The Office for Environmental Protection (OEP) published its response to the Department for Agriculture, Environment, and Rural Affairs’ (DAERA) draft ammonia strategy on Friday, in which the watchdog called for Northern Ireland’s plans to be more "coherent" and for the "full evidence base and underlying assumptions" used in its development be published.
Northern Ireland has 394 protected sites, but according to DAERA, last year 100% of special areas of conservation, 100% of special protection areas, and 99.7% of areas of special scientific interest in Northern Ireland had ammonia concentrations greater than 1 µg m3. This is the long-term annual average critical level for lichens and mosses, “and for ecosystems in which they are important”.
The consultation set out a long-term target for 2050 to reduce ammonia emissions “to a point where critical loads of nitrogen deposition and critical levels of ammonia are not being exceeded at designated sites”.
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To support this goal, DAERA set two draft interim targets for 2030. The first was to reduce agricultural ammonia emissions from Northern Ireland by at least 30%, based on the 2020 emissions levels. The second was to reduce ammonia concentrations at all designated sites by at least 40% (using 2020 as the baseline year) or to below critical levels.
The OEP welcomed the first target as “a fair and proportionate contribution to the overall UK target required under the Gothenburg Protocol”, and praised the “significant investment in research that DAERA has made in the development of the strategy”.
However, on the second interim target, the OEP was less warm, saying that it is “inconsistent in its wording in the document, and it is not clear which sites this target will apply to”.
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The watchdog has also called on the department to publish “the full evidence base and underlying assumptions used in the development of the draft ammonia strategy”.
The OEP notes that “while we welcome the significant investment in research, it would be best practice to publish the evidence base underpinning the strategy”.
“Early publication would meet stakeholder expectations, and modern-day expectations of transparency. It is likely to build confidence in the strategy and hopefully reduce the risks. Publication of the evidence base will give confidence that investment will deliver on the intended outcomes of the final ammonia strategy,” it reads.
The watchdog goes on to raise particular concern over the absence of a revised operational protocol for assessing air quality impacts, to guide planning authorities on the impact and assessment of ammonia.
It describes this absence as “extremely concerning”, going on to say it “threatens to undermine the ambition of the final ammonia strategy”.
The OEP also recommends that DAERA sets out a long-term roadmap for achieving its 2050 emissions target, noting that it is currently “not at all clear” how the overarching target will be achieved.
The response continues: “Without any indication of the steps being considered to reach the 2050 target, the draft ammonia strategy is in our view incomplete. Not only that, the absence of outline plans beyond 2030 may well impinge on the perceived credibility of the strategy and the commitment behind it – the commitment to deliver the changes required to improve the environment in Northern Ireland as intended.”
Shortly after the OEP was established in 2021, ENDS uncovered details of the first complaints made to the watchdog, three of which concerned alleged failures to follow environmental impact assessment regulations, and alleged breaches of the Habitats Regulations, in relation to the exceedance of ammonia levels on protected sites.
A DAERA spokesperson said that the responses to the consultation from all respondees are now being considered.
"A long-term implementation plan will be developed following the analysis of responses received during the consultation process, to inform a reworked draft ammonia strategy for an incoming minister and new executive to consider.
“As part of the consultation on the draft strategy, DAERA provided links on its website to a series of online seminars on ammonia with leading experts, held in September 2020. These seminars presented results from DAERA’s comprehensive research programme to inform policy development on ammonia emissions, led by the Agri Food and Biosciences Institute and incorporating the UK Centre for Ecology and Hydrology and Rothamsted Research as partners, and informed by the recommendations of the Expert Working Group on Sustainable Agricultural Land Management in their report, ‘Making Ammonia Visible’.
“Reports presenting the outcomes of ongoing monitoring at eight Special Areas of Conservation were also provided alongside the draft ammonia strategy on the DAERA website. DAERA will give further consideration to publication of the research evidence underpinning the strategy to build confidence in the plan and meet expectations of transparency.”
The article was updated with DAERA's comment