Nitrates Action Plan


The following is an article first published in the IHFA Holstein Friesian Spring Journal 2021. It looks at the Nitrates Action Plan (NAP).

The Nitrates Action Plan has been drafted by DAFM and can be read in full here

As part of the consultation process, IHFA made the following submission which can be read here

Farming plays an important role in the Irish economy and landscape, and approximately two-thirds of the Irish land area is in agricultural use. Water quality in our rivers, lakes and groundwater is relatively good but needs to improve. Farming practices play a key role in this improvement. Under the Water Framework Directive (WFD), Ireland has key targets to achieve.

Agriculture covers over 65% of the land area of Ireland and is the most frequent significant pressure in water bodies that are not meeting their Water Framework Directive targets. The main problems from farming are loss of excess nutrients and sediment to water. Excess phosphorus and sediment are typically issues for rivers and lakes, while too much nitrogen is the main issue for estuaries and coastal waters.

Where agriculture is identified as a significant pressure, the Local Authorities Waters Programme is working with the Agricultural Sustainability Support and Advice Programme (ASSAP) providing farmers with a free and confidential advisory service to help improve water quality. The programme is facilitating a far more targeted approach in terms of delivering the right measure in the right place. A major focus is in 190 areas that have been identified for priority action in the plan. 

The Nitrates Regulations

The Department of Housing, Planning and Heritage is the lead authority for nitrates regulations (SI 605 2017).  The purpose of these regulations is to give effect to Ireland’s Nitrates Action Programme for the protection of waters against pollution caused by agricultural sources. The set of measures in these regulations provides a basic level of protection against possible adverse impacts to waters arising from the agricultural sources. 

The Nitrates Action Programme (NAP) Review 2021

Ireland’s current Nitrates Action Programme (NAP) concludes in 2021. The process of reviewing the nitrates regulations and derogation has commenced, and is now open for consultation with all stakeholders. This initial consultation closed on the 15th January 2021 and a second consultation will open shortly. 

Purpose of the initial consultation

In accordance with the directive, Ireland’s Nitrates Action Programme (NAP), which is currently given effect by the European Union (Good Agricultural Practice for the Protection of Water) Regulations 2017, as amended, must be reviewed by the end of 2021. This will lead to the implementation of a new NAP, covering the period 2022 to 2025, inclusive. The purpose of this consultation is as follows: 

• To set out the draft timetable and work programme to produce the next NAP; 

• To set out the potential issues to be considered as part of the review; 

• To highlight milestones in the review cycle where further consultation will take place; and 

• To invite interested parties to make submissions on the above. 

This consultation also forms the starting point for delivering on the following commitments in the 

Programme for Government (extract)

• Review the effects of the nitrates derogation on water quality, in conjunction with the EPA, which will inform future policy in this area. 

• Work with nitrates derogation farmers to improve environmental outcomes on their farms, ensuring the sustainable use of the derogation, in line with our environmental objectives. 

Context of the Consultation Questions

The consultation to date has outlined a number of detailed issues. It should be noted that the initial consultation is exploratory and others can be raised in submissions. While these areas were identified for response in the consultation, the review will consider the wider agricultural sector and wider policy issues.

Better policy alignment

It is becoming clearer that there needs to be greater alignment between different environmental protection policies at a national and European level. In particular, the Farm 2 Fork and the EU Biodiversity Strategy for 2030 have set ambitious targets for the agricultural sector. In Ireland, the links between water quality plans and programmes, biodiversity strategies and climate adaptation plans needs to be developed to ensure we are achieving multiple benefits for as many implementation measures as possible. There are natural links between the measures required to protect each of these areas, and it is the role of policy-makers and stakeholders to ensure these links are strengthened as much as possible.

Also, the review needs to recognise that other areas such as Climate, Biodiversity and the Nitrates Derogation will be play a key part in framing the next Nitrates Action Programme.