultant destruction of our wildlife, our waters and our climate?’

An Taisce's submission to the review here.


For further information, contact:
Dr, Elaine McGoff, Natural Environment Officer, An Taisce: +353 1 707 7063
Charles Stanley-Smith, Communications, An Taisce. Tel: +353 87 241 1995
email: [email protected]
An Taisce The National Trust for Ireland


  1. The Nitrates Directive (1991) aims to protect water quality across Europe by preventing nitrates from agricultural sources polluting ground and surface waters and by promoting the use of good farming practices. The Nitrates Directive forms an integral part of the Water Framework Directive and is one of the key instruments in the protection of waters against agricultural pressures.
  2. Food Wise 2025 sets out a ten year plan for the agri-food sector, and provides a strategy to grow the sector in the next decade.
  3. EPA (2016) Ireland's Environment 2016 - An Assessment
  4. EPA (2019) Ireland’s Transboundary Gas Emissions 1990-2030
  5. The National Emission Ceilings Directive sets national emission reduction commitments for Member States and the EU for five important air pollutants: nitrogen oxides (NOx), non-methane volatile organic compounds (NMVOCs), sulphur dioxide (SO2), ammonia (NH3) and fine particulate matter (PM2.5). These pollutants contribute to poor air quality, leading to significant negative impacts on human health and the environment.
  6. EPA (2018) Ireland’s Final Greenhouse Gas Emissions 1990-2016