Irish perspective of the Nitrates Directive and the Rose energy incinerator

Carton Group Ltd
Bracetown Business Park.
Clonee. Co. Meath

Tel : + 353—1—8014048
Mr. Danny Moore,

Re: Irish perspective of the Nitrates Directive and the Rose energy incinerator

Monday, September 13,2010

Dear Danny,

I am writing to you to outline my views on the proposed incinerator proposed by Rose Energy in Glenavy, Northern Ireland.

Carton Group is Irelands’ largest chicken processor, processing 730,000 birds per week, employing 700 people in Shercock, Co. Cavan, with 150 farmer suppliers with a turnover of €1 80m in 2010. It is also one of Irelands’ oldest family companies (established in 1775) currently managed by the eighth generation of the Carton family.

First, there are many viable solutions to the problem of the disposal of chicken litter whether it is centralized incineration, on farm CHP, Pyrolysis, composting, pelleting into a garden fertilizer or as we prefer using as a fertilizer on the fields where wheat is grown that will become 65% of the poultry ration.

Second, I would like to state that we are totally in favour of the implementation of the nitrates directive in January 2011 on the Island of Ireland both North and South. I believe this because it will improve the environment generally and the water in our lakes and rivers.

Third, while there are examples around Europe of power plants burning considerable quantities of chicken litter and meat & bone meal to generate both heat and electrical power, there are always suspicions about longer term environmental effects (Dioxins) and the fact that chemical fertilizers will be used to put back Nitrogen and Phosphates into the soil to grow the wheat and other grains which make up the majority of chicken feed.

Fourth, Northern Ireland & The Irish Republic have known since 1991 of the changes required by the Nitrates Directive (91/676/EEC) and have been given an extra derogation of 4 years, from 2007 to 2011, to introduce measures that would assist farmers to implement it. Remember the other members of Europe (EU15) have implemented the Nitrates Directive in 2007.

In both the North and the South the respective Departments of Agriculture introduced capital grants to help farmers build storage sheds for chicken litter (to store litter during the winter period, October through February, when litter could not be land spread). In the South this scheme was eagerly taken up by farmers and most chicken farmers have this infrastructure in place. My understanding that few NI chicken farmers availed of their scheme.

Fifth, In the south we have built connections between the arable farmers of the North Dublin to South Louth area with chicken farmers of the North-East (Cavan, Monaghan, North Louth and North Meath) as well as the logistics infrastructure so that we can deliver the litter to the wheat fields when the arable farmers need it. While this is a significant cost, a virtuous circle has been created for the benefit of both farming groups and the rural environment.

Sixth, we have worked very closely with our native mushroom industry to supply the composters with chicken litter in the quantities and quality that they require. The Irish mushroom industry is a great success story and an important

commercial outlet turning a waste stream from one industry into a wonderful food product.

My main frustration however with the Rose project is how the competitiveness of our indigenous chicken industry is going to be compromised, by the erection of an incinerator with generous support of the public purse. Irish chicken farmers have to incur litter disposal costs (to mushroom composters or arable farmers), the cost of which is passed on to the processor. Currently, Irish chicken farmers are paid €O.38c per bird to grow chickens while in Northern Ireland this figure is closer to £O.20p. One of the main reasons for this difference is the higher litter disposal cost (which the farmer must pay) where southern chicken farmers are already implementing a cost structure compatible with the Nitrates Directive.

Yours sincerely,



Vincent Carton

Managing Director
Carton Group
Reg N: 63235
VAT Na: IE 8Y48467S
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