1
Economic analysis of ammonia regulation in Germany (Schleswig-
Holstein) in relation to the Habitat Directive
Final report
21 November 2017
Uwe Latacz-Lohmann
Department of Agricultural Economics
University of Kiel
Germany
2
Table of contents
1. Introduction 3
2. Agriculture and Natura 2000 areas in Schleswig-Holstein 5
2.1. Agricultural production 6
2.2. Natura 2000 areas, regional livestock densities and nitrogen deposition 13
2.3. Case study farms 16
3. The legal framework and administrative procedures for regulating ammonia emissions
from livestock holdings in Germany 18
3.1. TA Luft (Technical Instructions on Air Quality Control) 18
3.2. Umweltverträglichkeitsprüfungsgesetz (Environmental Impact Assessment Act) 21
3.3. FFH compatibility assessment 22
3.4. Filtererlass (Filter Decree of the State of Schleswig-Holstein) 24
4. Ammonia emissions abatement on livestock farms 25
4.1. System-integrated measures 25
4.2. End-of-pipe measures 30
4.3. Measures for reducing exposure to critical ammonia concentrations 33
4.4. Best available technology 34
5. Assessing the economic consequences of FFH-specific ammonia regulation
in the typical farms 37
5.1. Investment in a pig fattening installation with 2,500 fattening places 37
5.1.1. Establishing the baseline 37
5.1.2. The cost of general ammonia abatement requirements irrespective
of proximity to an FFH site 39
5.1.3 The cost of FFH-specific ammonia regulation in the 400 m distance scenario 41
5.1.4. The cost of FFH-specific ammonia regulation in the 2000 m distance scenario 44
5.1.5. Summary of results for the pig farm extension 45
5.2. Investment in a broiler fattening installation with 40,000 places 47
5.2.1. Establishing the baseline 47
5.2.2 The cost of FFH-specific ammonia regulation in the 400 m distance scenario 47
5.2.3 The cost of FFH-specific ammonia regulation in the 2000 m distance scenario 49
5.2.4. Summary of results for the poultry farm extension 50
5.3. Investment in a cowshed extension for 120 additional cows 52
5.3.1. Establishing the baseline 52
5.3.2 The cost of FFH-specific ammonia regulation in the 400 m distance scenario 52
5.3.3 The cost of FFH-specific ammonia regulation in the 2000 m distance scenario 53
5.3.4 Summary of results for the cowshed extension 54
6. Conclusions 56
References 58
Appendices 60
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1. Introduction
The objective of the project is to assess the economic consequences of environmental regulation
relating to ammonia emissions from livestock holdings in the vicinity of nitrogen-sensitive areas
designated under the EU’s Habitat Directive. Ammonia emitted by animal housing facilities can cause
damage to nitrogen-sensitive plants in the surrounding of animal houses if its concentration exceeds
critical limits.
The Habitat Directive requires Member States to implement the necessary measures to prevent
deterioration of the status of the designated areas. In Germany, areas with nitrogen-sensitive
vegetation are designated as so-called FFH (Flora Fauna Habitat) areas in which certain constraints
are imposed on farming activities. These constraints are laid down in the management plans for
individual FFH areas and can vary with the type of habitat concerned. Not all protected FFH habitats
have nitrate-sensitive vegetation. The most relevant nitrate-sensitive vegetation types are peat bogs,
heathers and forests, especially bog forests. Management prescriptions in FFH areas can relate to
both land use (e.g. requirement to maintain permanent pasture, set mowing dates, ban on mineral
and/or organic fertilizers as well as pesticides) and animal husbandry (e.g. maximum stocking rates,
minimum distances from protected areas, specific requirements for ammonia emission reduction). In
Germany, the regional governments (e.g. that of Schleswig-Holstein) are in charge of implementing
and enforcing environmental policies in FFH areas. In general, governments have chosen a mix of
carrot and stick policies. The former rely on voluntary participation of farmers in agri-environmental
schemes and pay willing farmers for adopting tailor-made conservation practices on their land. The
stick policies, by contrast, come in the form of statutory regulation and require farmers to implement
certain conservation or mitigation measures at their own cost.
