Consultation Feedback Form
Project:
Organisation:
Food Wise 2025
Department of Agriculture, Food and the Marine
Question
Do you agree with the approach and methodology
used for the Strategic Environmental
Assessment?
Comments
No. The Geographical Scope of the Strategy is identified as Ireland (including marine
areas). This is incompatible with actions developed for “Improvement of environmental
footprint of the sector”, since that footprint goes beyond the national territory.
The slogan “Local Roots Global Reach” in the promotional video explicitly declares the
potential wider by Food Wise 2025, while the assessment specifically restricts itself to
strictly local issues.
Have all relevant Plans, Programmes and Policies
been identified and considered? If not can you
advise of any gaps?
Has the relevant baseline data been identified for
each objective?
Are you aware of any additional on-going
research or monitoring that should be considered
in terms of the baseline environmental conditions?
Has the baseline information been correctly
interpreted to identify the key challenges and
opportunities arising from the plan?
Baseline ammonia concentrations have been assessed for 2013–2014 (final report in
preparation, Aug 2015) under EPA project 2012-CCRP-MS.8. See also ucd.ie/ammonia
Indicators in Table 2-1 are inadequate to assess ammonia emissions, concentrations and
deposition. Potential indicators and data sources listed are inadequate. Note EPA does not
measure ambient ammonia concentrations. CSO/DAFM/Teagasc proxy data can help
attribute emissions, but do not provide direct assessment of emissions, concentrations or
deposition of ammonia or its derivatives.
There is no national ammonia monitoring network, although the capacity exists to provide
one. Ammonia monitoring in 1999, and 2013–2014 has established a suitable baseline for
ambient ammonia concentration assessment away from point sources. Ongoing monitoring
is required to detect change, assess our performance under the National Emissions Ceiling
Directive, and assess potential for impacts to ecosystems through assessments of critical
loads of nutrient nitrogen, and critical loads of acidity.
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Do the strategic environmental objectives (SEO’s)
cover all relevant areas?
Do you consider that the alternative strategies
outlined are reasonable and have been assessed
correctly?
Do you think that cumulative and trans-boundary
impacts have been assessed fully?
With regard to the SEO to manage air pollution, Yes. The target to “Reduce/Minimise
emissions of atmospheric pollutants from each sector, with particular regard to ammonia
arising from agriculture”, is appropriate. A better target would be to comply with the
National Emissions Ceiling Directive.
Transboundary impacts of ammonia emissions have not been adequately assessed.
Consideration of transboundary impacts has been limited to effects in Northern Ireland.
Transboundary impacts of gaseous emissions have not been considered.
Do you agree with the assessment outcomes and
potential impacts addressed?
No. The potential impacts from ammonia emissions are dismissed, on the grounds of
claimed mitigation. No specific mitigation is identified in Food Wise 2025; the only related
claim is the use of an online nutrient management tool, which is the online version of
nutrient-management software already in use.
Do you agree with the list of mitigation measures
and monitoring proposed? Are there any further
measures you consider should be included?
Many rows in Table D Mitigation are blank. Therefore no mitigation whaterver is identified
in this table for these issues.
No mitigation for ammonia emissions is identified in Table D.
No monitoring for ammonia emissions, ammonia levels, or ammonia deposition to
ecosystems is indicated in Table E. Ammonia monitoring is essential to identify the status
and trends in emissions.
The SEA claims several times that Food Wise 2025 “suggests measures for limiting GHG
emissions and ammonia”, so that no transboundary impact is expected. Actions relating to
ammonia emissions as proposed in Food Wise 2025 are:
Teagasc to develop and rollout a Nutrient Management software tool to enhance
cost-effective use of feed, fertiliser and slurry to minimise nitrogen (nitrate,
ammonia and nitrous oxide) and phosphorus losses.
Agri-food research funding to prioritise research which … develops and assesses
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existing and emerging technologies for reducing ammonia and GHG emissions
and carbon sequestration in Ireland’s soils, biomass and agricultural systems.
Agri-food research funding to prioritise research which … Informs a policy review
to be initiated on the effects of ammonia restrictions on future increases in
livestock numbers and on the demography within the national herd.
These do not provide mitigation of ammonia emissions beyond what is currently done.
Monitoring of ammonia emissions, ammonia levels, and ammonia deposition are warranted
in view of the imminent breach of Ireland’s National Emission Ceiling Directive limit for
ammonia emissions, as expected under Food Harvest 2020 and Food Wise 2025
predictions for growth of animal populations.
Are you aware of any further environmental
information that will help to inform the
environmental assessment findings?
Do you have any other comments you wish to
make on the Food Wise 2025 and/or the related
SEA Environmental Report and Natura Impact
Statement?
“The draft Agri-Food Strategy 2025 suggests measures for limiting GHG emissions and
ammonia. Therefore no consequent transboundary effect is predicted as a result Agri-Food
Strategy 2025.” This is a weak claim; no specific mitigation for ammonia emission is
identified that is not already in use.
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