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MONINEA BOG IS one of the best remaining examples of an active raised bog in Northern Ireland, brim full of bright lichens and unique and rare sphagnum mosses, as well as an abundance of other flora that rely on good wet conditions to survive.
At least that was the case until recently for the nature site just across the border in Fermanagh, protected under EU law due to its intrinsic value to the European network of raised bog sites, many of which are on the island of Ireland.
In recent years, intensified agricultural practices close to the bog, and ammonia emissions that come with them, have had a devastating impact on it, in particular, a hotspot source – poultry farms.
Studies in the early 2010s found that up to 90% of sphagnum species were “eradicated or degraded” downwind of nearby farms. On a number of trees, lichens were replaced with a thick algal slime – a sign of severe eutrophication.
One shining light is that the site is starting to slowly recover since the closure of some farms in the nearby area and mosses and lichens are starting to establish again.
However, this light is fleeting as, despite clear warning signs to authorities about the ammonia crisis we face on the island of Ireland, there has been an explosion in the number of poultry farms concentrated close to protected nature reserves along the border region.
As part of our FACTORY FARM investigation in collaboration with The Detail and The Guardian, we took a deep dive into regulation of the poultry sector on our island, analysing various planning, enforcement and policy files from local and State authorities.
Our findings reveal that:
This article was developed with the support of Journalismfund.eu. In part one – out yesterday – we revealed that investigations are ongoing in Northern Ireland in relation to the suspected use of falsified poultry litter documents in planning applications.
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Explosion of farms in border region
Irish poultry production hit record levels in 2016, with almost 92 million birds slaughtered in export-approved plants. According to the 2020 Census of Agriculture – carried out every 10 years – the poultry population “has never been as large” as it is today.
While the sector is lauded as a success story on both sides of the border, the rapid growth in farms and bird numbers in recent years has also led to the rise of another problem – the amount of poultry litter produced and the ammonia emissions that come with it.
Exposure to high concentrations in the air can cause burning of the eyes, nose, throat and respiratory tract and can result in blindness, lung damage or death. Even inhalation of lower concentrations can cause coughing and nose and throat irritation, with people with asthma at a particular risk.
Ammonia is also a leading cause for the decline in biodiversity globally, and results in significant loss of plant species, as seen in Monivea Bog, as well as eutrophication of freshwater ecosystems.
According to Jack O’Sullivan, an environmental consultant with four decades of experience, the ammonia produced by farms is “very soluble in water”, forming into ammonium hydroxide taken up into the atmosphere and “rained out of the sky when you get a nice heavy rainfall”.
While not a major issue on grassland habitats, in areas with lots of small lakes and nature sites low in nutrients, such as in the border region, these can become eutrophic, or too rich in nutrients, he said.
Altering our protected sites
“There’s a massive range of protected areas along the border counties that are hugely impacted by ammonia,” according to An Taisce ecologist Elaine McGoff, in particular bogs and heaths. “Ammonia comes wafting over deposits on those habitats and it enriches them so the slower growing, nutrient poor species are out-competed.
“You end up with really horrible slimes on the trees, it kills off all of our sensitive species, it kills off the vegetative species and then it kills off the bees and butterflies and insects that depend on them,” she said. “We’ve completely altered these highly protected habitats,” she added, with the finger of blame firmly pointed at agriculture.
According to the Environmental Protection Agency (EPA), we breached our EU ammonia limits in eight of the past nine years, with agriculture making up 99% of total emissions. Last year, ammonia emissions were estimated to be 12% higher than levels in 1990.
Alison Hough, a barrister and environmental law law lecturer at TUS Midlands, told us that Ireland is set to continue to breach the ceiling until 2030 under current government policy.
Hough, who is currently examining cross-border cooperation in environmental matters, said that Northern Ireland also has “inordinately high levels of ammonia emissions in comparison to the rest of the UK”.
“Government inaction on stocking rates and nitrogen levels on both sides of the border has allowed this situation to escalate out of control, through a combination of inadequate regulation and ineffective enforcement,” she said.