The focus of this report is on statutory regulation to mitigate the negative impact of ammonia
emissions from livestock holdings in the vicinity of FFH areas. In Germany, agriculture accounts for
approximately 95% of national ammonia emissions (UBA, 2016). According to the National Emissions
Inventory for Germany, 52% of the overall ammonia emissions are from cattle farming, 20% from pig
farming, 9% from poultry and 15% mineral fertilizer application (Deutscher Bundestag, 2016, p. 13).
At the national level, the NEC (National Emissions Ceiling) Directive requires Germany to reduce
ammonia emissions by 29% by 2030 relative to the base year of 2005. This is significantly above the
EU average reduction commitment of 18%. However, between 2005 and 2015 Germany’s ammonia
increased by 12% (from 678 to 759 kilotons per year), and the target for 2010 of 550 kilotons was
missed by 131 kilotons.1 This means that German agriculture will have to achieve substantial
emission reductions irrespective of specific requirements near Natura 2000 areas in order to achieve
the 2020 target of 440 kilotons per year. This effort is partly reflected in Filter Decrees issued by
some federal states, including Schleswig-Holstein, requiring new pig housing installations to be
equipped with exhaust air cleaning. Given the outcomes of the latest general elections (September
2017), with the Green Party likely to play a significant role in the federal government, agriculture is
set to face a significant tightening of environmental regulation relating (not only) to ammonia
emissions.
1 Source: Umweltbundesamt (2017): Ammoniak-Emissionen. https://www.umweltbundesamt.de/daten/luftbelastung/luftschadstoff-emissionen-in-deutschland/ammoniak-emissionen#textpart-1
https://www.umweltbundesamt.de/daten/luftbelastung/luftschadstoff-emissionen-in-deutschland/ammoniak-emissionen#textpart-1https://www.umweltbundesamt.de/daten/luftbelastung/luftschadstoff-emissionen-in-deutschland/ammoniak-emissionen#textpart-1
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Currently, there exists a complex legal framework regulating emissions from livestock installations in
general. In addition, there are specific regulations for livestock holdings in critical neighbourhoods
such as near residential areas (where odour and particulate matter emissions are the main problem)
or FFH areas (with a focus on nitrogen deposition). In order to assess the economic consequences of
ammonia regulation at the farm level it is important to understand which legal regulations apply in
each particular case. There are no one-size-fits-all abatement measures that livestock farms in or
near FFH areas have to implement. Rather, the abatement measures to be adopted are highly case-
specific and can range from choice of location and size of the livestock installation through choice of
the feeding system to technical abatement measures such as flue gas scrubbers. Besides general
standards of good practice which each livestock installation must comply with, the FFH-related
ammonia regulation generally comes in the form of performance standards, i.e. critical loads of
nitrogen deposition in the target area (FFH area) which must not be exceeded. It is then at the
discretion of the farmer/investor to choose the mix of appropriate abatement measures to ensure
that the prospective total nitrogen deposition stays below the critical load. This must be proven by
means of atmospheric nitrogen dispersion modelling conducted by relevant experts (e.g. private
consultants or the chambers of agriculture).
