The government wants more livestock farms to come under the Industrial Emissions Directive (IED) with a lowering of the threshold to 150 livestock units (LSU) because of the expected environmental gain, emission reduction and contribution to national climate policy. LSU is a size indicator for different types of animals, used to determine how many animals can be kept under a permit.

Impact analysis proposed changes to RIE livestock sector

The research firm Schuttelaar & Partners has carried out an impact analysis on behalf of the Minister of Agriculture, Nature and Food Quality on the effects of the proposed changes to the RIE for the livestock farming sector. The impact analysis endorses the government's position and gives no reason to adjust the provisional position, according to State Secretary Heijnen of Infrastructure and Water Management.

The IED (Directive 2010/75/EU) is the main European instrument to regulate pollutant emissions from industrial plants and large livestock farms. The Industrial Emissions Directive was adopted on 24 November 2010 and based on a European Commission proposal to recast seven previously existing directives (including the IPPC Directive). The IED entered into force on 6 January 2011 and had to be transposed into legislation by Member States by 7 January 2013. Currently in the Netherlands, 2673 livestock farms are covered by the RIE, these farms are registered as IPPC farms. So far, this only applies to poultry and pig farms, with a minimum of 750 sows, 2,000 fattening pigs or 40,000 poultry. The permits of companies covered by the IED must take into account the full environmental performance of the installation. Including, for example, emissions to air, water and soil, waste production, use of raw materials, energy efficiency, noise, accident prevention and site remediation upon closure.

On 5 April 2022, the European Commission proposed revised EU measures to further tackle pollution from large industrial plants and livestock farms. These proposals include the revision of the IED2,3. As a producer of our food, the Dutch agricultural sector faces the task of reducing various emissions. About 10 % of the Netherlands' greenhouse gas emissions come from livestock farming (according to NL model).

Purpose impact assessment

Because the revision of the IED may have an impact on the livestock sector and the relevant authorities in the Netherlands, it is important to assess the consequences of adapting the IED. This should also consider the (level) playing field for livestock farmers in the European Union.

Impact assessment findings

• At a threshold of 150 LSU (livestock units), about 25% of livestock farms in the Netherlands are covered.
• The sector is in favour of a low threshold (150 LSU), as it can contribute to a more level playing field at European level since Dutch policy around ammonia and methane focuses on emission reduction anyway.
• The sector mentions the uncertainty surrounding the elaboration of the exact (emission) requirements for livestock farming in the implementation rules. This also played a role in 2010 for the RIE, which ultimately turned out better than expected. For methane and cattle it is more difficult to estimate what the exact measures (BAT) will be, because this is new in the IED.
• The environmental services have indicated that they foresee problems with knowledge and capacity. These include the increased number of permits that need to be updated. Under the current proposal, there will be a stepped approach to updating permits. The environmental services mention that a minimum requirement will apply to the number of inspections to be carried out, but this provision applies to industry. For livestock farming, no minimum requirement has as yet been included in the RIE.
• Climate policy contribution: The Coalition Agreement sets a more ambitious climate challenge for agriculture. Agriculture in the Netherlands is responsible for 76% of total methane emissions, according to emission records. Currently, although reducing methane emissions from agriculture is encouraged by the government, there is no normative policy. Adding methane and cattle to the RIE introduces this normative policy.

More information and report: https://www.tweedekamer.nl/kamerstukken/brieven_regering/detail?id=2023Z03901&did=2023D09154