Nitrates Action Programme, farming and the future

Ireland’s water quality is declining. In 53% of water bodies at risk of not achieving good ecological
status, agriculture is the single biggest pressure contributing to water pollution, according to the EPA. One third of rivers and lakes and one quarter of estuaries have excess nutrients (nitrogen and phosphorous) and the concentrations are continuing to rise. Other significant pressures on water quality from agriculture include pesticides, sediment and harmful bacteria and viruses. There are 139,600 farm holdings in Ireland and most of them produce agricultural nutrients (manure, slurry) and use chemical fertilisers to promote growth on the farm. Improper use of fertilisers, inadequate storage or poor application practice for local soil conditions can result in nutrients entering streams and rivers causing pollution and leading to excessive growth of algae and reduced oxygen levels.

The Nitrates Action Programme (NAP) first introduced in 2006 is designed to prevent pollution of
surface waters and groundwater from agricultural practice. A draft for the fifth iteration of the NAP is currently in development. This latest draft proposes a range of new initiatives and additional measures the agricultural sector needs to undertake to protect water resources.
The principal elements of the NAP include:
• limits on farm stocking rates
• legal maxima for nitrogen and phosphorus application rates
• prohibited spreading periods preventing the application of organic and chemical fertilisers
during more environmentally vulnerable times of the year
• minimum storage requirements for livestock manures
• requirements regarding maintenance of green cover in tillage lands and
• set-back distances from waters.

One of the key recommendations made by An Fóram Uisce in their submission on the latest draft NAP, is that it is essential to have policy coherence in the management of Ireland’s environment. The establishment of a designated policy coherence group to ensure alignment between the key national and European policies which impact both agriculture and the environment, such as the River Basin Management Plan, the Nitrates Action Programme, the Common Agricultural Policy and the Food Vision 2030 is recommended.

The Forum recommends that the NAP adopts an integrated land use management plan, using nutrient management plans aligned with the EPA’s pollution impact potential maps and catchment assessments to form the basis of a joined up collaborative and cooperative approach to environmental management. Engaging with farmers early in the development of landscape-scale or catchment-based actions so that farmers are facilitated to co-design solutions and have input to the NAP requisite of ‘right measure in the right place’. A catchment level approach could potentially encourage peer learning and the sharing of knowledge with the wider farm community.

A concern among Forum members is that there will never be enough resources available to increase inspections and enforcements nationally to ensure full compliance with Good Agricultural Practice and NAP regulations. Awareness, training and supports should therefore be resourced in an attempt to increase the understanding around the need for compliance with GAP regulations for the protection of water, climate, and biodiversity, with a view to voluntarily increasing levels of compliance rather than through enforcement. If farmers are involved in the co-design of locally targeted mitigation measures, there is likely to be an increase in ownership and willingness to comply with these measures.

Many of the actions identified to protect water such as installing buffer strips, reduced stocking rates, increased storage capacity, protecting wetlands and fencing all have a cost attached and essentially reduce farmers income. The Water Forum supports the principle of public money for public good but protecting and restoring the increasing needs of nature is not cheap.
With important policies such as the Common Agricultural Policy, Climate and Biodiversity Action Plans and the Nitrates Action Programme and the draft River Basin Management Plan all at development stage, there is a unique opportunity to streamline actions and funding for the most effective environmental outcomes.

The Forum would like to see greater social discourse on how the measures required by these policies will be funded. Everyone knows that comprehensive action now is the intelligent economic option as the cost of making good when the environmental harm is done will not just be an economic one but has implications for the health and well-being of society.

An Fóram Uisce Submission to the draft Nitrates Action Programme

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