The remainder of this report is structured as follows. Chapter 2 provides some descriptive statistics
of agriculture in Schleswig-Holstein, including a map of the geographical location of designated FFH
areas overlain by a map of regional livestock densities. This will highlight the spatial dimension of
critical neighbourhoods in Schleswig-Holstein. Chapter 2 also presents three livestock farms typical of
Schleswig-Holstein: a typical dairy farm with 120 cows, a typical example of a large pig farm with
2,500 fattening places and a typical poultry farm with 40,000 broiler fattening places. Chapter 3 sets
out the legal framework for regulating emissions from livestock installations in general and the
specific regulations applying to livestock holdings in the vicinity of FFH areas. Chapter 4 gives an
overview of established and novel ammonia emission abatement measures for dairy, pig and poultry
holdings. It will provide a brief overview of general abatement measures (good practice) that apply to
all livestock holdings and specific measures which are typically used in livestock farms close to FFH
areas. We will consider both the effectiveness (% emission reduction) and the costs (fixed and
variable costs) of the specific abatement measures. Section 5 considers the farm-level consequences
of ammonia regulation in the three typical farms. We assume that these farms consider doubling the
size of their livestock operations at their current production site (i.e. no relocation to avoid critical
neighbourhoods). We will carry out net present value (NPV) calculations for each of these livestock
housing investments in a total of four scenarios: two distances (400 m and 2000 m) from a nitrogen-
sensitive FFH area and two initial levels of nitrogen deposition (depending on whether or not the
Critical Load has been exceeded prior to the enlargement). In each scenario, the farmer/investor will
have to implement different ammonia abatement measures which will affect the profitability (NPV)
of the investments. The NPV of the investments located at a reference site in large distance from FFH
areas serves as a benchmark to assess the financial consequences of FFH-specific ammonia
regulation. Chapter 6 concludes.
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2. Agriculture and Natura 2000 areas in Schleswig-Holstein
Schleswig-Holstein’s natural endowment (mild climate, good soils) provides excellent conditions for
productive agriculture. Schleswig-Holstein can be roughly divided into eastern, central, and western
regions. The rolling eastern countryside is rich in lakes. The loamy soil in this area is responsible for
one of the best wheat harvests in Germany. In the middle of the state lie the uplands, an old moraine
area. The soil is sandy and quite poor on average in this area. The uplands are the center of milk
production in Schleswig-Holstein. The western region consists of flat, marshy, treeless land. It is
known for its high productivity in wheat and cabbage growing. West of the marshes are shallows and
flats that are exposed to the tides. Some tidal flats and marshes have been reclaimed, planted with
grass, and used for livestock grazing. Much of the western coast lies within a protected area, which
limits its development. Climatically, Schleswig-Holstein lies in an area affected by the Gulf Stream,
which gives it mild winters and temperate summers. High humidity and rainfall (a yearly average of
about 760 mm) make for strong plant growth and high yields.
Intensive agriculture has led to a number of severe environmental problems, most notably a
substantial decline in water quality in both groundwater and surface water bodies. The nitrogen
surplus still exceeds, on average, the level of 50 kg N/ha permitted by national legislation
(Düngeverordnung) as of 2018 (see Figure 2.1). At the same time, and following a general trend,
Schleswig-Holstein has faced a significant decline in biodiversity in the open countryside.
Figure 2.1: Average mineral nitrogen application (N-Mineraldüngung) and nitrogen balance surplus
(Überschuss der N-Flächenbilanz) per ha of Utilizable Agricultural Area for the years 2003 to 2011
(kg N/ha)
Source: Taube et al. (2015)
This chapter presents some descriptive data on the Schleswig-Holstein farming sector, assesses the
extent of critical neighbourhoods between intensive livestock husbandry and Natura 2000 areas and
finally describes the three case study farms which will serve to analyse the cost of ammonia
regulation in the vicinity of Natura 2000 areas.
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2.1. Agricultural production
Table 2.1 provides a broad overview of the farming sector in Schleswig-Holstein (SH) in terms of farm
numbers, production capacities, land use and structure of the livestock sector. The number of
agricultural holdings has fallen by 10% between 2010 and 2016 and currently stands at around
13,000 farms of which approximately 4,300 are part-time holdings (with less than 50% of total
household income from farming). The economic importance of Schleswig-Holstein’s agriculture
(measured by its share of Gross Value Added) has steadily declined over time and currently stands at
approximately 1% of GNP (German average = 0.7%). The SH farming sector employs 2.5% of the
region’s workforce. The average for Germany is 1.5%. These figures underline the relative
importance of agriculture in the northernmost Bundesland. At the same time, they show that the
value added (and thus the income) per person employed in agriculture are lower than in the rest of
the economy.