While poultry ammonia emissions pale in comparison to levels in the dairy and beef industries, the farms in the border region are having a significant impact due to their heavy concentration close to protected areas straddling both sides of the border.
This is clearly seen in Monaghan, home to over half of all poultry farms in the Republic. According to the CSO, over 60% of birds in both the egg and meat sectors are now produced in the county.
Border region hotspot
Our analysis of decades of planning applications highlights a rapid growth in the number of new farms and new sheds on existing farms in the past decade. This is also reflected in the findings of a 2021 report from the planning consultancy Fehily Timoney commissioned by Monaghan County Council.
The report provides the first detailed examination of poultry farm density in the county, as well as bird numbers, litter produced and ammonia emissions from the farms. And the numbers are big.
The report estimates that 250,000 tonnes of manure is produced every year, producing 1.6 million kilograms of ammonia – almost 70% of which comes directly from the bird’s housing.
The report points to an “increasing intensification” of the industry – supported by our own analysis of farm planning and licence records – with a capacity on farms for 18.5 million birds in 2021.
There is a clear linear increase in larger, EPA-licensed poultry facilities in Monaghan from 2003, with a spurt in new applications in the past five years. There are also plenty of applications through the planning system for smaller farms up to 40,000 birds with a review of planning data showing 118 applications lodged for farms between 2018 and 2020.
“If the sector is to continue to expand and grow in Monaghan, measures will need to be implemented to mitigate the impacts of ammonia and nitrogen emissions and to ensure sustainable management of poultry manure,” the report stated.
In a statement, Monaghan County Council said it “conducts its planning functions in accordance with its legislative and policy obligations”. As part of this, it said, “relevant cumulative impacts are considered when determining poultry related planning applications”.
This is not the view of An Taisce, a statutory consultee in the planning system that has made hundreds of submissions on planning cases, including on poultry farms in the border region.
“What we’ve seen from the way the poultry industry is managed in the planning system is no different to data centres or dairy expansion. It’s an industry that has very light touch regulation and has an easy ride through the planning system,” according to Ian Lumley, the environmental group’s head of advocacy.
Lumley said that the same criticism applies to the EPA that is in charge of licensing large poultry farms in excess of 40,000 birds.
New EPA rules and impact
Concerns over ammonia emissions in the border area have come under the radar of the EPA more closely in recent years, with nearly 150 licensed farms, each with over 40,000 birds, concentrated in the Cavan and Monaghan region alone.
Following a sharp increase in licence applications in recent years, the EPA commissioned a project in 2021 to model the cumulative impact of ammonia from intensive agricultural facilities at three EU protected nature sites along the border – Slieve Beagh, Kilroosky Lough and Lough Oughter.
The three sites are unique in their own right. Lough Oughter in Cavan is recognised as the best inland example of a flooded drumlin landscape, while Kilroosky has rare marl lakes and Slieve Beagh is a blanket bog habitat that acts as a stronghold for the under threat, and iconic, Hen Harrier.
The EPA report found that critical ammonia levels were exceeded at all three sites as a result of the cumulative impact of emissions from intensive agricultural facilities surrounding the protected areas.
Poultry sources were identified as the biggest ammonia contributor in Slieve Beagh and Kilroosky, and were identified as the second biggest contributor for Lough Oughter.
On the back of these findings, the EPA launched new guidelines last summer for farms close to the protected areas, informing poultry farmers that it would not issue licences for new farms until overall ammonia levels reduces, while existing farms would need to invest in technologies to control or reduce ammonia levels before any expansion applications would be entertained.
Gaps in data in Ireland
While rules are now being tightened up, environmental groups and air quality experts have raised concern for years about delayed action to measure the scale of ammonia emissions in the border area where there is already a concentration of farms.
An analysis of EPA licence records shows it is only in recent years that it started to use ammonia modelling to assess the potential emissions linked to this activity.
According to research by Dr Dáithí Kelleghan, an ammonia modelling expert from UCD’s School of Biosystems and Food Engineering, there is still a scarcity of data available to the EPA and other authorities – despite years of warning.
