Environment Council Report March 2025

1. Activity since last National Council 
2. Interim Review of 5th NAP was completed and the amended Good Agricultural Practice for the Protection of Waters regulations (SI No 113 of 2022, as amended) was signed into law as SI No 42 of 2025 on the 28th February. In December 2024 and January 2025, IFA made a submission to the public consultation on the interim review and to the Strategic Environmental Assessment (see Appendix 1 and 2). The changes introduced are:
3. Revised nutrient excretion rates for calves to reflect their lower nutrient output, especially in their first 90 days. Nutrient excretion rates for other cattle aged less than 1 year and for 1-2 year old cattle are also updated to reflect the latest Teagasc research.

The amended regulation recognises the lower nitrogen excretion rate achieved by dairy farmers who opt to manage crude protein in the concentrates fed to their cows across the year.

• The maximum crude protein content allowed in concentrates fed to cattle aged two years and over at grass between 15^thApril and 30^th September is reduced from 15% to 14% and this requirement now applies to all farmers.
• A 5% reduction in the chemical nitrogen allowance for grassland on higher stocked farms. A new lower chemical nitrogen allowance for extensively stocked livestock farms.

• Mandatory inclusion of clover when reseeding perennial rye grass-based swards now applies to all farmers.
• A provision has been introduced to allow a restriction on the use of unprotected urea in granular form. To facilitate the use of existing stocks that restriction will apply from 15^th  September 2025. Application of urea in liquid form will still be permitted.
• Measures that relate to Derogation farmers are as follows: 
  • Introduction of a provision that will allow the maximum Nitrates Derogation stocking rate to reduce to 220kg N/ha in areas where the EPA (Environment Protection Agency) have identified a need for nitrate reduction measures. For these additional areas, the lower stocking rate limit will apply with effect from December 2025. The Department of Agriculture, Food and the Marine (DAFM) will shortly write to the individual farmers who may be impacted by this change. Farmers not in the areas identified in the EPA map will remain at 250kg N/ha. 
  • For Nitrates Derogation applicants, the maximum stocking rate will be limited to 170kg N/ha for land more than 30km ‘as the crow flies’ from the main farm-holding unless demonstrable evidence is provided to DAFM to show that this land is being farmed at an appropriate higher level.
• The Water Quality Group continue to meet regularly to potential measures for the 6^th Nitrates Action Programme which needs to be presented to the European Commission in Q4 2025 for consideration. There will be a public consultation on the draft programme in Q2/Q3 in 2025. 
• IFA wrote to Minister of State, John C 
• In December 2024, the EPA published Early insights indicator report on Nitrogen concentrations in selected major rivers (January-June 2024). The data suggest that nitrogen concentrations in waters nationally have reduced in the first half of 2024 relative to other years, and that they are at the lowest they have been since 2016. The full indicator report on Water Quality 2024 will be published by the EPA in June 2025, and it is hoped that these reductions in nitrogen concentrations will be reflected in the full report. 