The relative importance of agriculture also becomes evident when considering the use of the land
area in SH and Germany as a whole (Figure 2.2). While agriculture accounts for 70 % of land use in
SH, the corresponding figure for Germany is only 52%. The share of forests is significantly lower in SH
(11%) than in Germany as a whole (31%).
One third of SH’s Utilizable Agricultural Area (UAA) is in permanent pasture (Figure 2.3). This share
has been in decline over time. This trend has been broken by the launch of the
Grünlanderhaltungsverordnung in 2013 by the regional government – a piece of legislation limiting
the conversion of permanent pasture to arable land.
Figure 2.2: Use of the land area in Schleswig-Holstein vis-à-vis Germany as a whole 2015
Data source: GENESIS-online database: https://www-genesis.destatis.de/genesis/online
https://www-genesis.destatis.de/genesis/online
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Table 2.1: Descriptive statistics of the farming sector in Schleswig-Holstein
2010 2016 Change
2010 = 100
Number of farm holdings (total) 14.123 12.716 90
of which part-time farms 4.614 4.270 93
Utilisable agricultural area (UAA) (total) in ha 995.637 990.403 99
Arable land (ha) 674.283 655.803 97
Permanent crops (Dauerkulturen) (ha) 6.670 6.598 99
Permanent pasture (ha) 313.892 327.805 104
Cereals (food and feed) (ha) 292.192 303.721 104
Maize (ha) 175.669 165.217 94
Cereals for silage (ha) 138 848 614
Arable grass (feed) (ha) 48.562 33.620 69
Pulses (feed) (ha) 13.942 7.492 54
Sugar beet (ha) 7.491 7.061 94
Potatoes (ha) 5.458 5.418 99
Oilseed rape (ha) 111.890 92.817 83
Pulses (food) (ha) 1.616 4.217 261
Fruit and vegetables (ha) 7.758 7.879 102
Set-aside/fallow (ha) 6.945 9.133 132
Livestock (total) in LU 1.068.516 1.015.024 95
Cattle (number of animals) 1.137.172 1.095.984 96
Dairy cows (number of animals) 364.240 396.358 109
Heifers 366.631 379.502 104
Pigs (total) (number of animals) 1.620.161 1.461.628 90
Piglets (number of animals) 397.319 433.629 109
finishers (number of animals) 1.106.486 933.893 84
sows (number of animals) 116.356 94.106 81
Sheep (number of animals) 281.728 205.685 73
Chicken (total) (number of animals) 2.948.936 3.759.219 127
Laying hens (number of animals) 1.158.679 1.438.142 124
Broilers (number of animals) 1.678.514 2.247.068 134
Data sources: Landwirtschaftliche Betriebe mit Anbau von ausgewählten Ackerkulturen 2010.xlsx
Landwirtschaftliche Betriebe mit Anbau von ausgewählten Ackerkulturen 2016.xlsx
Viehhaltung der Betriebe 2010.xlsx Viehhaltung der Betriebe 2016.xlsx Rechtsformen und Erwerbscharakter 2010.xlsx Rechtsformen und Erwerbscharakter 2016.xlsx
file:///C:/Users/suapm106/AppData/Local/Microsoft/Windows/Temporary%20Internet%20Files/Content.Outlook/2MHMIT9K/Landwirtschaftliche%20Betriebe%20mit%20Anbau%20von%20ausgewählten%20Ackerkulturen%202010.xlsxfile:///C:/Users/suapm106/AppData/Local/Microsoft/Windows/Temporary%20Internet%20Files/Content.Outlook/2MHMIT9K/Landwirtschaftliche%20Betriebe%20mit%20Anbau%20von%20ausgewählten%20Ackerkulturen%202016.xlsxfile:///C:/Users/suapm106/AppData/Local/Microsoft/Windows/Temporary%20Internet%20Files/Content.Outlook/2MHMIT9K/Viehhaltung%20der%20Betriebe%202010.xlsxfile:///C:/Users/suapm106/AppData/Local/Microsoft/Windows/Temporary%20Internet%20Files/Content.Outlook/2MHMIT9K/Viehhaltung%20der%20Betriebe%202016.xlsxfile:///C:/Users/suapm106/AppData/Local/Microsoft/Windows/Temporary%20Internet%20Files/Content.Outlook/2MHMIT9K/Rechtsformen%20und%20Erwerbscharakter%202010.xlsxfile:///C:/Users/suapm106/AppData/Local/Microsoft/Windows/Temporary%20Internet%20Files/Content.Outlook/2MHMIT9K/Rechtsformen%20und%20Erwerbscharakter%202016.xlsx