A 2019 paper by Dr Kelleghan found that the State “urgently requires a detailed atmospheric ammonia concentration model”, without which “it is extremely difficult to identify [protected nature] sites potentially at risk from impacts arising from atmospheric ammonia”.
Dr Kelleghan’s warning was not heeded, according to a 2021 report he co-authored which found that, “despite previous recommendations, there is no continuous [ammonia] monitoring network in Ireland”.
The EPA is now starting to act on these concerns. In an email from the EPA’s licensing team to the Agri-Food and Biosciences Institute in November 2021, the agency said it had set up ammonia monitors near Clones in Monaghan and was awaiting data analysis.
It said that there are also plans for additional monitoring close to one additional site in Monaghan as part of a national ecosystems monitoring network that is now legally required under the EU National Emissions Ceilings Directive to monitor for the negative effects of air pollution across ecosystems.
According to records released by Monaghan County Council, it has also been working with a cross-border bog conservation project since June 2020 to monitor air quality at seven locations within Slieve Beagh – four in Northern Ireland and three in the South.
Even if authorities here are now starting to tighten up on rules for farms near protected areas, there are still significant impacts just across the border.
Transboundary impacts
Working with our investigative partners The Detail and The Guardian we examined similar issues in the North, with protected areas inundated with ammonia from poultry and other agricultural sources such as intensive cattle and beef production.
Like Ireland, the UK consistently breached its ammonia limits while in the EU, with Northern Ireland responsible for an estimated 12% of emissions, despite only having 3% of the UK population and 6% of its land area. Today, it is the only part of the UK where ammonia levels are not decreasing.
A stark presentation to the Council for Nature Conservation back in January 2018 by Professor Sue Christie – who sat on the ammonia expert working group - laid out the impact of ammonia on sensitive habitats that were the “‘canaries’ warning of growing pollution”.
Unlike in the south, there is a strong monitoring network already established in Northern Ireland to measure the impact on protected areas. And the results are not good.
According to the Agri-Food and Biosciences Institute, the majority of 250 protected nature sites sensitive to ammonia are “experiencing ammonia concentrations and nitrogen deposition above the critical levels… at which damage to plants may occur”.
Yet, despite these findings, planning files from local authorities in Northern Ireland show that farms continue to receive permission even where ammonia levels at nearby protected areas are already well above their critical levels.
Permissions granted in the North
The Department of Agriculture, Environment and Rural Affairs (DAERA) plays a key role in this areas as it has policy responsibility in relation to ammonia impacts on the environment.
The Northern Ireland Environment Agency (NIEA), which sits under the Department, also acts as a statutory consultee in the planning system and has a strong influence over the level of environmental assessment required in each planning case.
In the early 2010s, it adopted a policy whereby any proposed farm estimated to account for more than 1% of the critical ammonia level of any protected areas within a 7.5km radius where levels already exceeded the safe threshold would be deemed to have the potential to cause a significant impact on the site.
In such a case, NIEA would require more in-depth air quality and environmental assessment. However, where the individual farm is found to contribute less than 1% of the critical load of ammonia, the need for further assessment is screened out.
In the majority of hundreds of cases analysed by our team, authorities accept the position outlined in air quality assessments that the impact of the farm on its own is less than 1% and too low to have any significant impact alone.
Environmental groups in the North, however, are concerned there are a lack of cumulative impact assessments being carried out, especially as ammonia levels at numerous protected areas are already dangerously above critical levels.
Under DAERA/NIEA protocols, farms should come under heavier environmental scrutiny if, in combination with other nearby farms, the farms may produce more than 10% of the critical ammonia level on designated sites within the 7.5km radius.
If this 10% threshold is met, more detailed air quality modelling and environmental assessment is required. If it is found, after detailed modelling, that the combined ammonia emissions do indeed contribute more than 10%, the application should be recommended for refusal.
There is a significant caveat, however, as cumulative assessment is only required where a proposed farm is estimated to individually contribute to 1% or more of the ammonia levels. Therefore, as we found in the majority of cases – where the air quality reports find individual farms contribute less than 1% – no cumulative assessments are carried out.