• The Farming for Water EIP, is a €60 million project is a collaboration with Teagasc, Local Authority Waters Programme (LAWPRO) and Dairy Industry Ireland that aims to support approx. 15,000 farmers to bring about improvements in water quality. As of March 2025, over 1,500 farmers had applied to participate in the project. Here is more information on the funded measures.
  • A meeting was held with Regional Executive team on the 16^th December to discuss supporting the project, it was agreed that the Regional Executive team should meet with EIP Farming for Water team. This meeting took place online on 11^thMarch 2025.  
• IFA wrote to the EPA to get an update on the review of the use of sewage sludge on agricultural land, which was to be concluded in Q4 2024. The new expected completion date is Q1 2025. 
• IFA hosted an online briefing for the Environment Committee by the EPA on compliance and enforcement in Urban Waste Water Treatment Plants. In 2024, the EPA completed 218 site inspections, which equates to 40% inspection rate for licences/annum. The focus of inspection is operational performance, Water Framework Directive (WFD) pressures, incidents/complaints, and sampling.
  • If farmers have concerns about non-compliance, they should make a compliant directly to the EPA and Uisce Eireann as soon as possible and provide any information they have, for immediate follow up. For Uisce Éireann, the person needs to log a complaint in relation to a specific wastewater issue by calling their call centre on 1800-278-278 or emailing operations@water.ie. For the EPA, the person must log a complaint at the following link and provide the necessary details.
• The Nature Restoration Regulation came into force in August 2024, under the regulation Ireland is required to submit a draft Nature Restoration Plan (NRP) to the European Commission within 24 months (August 2026). The National Parks and Wildlife Service (NPWS) under the Department of Housing, Local Government and Heritage are the led Department to deliver the plan.
  • IFA is a member of the Independent Advisory Committee (IAC) on Nature Restoration that was established to advise on the developments and the contents of the NRP. The 1st meeting of the IAC was in January 2025, this was an introductory meeting. 
  • IFA is representing COPA (European Farming Organisation) on European Commission expert sub-group on Nature Restoration which will support the European Commission in preparing delegated acts, in developing guidance and in sharing good practices.
• In February IFA made a submission to the public consultation on the uniform format for Member States’ national restoration plans under the Nature Restoration Regulation (see Appendix 3). The key concerns raised in the submission are as follows: 
  • A dedicated fund needs to be established outside of Common Agriculture Policy (CAP) to support implementation of the proposed restoration measures set out in the plan. Without this financial commitment farmers fear they will end up bearing the financial costs of the restoration measures, similar to the experience of farmers in Ireland with designations under Natura 2000. 
  • The implementation of measures should be incentivised, and any loss of earnings and/or devaluation of land fully compensated. 
  • The restoration measures proposed under the NRP must be voluntary for farmers, and their property rights fully respected within the plan. 
  • The plan must not place any additional administrative burden on farmers. 
  • A detailed socio-economic impact assessment must be undertaken to understand the positive and negative impacts of the proposed restoration measures on farmland and farm incomes prior to the plan being approved. 
• In the area of Climate Action within the farming sector, the following activities have taken place:
• IFA participated in a Land Use Review Phase 2, Citizen Engagement Workshop Group (CELUR) – Visioning Workshop on 6th December and meeting on 13^th February in Dublin. The meeting in February concluded the work of WG with the report to be submitted to Government by mid-March 2025. 
• IFA met with Maire Donnolly, Chair of the Climate Change Advisory Council on 29^th January in the Farm Centre to discuss recommendations for agriculture in the CCAC annual report. 
• On 4th March, the Irish Fiscal Advisory Council and the Climate Change Advisory Council published a collaborative reporthighlight the potential cost to the State for not meeting the climate action targets. The report estimates the potential costs for not meeting targets could be between €8 to €26 billion.
  • The report suggests that the Government could look to change incentives in agriculture around measures that could substantially lower emissions in a cost effective, proposed measures breeding, the lifespan of animals and fertiliser type. 
• IFA met online with Uisce Eireann (UE) to discuss the increase the Non-Domestic Tariff (Water Charges) from the 23^rd January 14^th and 28^th February 7^th and 11^th March. The new tariff rates were introduced by the Commission for Regulation of Utilities (CRU) on the 1^st October 2024 for a 12-month period which runs to 30^th September 2025. There will be another round of consultation in 2025, and IFA will reiterate its opposition to the increases. 

	New Water Service Charges 2024
Metered Tariffs	Standing Charge per connection(€/yr)	Volumetric Charge (€/m3)
Band 1 class(<1,000m3)	83.02	2.19
Band 2 class(1,000m3 – 19,999m3)	218.11	1.68
Band 3 class(20,000m3 – 249,999m3)	3,708.61	1.56
Band 4 class(250,000m3 – 2,299,999m3)	41,332.17	1.38
Band 5 class(250,000m3 – 2,299,999m3)	295,967.72	1.27