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Figure 2.3: Use of the Utilisable Agricultural Area (UAA) in Schleswig-Holstein 2015
Data source:
http://www.umweltdaten.landsh.de/agrar/bericht/ar_tab_anz.php?ar_tab_zr_spalten.php?nseite=5
7&ntabnr=1||ar_tab_zr_spalten.php?nseite=57&ntabnr=3||ar_tab_zr_spalten.php?nseite=57&ntab
nr=2&Ref=GSB
The three most important cash crops in SH are wheat (20% of UAA), oilseed rape (9% of UAA) and
barley (6% of UAA). All other cash crops, including sugar beet, have very small shares. The high share
of forage crops (24% of UAA) can be attributed to the importance of dairy farming in the central part
of SH.
The SH countryside is characterized by a relatively high share of structural elements such as lakes,
ponds, hedgerows, solitary trees, etc. Most of these elements can be counted as Ecological Focus
Area under the Common Agricultural Policy. This may explain the relatively small share of set-aside
(1%).
Figure 2.4 highlights the importance of dairy farming in SH. Forage farms (dairy, cattle raising, cattle
fattening, small ruminants) account for 60% of all farm holdings and 57% of land use. Specialized
arable farms are mainly located in the eastern part of SH on the loamy soils along the Baltic Sea.
These account for 23% of all holdings and 29% of land use. Specialized pig and poultry farms
(finishing) have a share of 4% of the farm holdings and 5% of agricultural land use.
http://www.umweltdaten.landsh.de/agrar/bericht/ar_tab_anz.php?ar_tab_zr_spalten.php?nseite=57&ntabnr=1||ar_tab_zr_spalten.php?nseite=57&ntabnr=3||ar_tab_zr_spalten.php?nseite=57&ntabnr=2&Ref=GSBhttp://www.umweltdaten.landsh.de/agrar/bericht/ar_tab_anz.php?ar_tab_zr_spalten.php?nseite=57&ntabnr=1||ar_tab_zr_spalten.php?nseite=57&ntabnr=3||ar_tab_zr_spalten.php?nseite=57&ntabnr=2&Ref=GSBhttp://www.umweltdaten.landsh.de/agrar/bericht/ar_tab_anz.php?ar_tab_zr_spalten.php?nseite=57&ntabnr=1||ar_tab_zr_spalten.php?nseite=57&ntabnr=3||ar_tab_zr_spalten.php?nseite=57&ntabnr=2&Ref=GSB
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Figure 2.4: Farm types in Schleswig-Holstein
Data source: http://www.schleswig-
holstein.de/UmweltLandwirtschaft/DE/LandFischRaum/04_AgrarberichtStatistik/06_Agrarstrukrur/0
1_ZahlFlaecheBetriebe/07_ZahlFlaecheBetriebsformen/ein_node.html
After many years of decline, the number of dairy cows in SH has gone up again in recent years
following the liberalisation of the dairy quota trade in 2007. Prior to 2007, quota trade was limited to
exchanges within the federal states. After this constraint was removed in 2007, SH has seen a
substantial inflow of quota from other federal states, giving rise to a significant increase in milk
production. Between 2010 and 2016, cow numbers have gone up by 9% (see Table 2.1). Milk yields
have also increased over time (Figure 2.5), reinforcing the recent trend of expansion.