Tension between policy and science
It is not just environmental groups who have raised concern with this policy. According to NIEA minutes from an April 2016 meeting, concerns over the threshold limits were raised by the agency itself. The minutes state that the 10% threshold “is the result of a policy and has not been determined scientifically”.
A 2018 European Court of Justice (ECJ) decision concerning ammonia and nitrogen levels in the Netherlands also caused alarm with the 1% threshold below which DAERA and NIEA policy states farms can be screened out for further environmental assessment.
In this case, the ECJ found that any additional ammonia contribution to protected areas already exceeding their critical levels could be considered as having the potential to cause a significant negative effect to the site’s integrity.
This means that, if a site is already impacted in the eyes of the EU, any additional contribution from an individual farm, no matter how minute, could be considered significant enough under EU law to require further assessment in the planning system.
Following the ECJ decision, Shared Environmental Services (SES), a body that supports local authorities with environmental assessments, outlined new guidance in July 2019 that would limit the ammonia contribution at which farm applications require further assessment to 0.1% – 10 times lower than DEARA/NIEA policy.
Giving evidence to the Stormont Agricultural Committee in early 2021, Paul Duffy, the head of planning in Mid and East Antrim council with responsibility for SES, said that the new guidance was “influenced” by the ECJ decision.
The new guidance was shared with planning authorities in August 2019, but within a few months, the Ulster Farmers Union (UFU) – the largest farming union in the North - launched a legal challenge, arguing that the proposed changes made it virtually impossible for farms to meet thresholds.
The guidelines were subsequently withdrawn on the understanding that DAERA would publish a consultation on an ammonia action plan within “a matter of weeks”, according to SES’s Duffy. More than two years later and the new guidelines are still pending.
In a statement, the UFU said that they launched the legal challenge as the threshold changes were proposed “without any warning or consultation” and that it is waiting on the new ammonia strategy “needed to address the ammonia issue and to provide clarity on the ammonia operational protocol for relevant agricultural planning applications”.
‘Significant uncertainty’
The Northern Ireland Audit Office (NIAO) picked up on this in a review of planning issues released this February, recommending that relevant authorities “seek urgent clarification from DAERA on the appropriateness of ammonia thresholds in making planning decisions”.
“The lack of clear environmental and ammonia guidance from DAERA creates significant uncertainty for planning authorities, applicants and other stakeholders in the planning system,” the report states.
The Department for Infrastructure, responsible for regional planning matters, also flagged its concern to us, telling our team that DAERA’s input on ammonia emissions in planning cases “relies on what is acknowledged to be an outdated operational protocol on ammonia which does not reflect up to date scientific data and recent case law”.
DAERA said that it is currently considering the latest version of the draft ammonia strategy that contains a revised protocol for the assessment of air pollution and “includes consideration of the thresholds used”. There is no specific date for publication at present.
Law expert Alison Hough said there is a lot of ground to make up on both sides of the border to address the ammonia issue as there is a “systemic failure” by authorities to fulfil obligations under the Espoo Convention.
The Convention sets out obligations to notify and consult on major projects under consideration likely to have a significant environmental impact across state boundaries.
“There appears to be no appetite for enforcement in relation to these important international law obligations,” she said. “Unless coherent and coordinated action is taken between the two jurisdictions, environmental harms from ammonia will continue.”
According to Elaine McGoff, An Taisce’s ecologist, until authorities take a more serious look at the problem, there will remain a “massive range of protected areas along the border counties hugely impacted by ammonia.
“We should be looking at how far the ammonia goes and that’s not happening. Our most precious species and habitats have just been ruined by this – and nobody seems to be paying any attention.”
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This investigation was written by Niall Sargent of Noteworthy. It was proposed and co-funded by you, our readers. This article was developed with the support of Journalismfund.eu as part of a cross-border project with Rory Winters, Luke Butterly and Tommy Greene for The Detail and Ella McSweeney for The Guardian.
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