• .
• IFA wrote to Minister Alan Dillion to request a meeting to discuss concerns with regards proposed extension of the Extended Producer Responsibility (EPR) scheme to include Agricultural tyres. The IFA is seeking the continuation of the derogation for agricultural tyres under S.I. No. 400/2017 – Waste Management (Tyres and Waste Tyres) Regulations 2017.
  • IFA met online with consultants who were employed to undertake independent analysis of the proposed Visible Environmental Management Costs (vEMCs) under extension of the EPR Scheme for tyres. 
• Under the new Water Abstraction law, if your abstraction meets or exceed 2,000m3 in any 24-hour period (licensing threshold) you are required to have a licence to carry out that abstraction. If you presently carry out an abstraction that meets or exceeds this licensing threshold then you must make an application for a licence by the 28^th February 2025, if you have not applied for a licence you should apply for extension immediately. No penalty currently applies but this may change. 
  • If you abstract 25m3/day (25,000 litres) of water or more per day, you must register this abstraction with the EPA. Abstractions already registered with the EPA under the 2018 Regulations are deemed to be registered under the Act
  • Under the law the EPA are required to carry out assessments to determine if an abstraction on the register that is between 25m3/day and 1,999m3/day requires a licence.  The EPA will be in contact with those persons on the register who carry out such an abstraction in due course.
• On the 7^th March the Department of Housing, Local Government and Heritage published the Planning and Development Act 2024 Implementation Plan. The Act will be commenced on a phased basis to facilitate the transition from the arrangements under the current Act to those under the new Act. Some key changes commenced include:
  • A plan led system of planning and development based on an integrated hierarchy of plan-making consisting of (a) National Planning Framework, (b) three regional assembly Regional Spatial and Economic Strategies, (c) thirty-one local authority Development Plans and (d) Area Plans as mandated or required by local authorities. 
  • Development plans will have a 10-year lifespan, with 5 year reviews, rather than the current 6 year lifespan and they be more strategic in nature.
  • The reconstitution of An Bord Pleanála as An Coimisiún Pleanála which will be subject to statutory, mandatory timelines to give confidence and certainty to applicants. The headline time periods for An Coimisiún Pleanála range from 18 weeks for appeals of decisions of planning authorities on smaller-scale development proposals, to 48 weeks for larger-scale Strategic Infrastructure Developments.
  • Reform of planning judicial review, including the introduction of a Scale of Fees and Environmental Legal Cost Financial Assistance Mechanism; improving access to justice whilst regulating excessive legal costs.
• IFA attended Teagasc Sustainability in Agriculture: The Science and Evidence conference on 5^th November in Ashtown, Dublin. 
• IFA attended the Waters of LIFE Stakeholder Advisory Group Meeting on 19^th November in Portlaoise, Co. Laois. 
• IFA was a panellist at Dairy Day organised by Farmers Journal on 21^st November in Pairc Ui Chaoimh Event Centre, Cork.   
• IFA presented at EPRO General Meeting on agricultural plastic on the 21^st November in Dublin. 
• IFA attended the Teagasc Signpost GHG conference and General Assembly on the 21^st November in Clonmel, Tipperary. 
• IFA attended the ASSAP Farming Consultative Group meeting on 25^th November in Castledockrell, Co. Wexford. 
• IFA attended IFFPG Management (3^rd, 10^th and 20^th December and 24^th January) and Board (12^th December and 26^th January) meeting. 
• IFA Environment and Rural Affairs Committee met online on 26^th November to discuss submission to Interim Review of 5^th NAP, had a briefing from the EPA on Water Quality on 16^th December in Johnstown Castle, following by a committee meeting and a committee meeting on the 29^th January   the Farm Centre. 
• IFA met online with NPWS to get an update on the Nature Restoration Law on 13^th December.
• IFA met online with Dr. David Styles, NUIG to discuss emission factors in organic peat soils on 16^th December.   
• IFA attended the EPA Advisory Council meeting on 15^th January in Johnstown Castle, Wexford. 
• IFA attended the NESC Workshop on Sustainable Development on 10^th February in Dublin. 
• IFA attended online workshop organised by UCD Agriculture and Land Use climate communications on 24^th February. 
• IFA was a panellist at the UCD International HOLOS-IE/EU workshop within Environ 2025 on the 10^th March in Dublin. 
• IFA gave a presentation at the Kilkenny Co. Executive on the 14^th January and to the Hill Committee on 12^th February.  

1. Any EU/COPA developments
2. IFA attended Chairmanship WP ENVI online meeting on the 13^th December and 24^th February.  
3. IFA attended the COPA Soil and Biodiversity Taskforce meeting 7^th and 16^th January
4. IFA attended the first meeting of COPA Water Resilience Taskforce meeting on the 24^th February. 
5. IFA made a submission to the public consultation on the uniform format for Member States’ national restoration plans under the Nature Restoration Regulation (see Appendix 3). 

• Upcoming issues
• The first meeting of the Leaders Forum on the Nature Restoration Law will take place on the 25^th March. 
• IFA will continue to work with the Water Quality Group to ensure that farmers concerns are considered as part of potential proposed measures.  
• IFA will attend the COPA WP and CDG on Environment in Brussels on 1^st and 2^nd April. 
• IFA Environment and Rural Affairs Committee will meet on the 17^th April.