Figure 2.5: Development of milk yields (kg ECM per cow and year)
Data source: http://www.schleswig-holstein.de/UmweltLandwirtschaft/DE/LandFischRaum/04_AgrarberichtStatistik/07_TierischeErzeugnisse/02_Milchwirtschaft/03_MilcherzAnlieferVerwendMeierei/ein_node.html
4.5
51
4.7
80
4.8
02
4.8
81
5.3
06
5.7
09
6.0
66 6.7
44
6.9
75
7.0
84
6.9
93
7.0
17
7.3
45
7.4
41
1 9 7 7 1 9 8 4 1 9 8 7 1 9 9 0 1 9 9 3 1 9 9 6 1 9 9 9 2 0 0 3 2 0 0 6 2 0 0 9 2 0 1 2 2 0 1 3 2 0 1 4 2 0 1 5
% of farms % of UAA
http://www.schleswig-holstein.de/UmweltLandwirtschaft/DE/LandFischRaum/04_AgrarberichtStatistik/06_Agrarstrukrur/01_ZahlFlaecheBetriebe/07_ZahlFlaecheBetriebsformen/ein_node.htmlhttp://www.schleswig-holstein.de/UmweltLandwirtschaft/DE/LandFischRaum/04_AgrarberichtStatistik/06_Agrarstrukrur/01_ZahlFlaecheBetriebe/07_ZahlFlaecheBetriebsformen/ein_node.htmlhttp://www.schleswig-holstein.de/UmweltLandwirtschaft/DE/LandFischRaum/04_AgrarberichtStatistik/06_Agrarstrukrur/01_ZahlFlaecheBetriebe/07_ZahlFlaecheBetriebsformen/ein_node.htmlhttp://www.schleswig-holstein.de/UmweltLandwirtschaft/DE/LandFischRaum/04_AgrarberichtStatistik/07_TierischeErzeugnisse/02_Milchwirtschaft/03_MilcherzAnlieferVerwendMeierei/ein_node.htmlhttp://www.schleswig-holstein.de/UmweltLandwirtschaft/DE/LandFischRaum/04_AgrarberichtStatistik/07_TierischeErzeugnisse/02_Milchwirtschaft/03_MilcherzAnlieferVerwendMeierei/ein_node.htmlhttp://www.schleswig-holstein.de/UmweltLandwirtschaft/DE/LandFischRaum/04_AgrarberichtStatistik/07_TierischeErzeugnisse/02_Milchwirtschaft/03_MilcherzAnlieferVerwendMeierei/ein_node.html
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With a total of 423 pig farms in 2016, pig production is less important than milk production (5,185
forage farms – see Table 2.2), but has seen the larger increase in average herd size (Figure 2.6). The
average finisher farm has a good 1,600 fattening places – a value much in excess of the German
average. As will be shown in chapter 3, the Filter Decree issued by the regional government in 2013
obliges all new pig fattening units with more than 2,000 places to install and operate an exhaust air
cleaning system. In 2013, there existed only 40 fattening units (ca. 10% of all pig farms) with more
than 2,000 places (Wasielewski and Schmidt, 2014).
