Dr. Eimear Cotter:

I thank committee for the invitation to appear before it today. The Environmental Protection Agency’s mission is to protect and improve the environment as a valuable asset for the people of Ireland and to protect against the harmful effects of radiation and pollution. The EPA has a wide range of responsibilities as environmental regulator, knowledge provider and advocate. Specifically related to water quality, the EPA’s responsibilities include: co-ordinating and implementing the national monitoring programme to assess and report on water quality; assessing the impact of human activities and pressures on the status of water; and providing advice and assisting in the establishment of environmental objectives, programmes of measures and river basin management plans.

The nitrates directive is implemented in Ireland via the good agricultural practice regulations. Under these regulations, the EPA’s statutory functions relate to reporting to the European Commission on water quality in the context of the implementation of the directive. We provide the Department of Agriculture, Food and the Marine with an annual and independent assessment of water quality in Ireland as part of its annual derogation report. Every four years, the EPA compiles an assessment on the implementation of the nitrates directive. The EPA is a member of the nitrates expert committee, which is co-chaired by representatives of the Department of Agriculture, Food and the Marine and the Department of Housing, Local Government and Heritage.

Water quality in Ireland is not as good as it should be. Our rivers, lakes, estuaries and groundwaters continue to be under pressure from human activities. Just over half of surface waters are in a satisfactory condition, which means that a large number are not in good ecological health. An overarching message in the EPA’s State of the Environment report, published at the end of 2020, is that the water environment needs to be improved and water pollution must be tackled locally at a water catchment level. The evidence shows that agriculture is the most significant pressure on water quality. The most widespread problem is excess nutrients from animals and fertilisers which have resulted in elevated levels of nitrogen and phosphorus in our waters.

Nutrient levels impact the ability of these waters to sustain healthy ecosystems and cause nuisance algal blooms. High nitrogen levels in drinking water that are above the drinking water standard can pose a risk to human health. In particular, nitrogen pollution is causing a pressure in parts of the south, south east and east of the country. A combination of freely draining soils and relatively intensive farming means that the risk of nitrate leaching is high. Rivers such as the Bandon, Lee, Blackwater, Suir, Nore, Barrow and Slaney have high nitrogen levels with significant implications for the marine environments they flow into.

On other agriculture impacts, pollution from phosphorus run-off, causes a pressure around the country on land where the soils are poorly draining. There are also problems arising from excess sediment from run-off and stream bank erosion, drainage impacting on physical habitat condition, as well as pesticides, herbicides and other chemicals in waters. Overall, the message is that protecting water quality is an issue for all farmers, not just those that have the largest or more intensive farms.

The nitrates action programme, NAP, is an important implementation mechanism to drive improvements in water quality and to meet our water framework directive objectives. However, the evidence shows that the fourth NAP has not protected water quality from nutrient pollution from agriculture. The EPA supports the range and breadth of proposed measures in the fifth and next NAP which, if implemented as proposed, will strengthen the protection of the environment.

A one-size-fits-all approach will not be adequate to achieve the outcomes that we need. Therefore, measures must be targeted to achieve water quality objectives. They need to be targeted and specific to the soils, activities and risks on the farm. The EPA has developed maps, called pollution impact potential maps, that show the highest risk areas for losing phosphorus and nitrogen in the landscape. We have also recently published an assessment of the amount of nitrogen reduction needed in the key catchments of concern along the south and south east. These tools can help policymakers, farmers and their advisors to target actions to reduce nutrient losses from farms.

Measures in the nitrates action programme must be consistent and aligned across agricultural and other environmental policy to achieve multiple environmental benefits. The EPA welcomes the acknowledgement in the consultation document that better cross-policy integration is needed. We also welcome the inclusion of measures for ammonia losses and greenhouse gas emissions as a means of joining up policy. It is clear from the consultation to date that there are issues with achieving compliance with the European Union (Good Agricultural Practice for Protection of Waters) Regulations. Securing compliance with all existing and new regulations needs to be given priority, using the full suite of tools from support and advice, incentives and a strengthened enforcement and inspection regime.

In summary, agriculture is the most significant pressure impacting on water quality. Trends are going in the wrong direction. A reduction in nutrient emissions to water is essential to achieve improvements in water quality and protect our coastal waters. The fifth nitrates action programme is an opportunity to reduce pollution from nutrients, which will also bring multiple benefits for health, climate, air quality and biodiversity. Targeted, consistent and substantial measures are needed as a matter of urgency, using the full suite of tools from advice, incentives and a strengthened enforcement and inspection regime to support compliance. The EPA is committed to working constructively and collaboratively with relevant Departments and agencies to provide the evidence base for assessing water quality and the wider environment, as well as assisting in developing plans and programmes that will protect and restore Ireland’s natural environment.