Irish farming's 'green' reputation is not supported by evidence, the EPA director Laura Burke has told the Department of Agriculture.
In her hardest-hitting comments to date on the sector’s environmental performance, she said agricultural practices are identified in EPA reports as being one of the main pressures responsible for the decline in water quality nationally.
In a submission on the development of a new agri-food strategy seen by the Farming Independent, Ms Burke said the sector is responsible for approximately one-third of national greenhouse gas emissions, and over 99pc of national ammonia emissions.
"It is recognised that on an individual farm, and farm-type, basis there can be evidence of exemplary and low impact practice,” she said.
“However, taking the sector as a whole, the economic growth in recent years is happening at the expense of the environment as witnessed by the trends in water quality, emissions and biodiversity all going in the wrong direction.”
It is clear from the evidence, she said, that agriculture and other land management practices are key drivers of these negative trends.
"Business as usual will not reverse these trends," she warned.
Addressing Irish agriculture's 'green' reputation “leveraged by Origin Green and other labelling schemes” she said it was clear from an examination of the science that the environmental sustainability of the sector as a whole is “largely not supported by the evidence”.
She added that the case is “weakening” year on year as polluting air emissions increase and water quality further deteriorates.
"In our view, this is a serious reputational risk for the agri-food sector in Ireland,” she said.
"Pending evidence and implementation of effective solutions to ongoing unsustainable air and water emissions, any plans for further intensification/expansion of the dairy herd would be difficult to sustain.”
Responding to the comments, Bord Bia said that through Origin Green, Ireland remains the only country globally with an independently verified national sustainability scheme.
"Since the launch of Origin Green in 2012, Origin Green members have made progress towards the aim of driving sustainable food production,” it said.
"Beef farms that joined Origin Green in 2014 saw an average of 5pc reduction in CO2 per unit of beef produced and dairy farms that joined in 2014 saw an average of 9pc reduction in CO2 per unit of milk produced."
Bord Bia also said that over 2,400 sustainability improvement targets have been set by Origin Green verified companies, with all targets reviewed and verified on an annual basis by international verification specialists Mabbett.
It "challenges the notion that Origin Green serves simply as a marketing or labelling scheme when progress has been achieved by Origin Green members across the supply chain".
Despite this, Bord Bia said it endorses the EPA’s view that "further work needs to be done to accelerate the pace of this change", and accepts the importance of the "continued positive reputation of the Irish agricultural industry".
Also in the submission, Burke said the national agri-food strategy should detail in specific measurable terms how it will address the EU Farm to Fork strategy, which sets targets to "transform the EU's food system", including a 50pc reduction in the use (and risk) of pesticides; a 20pc reduction ("at least") in the use of fertilisers; a 50pc reduction in sales of antimicrobials used for farm animals; and an ambition that 25pc of agricultural land is to be "under organic farming" by 2030.
In areas with known nitrogen pollution, she said it is essential that measures are implemented immediately to halt, and reverse, the continuing increases in nitrogen emissions to water.
"These measures must go beyond improving efficiencies and must be focus[sed on reducing the total emissions through breaking the link between animal numbers, fertiliser use and deteriorating water quality," she said.
Particular emphasis should be placed on developing economically sustainable farm systems for less intensive farms that focus on producing quality food for a premium price, according to Burke.
"Develop and implement a food labelling system for national produce that provides consumers (national and international) with clear purchasing decision support information on carbon intensity (including the transport to market carbon intensity), and sustainability of the product," she said.
Burke also highlighted recent research undertaken by CSO and ESRI (the latter funded by the EPA) that identified within the national taxation and subsidy system a series of reliefs that are environmentally harmful, a number of which occur in the agri-food sector.
"Such market failures need to be identified and removed from the taxation code and subsidy scheme as they are incompatible with sustainability ambitions," she said.
Burke described the farming community as “custodians of our landscape” and said they have a core role in all solutions.
"We need to promote land uses that are sustainable and right for our environment and our people," she said.