Figure 2.6: Average herd size – finishers
Data source:
http://www.umweltdaten.landsh.de/agrar/bericht/ar_tab_anz.php?ar_tab_zr_zeilen.php?nseite
=39&ntabnr=1-4&Ref=GSB/
http://www.umweltdaten.landsh.de/agrar/bericht/ar_tab_anz.php?ar_tab_zr_zeilen.php?nseite=39&ntabnr=1-4&Ref=GSB/http://www.umweltdaten.landsh.de/agrar/bericht/ar_tab_anz.php?ar_tab_zr_zeilen.php?nseite=39&ntabnr=1-4&Ref=GSB/
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Table 2.2: Selected characteristics of common farm types in Schleswig-Holstein 2016
Farm type Number of
farms
Farm size (ha UAA
per farm)
Standard output
(€ per farm)
Herd size (LU per farm)
Profit (€ per farm)
Cattle herd (animals per
farm)
Dairy cows (animals per
farm)
Sows (animals per
farm)
Animals sold per farm and
year Arable farms 3 288 93 171 142 4 45 088 Horticultural farms 356 14 537 435 1 Cattle raising and cattle fattening (non-dairy) 1 424 41 67 377 48 16 601 124 Dairy farms 3 051 106 376 236 186 7 767 253 143 Combined dairy, cattle raising and cattle fattening farms 710 87 263 435 150 24 887 289 68 Pig farms (total) 423 96 698 099 225 38 317 61 2 671
pig fattening farms 211 86 552 824 193 34 886 2 979
pig raising (sow) farms 62 89 777 183 211 45 961 271 Combined sow and fattening farms 150 112 869 765 277 56 641 150 1 424
Poultry farms 74 46 715 396 173 Laying hens 44 . . 107 Poultry fattening 29 69 914 343 . Other farm types 3 390 56 147 265 45 Total 12 716 78 238 470 80
*Classification by EU classification system Data sources: Betriebswirtschaftliche Ausrichtung Standardoutput 2016.xlsx
LBV-Kurzauswertung Wirtschaftsergebnisse 2015/16
file:///C:/Users/suapm106/AppData/Local/Microsoft/Windows/Temporary%20Internet%20Files/Content.Outlook/2MHMIT9K/Betriebswirtschaftliche%20Ausrichtung%20Standardoutput%202016.xlsx
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Table 2.2 summarizes key characteristics of livestock farms in SH. The average Schleswig-Holstein
dairy farm keeps 143 cows and farms 106 ha of land. The average pig-raising farm keeps 271 sows.
Table 2.2. also shows the profits achieved in financial year 2015/16. It is clear that the profits were
low and will hardly suffice to provide the owners with a satisfactory remuneration of their labour
input.
The livestock housing systems typical of Schleswig-Holstein are described in Table 2.3 (for cattle) and
Table 2.4 (for pigs). The tables show both the number of farms operating the respective system and
the total number of places available in each system. The data are from the farm structural survey of
2010. More up-to-date data are not available. It is important to note that tethered husbandry
systems for dairy cows are no longer permitted and will disappear entirely after a transition period.
