There is no need to put a filter on a cow

By Benoît Lutgen

Benoît Lutgen (EPP, BE) is the AGRI rapporteur on the Industrial Emissions Directive (IED)

30 Nov 2022

BenoitLutgen

On 5 April 2022, the European Commission proposed a revised Industrial Emissions Directive (IED) that would add farms with more than 150 cows to the list of industries whose emissions require regulation.

When the Commission presented its proposal, several agriculture ministers contested furiously. Former French Minister of Agriculture Julien Denormandie even called the text "nonsense" and "the type of text that creates distance between farmers and the Commission" after a meeting of the Agriculture and Fisheries Council on 7 April.

But, even more surprisingly, in the European Parliament's Committee on Agriculture, a unique majority of MEPs from across the political spectrum, including members of the EPP, the Greens, S&D, Renew and the ECR, stood side by side in refusing the text.

The IED is a so-called permitting directive that lays down the conditions under which national governments should grant a permit to industrial installations like power plants, refineries, waste incineration, etc. It requires, among other things, a costly analysis of the impact of pollutant emissions of an installation to be presented before a permit can be granted.

The new rules would extend IED coverage to mining and large-scale battery production but also rearing cattle, an activity that mainly takes place in the open air. Although everyone is well aware of the need to reduce ammonia and methane emissions from cattle, including cattle in the scope of a directive for industry is simply one fausse bonne idée.

First, as mentioned above, rearing cattle is an activity that mainly takes place outdoors, unlike all the chemical activities that are in the scope of the IED. It speaks for itself that you simply cannot put any kind of a filter on a cow's "chimney."

Moreover, the Commission admitted that it has yet to list any mitigating measures in its so-called "best available techniques" list for the cattle sector. This means that the Commission is asking the European Parliament and the Council to blindly add the bovine sector to the list of industrial activities without knowing the financial consequences of the mitigating measures for farmers.

When we asked the Commission for the available techniques during an exchange of views in a meeting of the Committee on Agriculture on 24 October, the non-elected civil servants only came up with the suggestion of methane-mitigating feed additives – a technique that several Member States have already enlisted in the national strategic plans they have prepared as part of the European Union's Common Agricultural Policy.

The Commission's proposal disproportionately affects small and mixed farmers

Secondly, the Commission's proposal disproportionately affects small and mixed farmers, hitting them the hardest. By proposing a very low threshold of 150 cows or its equivalent (in the case of a mixed farmer, 50 cows and 200 pigs), the updated directive would put smaller farmers at a competitive disadvantage compared to industrial farms with more than 5,000 cows, for example. It seems that the Commission neglected the logic of scale economies, which consequently gives real industrial farms a huge competitive advantage.

Moreover, as the cost of a new permit can easily reach more than €40,000, it will logically block family farms from investing in environmental and animal welfare benefits.

In a changing geopolitically context, the EU needs to ask itself which kind of food policy it would like: a more self-sufficient family farm model or a model where food is imported from industrial farms abroad?