Agricultural atmospheric ammonia: identification & assessment of potential impacts

Reactive nitrogen pollution, particularly ammonia (NH3), when above critical limits adversely impacts biodiversity through eutrophication, acidification or direct toxic effect. Though total nitrogen deposition is a primary driver for species community changes and impacts, the concentration of ammonia should also be considered. Both total nitrogen deposition and ambient ammonia concentrations are above levels that can result in harm to biodiversity at many Natura 2000 sites across Europe and in Ireland. Reactive nitrogen is principally composed of both chemically reduced ammonia and ammonium (NH4+), alongside oxides of nitrogen (NOx). While traffic is the primary source of oxides of nitrogen, agriculture accounts for virtually all ammonia emissions in Ireland.


Although there is substantial evidence that reactive nitrogen causes negative impacts on biodiversity, the relationship between exposure to reactive nitrogen (dose) and negative ecological indicators (effect) is not always straightforward. The complexity of understanding dose-effect relationships increases if multiple factors with negative effects occur concurrently (e.g. adverse effects of air quality occurring at the same time as adverse effects of climate change). Additionally, adverse impacts of reactive nitrogen are likely to occur over long periods of time and may not be immediately visible during a site survey. It is recommended that, although indicators of negative effects may be observed during field visits, these indicators should be used alongside other evidence (such as monitored or modelled concentration or deposition, local sources, local knowledge) to build evidence of adverse impacts on a site. Essentially, ecological indicators alone should not be used as evidence of adverse impacts but rather considered as part of a suite of indicators. Survey indicators could include algal proliferation, presence of nitrogen tolerant species, absence of nitrogen sensitive species, presence of pink or decaying Reindeer Lichen (Cladonia portentosa) or of decaying Sphagnum spp.


A guidance document describing a framework for the assessment of impacts of ammonia emissions from intensive agricultural installations has recently been published in the Republic of Ireland by the Environmental Protection Agency (EPA). Similar guidance has also been published in Northern Ireland, England, Scotland and Wales as well as other European Member States on how reactive nitrogen should be assessed in the context of Environmental Impact Assessment (EIA), Appropriate Assessment (AA) and AA screening. Recent court rulings in the Netherlands support the need to implement science-based and defensible approaches to the assessment and management of agricultural emissions of nitrogen to the atmosphere. There have been two broad approaches applied within Europe to the assessment of potential reactive nitrogen and ammonia impacts on Natura 2000 sites, namely the Critical Criteria Approach and the Integrated Approach.


The Critical Criteria Approach prevents the development of new sources that have a significant potential to adversely affect Natura 2000 Sites but allows the development of sources that do not have significant adverse effects. The Critical Criteria Approach is currently adopted by the majority of Member States who have a policy of dealing with such emissions. The Integrated Approach provides a framework for reducing emissions from existing sources to create room for new activities such as infrastructure, housing or intensive agricultural installations. The Integrated Approach was adopted by the Netherlands in 2015. However, because it allowed credits for reductions to be gained prior to the gains being realised, it was deemed illegal by the Dutch Council of State in 2019. As a consequence, modifications to the integrated approach are currently being investigated in the Netherlands. However, the European Commission commended the integrated approach highlighting it as the most appropriate method to deal with the issue of adverse impacts of reactive nitrogen from agriculture.


The assessment of emissions of ammonia from agricultural developments, required for planning or licence consent, is predominantly undertaken using air dispersion modelling techniques. A range of dispersion modelling approaches are available for the assessment of impacts from agricultural development. These dispersion modelling approaches vary in complexity and accuracy with simple approaches generally overestimating impacts to provide a highly conservative indication of potential

impacts and more advanced modelling approaches generally providing a more representative, yet conservative indication of potential impacts. This Irish Wildlife Manual aims to summarise:
– The effects of emissions of ammonia from intensive agricultural sources and its deposition on biodiversity.
– The regulatory requirements for the assessment of these effects and the indicators of adverse effects including physical observations and theoretical limits used in modelling assessment.
– The approach recommended by the Irish EPA and approaches used in various European Countries that are currently used to assess and report on the potential effects of emissions of ammonia from agricultural development.
– A framework for high-level review of dispersion modelling assessment intended for non-expert users of dispersion models that details a non-technical basis to consider whether the critical components of a dispersion modelling study meet the requirements of dispersion modelling guidance issued by the Irish EPA.

There is no single publicly available database in Ireland that quantifies and locates ammonia emitting activities

Emissions from individual projects that are determined to be insignificant in isolation can be approved using a critical criteria approach. The use of the same approach for multiple projects, either concurrently or consecutively can result in baseline creep, where over time the combined impacts of individually insignificant projects result in a significant adverse impact, that may not be identified using a critical criteria approach.

The predominant source of ammonia in Ireland is cattle farming, which is well dispersed throughout the country. Intensive farming of pigs and poultry contributes a far lower proportion of total emissions of ammonia, but these activities are concentrated in a small number of high production areas, where the effects on biodiversity can be significant.

The border counties of Cavan and Monaghan have the highest concentrations of IED licensed and sub-threshold intensive agricultural facilities. Both Cavan and Monaghan also have high densities of cattle (cattle/km²) compared to the average cattle density in Ireland.

Movement of Animal Manures

NTIG to establish a working group to address the gaps in processes governing the protection of waters from the movement of animal manures (Source: NTIG Minutes, March 2021)

Extract from minutes:

Recent intensive pig and poultry license applications have seen many farms doubling in size.

The HSE (who gave presentation on issue at NTIG meeting) is concerned about possible impacts of slurry and other animal manures on drinking water quality.

Tracking and following up on the movement of manures between farms is very challenging.

The EPA licensing process for intensive pig and poultry farms does not regulate the management of slurry that is moved offsite

Potential health implications
• Microbial contamination of ground and surface water
• Nutrient enrichment
• There are 380k private well supplies in Ireland; 180k of these are not registered or tested.
• As part of environmental health regulations, 1418 small private supplies are tested. These are generally associated with small food businesses so are subject to inspections by LAs.
Annually, approximately 6% of these inspections show that the private supply is contaminated.
• WHO documents are available on the implications of nitrate pollution of groundwater, which can be carcinogenic.


Suggested control measures
• Risk rating of any potential measures would be key to ensuring effective outcomes.
LAWPRO: Role and experience of LAs, the EPA and others in the control system for manure, animal by products and digestates
• LAWPRO provided an overview of the LA experience, which has shown that there are potential gaps in control measures.


Discussion
• Tracking and transparency are key issues.
• DAFM has moved to an online tracking system may assist with this.
• Geographic concentration of intensive agriculture can lead to increased potential risk in those areas.
• ACTION: NTIG to establish a working group to look at this issue.

Update:

Farms now submit via DAFM (Record 3 form) and that data is submitted to IPPC licencing

System went online at the end of 2021

Screenshot

Monaghan County Council: Baseline Study Report on the Poultry Sector

Fehily Timoney Consultants

A baseline study quantifying the scale of the poultry industry and identifying environmental impacts of the poultry sector within County Monaghan

Since 2018, significant growth in the sector has been observed. The number of licensed poultry facilities has increased from 76 to 101 and 118 planning applications for the development of sub-licence threshold poultry developments were submitted.

Using AERMOD and ArcGIS to Model Ammonia Emissions from Irish Broiler Houses

Broiler and layer production in Ireland combined account for approximately 2% of Ireland’s national ammonia emissions (EEA, 2015).

Poultry production in Ireland is predominantly in the form of intensive agriculture. Broiler production involves raising chickens in large houses for 35 – 40 days, after which they and the manure that has built up are removed from the house.

Layer birds are housed continuously throughout the year and manure is removed via conveyor belts. As
the farms are located in discrete locations, any atmospheric ammonia produced by poultry manure during production is considered a point source of atmospheric ammonia.

As a point source, the concentration around these houses is more likely to exceed limits designed to protect sensitive habitats and species at a local level, compared to diffuse sources such as cattle housing or land spreading of manure.

PRTR: Intensive livestock production and aquaculture

The PRTR Intensive livestock production and aquaculture sector includes the following activities:

(a) Installations for the intensive rearing of poultry or pigs

(i) With 40 000 places for poultry;

(ii) With 2 000 places for production pigs (over 30 kg);

(iii) With 750 places for sows.

(b) Intensive aquaculture with a production capacity of 1 000 tonnes of fish or shellfish per year.

https://data.gov.ie/dataset/prtr-intensive-livestock-production-and-aquaculture?package_type=dataset

List of all EPA Licensed Poultry Farms

The EPA grants and enforces Industrial Emissions (IE) licenses for specified agricultural activities.

You can find these licenses here:

https://www.epa.ie/our-services/licensing/industrial/integrated-pollution-control-ipc-licensing/who-needs-an-integrated-pollution-control-ipc-licence/

You can:

Browse Applications/Licences by Applicant/Licensee name
Search by Register Number
Search by Applicant/Licensee Name
Search by Facility Type/County/Status

But, you cannot search by poultry, chicken or duck etc as not all poultry farms have these keywords in the name

Here is a simple workaround in Excel of all EPA poultry licenses

Note: The only categories of intensive agricultural activities which fall under EPA control are:

Intensive Agriculture
6.1) The rearing of poultry in installations where the capacity exceeds 40,000 places. ( ) In clause (a) ‘ poultry ’ shall be construed in accordance with Regulation 2(2) of the European Communities (Poultry and Hatching Eggs) Regulations 2010 ( S.I. No. 564 of 2010 ). 
6.2The rearing of pigs in an installation where the capacity exceeds — ( )750 places for sows, or ( )2,000 places for production pigs which are each over 30kg.

All intensive agriculture sites below these capacities would be controlled by the local authorities. 

e.g. fur farms do not fall within the scope of the EPA Act