Table 2.3: Descriptive statistics of cattle housing systems in Schleswig-Holstein in 2010
Housing system Number of farms Places in the respective
system
Cattle (total)
Tethered (bindestald), slurry 900 41 900
Tethered, deep litter 2 300 102 900
Loose-housing, slurry 5 200 834 600
Loose-housing, deep litter 4 700 254 200
Other housing systems 1 200 31 200
Total 8 100 1 264 800
Dairy cows
Tethered, slurry 500 18 500
Tethered, deep litter 900 27 200
Loose-housing, slurry 3 900 343 100
Loose-housing, deep litter 800 20 000
Other housing systems / /
Total 5 200 410 100
Other cattle ¹
Tethered, slurry 600 23 300
Tethered, deep litter 2 100 75 700
Loose-housing, slurry 4 900 491 500
Loose-housing, deep litter 4 600 234 200
Other housing systems 1 200 30 000
Total 8 100 854 700
¹ Calves and heifers, male cattle and other cows (non-dairy)
Source: Statistisches Amt für Hamburg und Schleswig-Holstein: Berichte zur Landwirtschaftszählung 2010
13
Table 2.4: Descriptive statistics of pig housing systems in Schleswig-Holstein in 2010
Housing system Number of farms Places in the respective
system
Pigs (total)
100% slatted floor 900 922 600
Partly slatted floor 900 660 000
Solid floor, deep litter 500 54 700
Other housing systems 100 /
Outdoor systems 100 /
Total 1 800 1 655 600
Sows and boars
100% slatted floor 100 28 900
Partly slatted floor 400 94 900
Solid floor, deep litter 300 13 600
Other housing systems / /
Outdoor systems / /
Total 700 131 300
Other pigs ¹
100% slatted floor 800 893 700
Partly slatted floor 800 575 100
Solid floor, deep litter 400 41 000
Other housing systems / /
Outdoor systems / /
Total 1 700 1 524 300
¹
Source: Statistisches Amt für Hamburg und Schleswig-Holstein: Berichte zur Landwirtschaftszählung 2010
2.2. Natura 2000 areas, regional livestock densities and nitrogen deposition
Given the importance of livestock production in Schleswig-Holstein, nitrogen deposition is relatively
high compared to other parts of Germany. The only area with higher deposition rates is the
southeasterly parts of Lower Saxony - an area of intensive pig and poultry fattening (see Figure 2.7)
As of 1996, Schleswig-Holstein has registered Natura 2000 areas with the EU Commission. This
process is now concluded. There are presently 311 registered Natura 2000 areas in Schleswig-
Holstein: 271 FFH (Flora Fauna Habitat) areas and 46 bird sanctuaries. These encompass a land area
of 156,000 ha and an area of 765,000 ha on the open sea. Only counting the land area, the Natura
2000 network accounts for 9.9% of the state’s territory and 16.6% of the Utilizable Agricultural Area
of Schleswig-Holstein. Most Natura 2000 areas are located on agricultural land or forest land, a few
smaller sites are on unproductive land (e.g. dunes, moors) or in urban areas.
14
Figure 2.7: Nitrogen deposition in Germany in 2009
Source: Umweltbundsamt (2017):
http://gis.uba.de/Website/depo1/download/Erlaeuterungen_DepoKartendienst_UBA.pdf
Figure 2.8 shows the location of the Natura 2000 areas. The figure also contains information about
regional livestock densities (at the county level) in order to identify areas where critical
neighbourhoods are likely to occur. Two counties stand out in this respect: Schleswig-Flensburg
(bordering Denmark) and Steinburg (in the south along the Elbe river). Schleswig-Flensburg is
characterized by mixed farms with arable cash crops and intensive pig production (both finishers and
sows). In Steinburg, by contrast, the focus is on dairy farming. In general, critical neighbourhoods are
likely to appear along the so-called Mittelrücken, i.e. the area of intensive dairy farming in the central
part of Schleswig-Holstein. More disaggregated primary data on livestock densities (below the county
level) is not available due to privacy concerns. However, appendix 11 shows a map of livestock
densities on a 5x5 km grid. This map reinforces the view that livestock densities in the central part of
Schleswig-Holstein are generally higher than in the eastern arable areas.
Natura 2000 sites, which are located on agricultural land, range from around 10 ha to over 8,000 ha.
A list of all registered FFH areas with their names and sizes can be found in appendix 12.
http://gis.uba.de/Website/depo1/download/Erlaeuterungen_DepoKartendienst_UBA.pdf
15
Figure 2.8: Location of Natura 2000 areas in Schleswig-Holstein and livestock densities at the county
(Landkreis) level
There is not enough data to verify whether farms located near Nature 2000 sites are larger or smaller
than the average farms. Nor is it possible to obtain primary data that would allow us to estimate how
many animals are kept at different distances of Natura 2000 sites.
Data is also lacking about the use of ammonia abatement technologies (such as exhaust air filters,
cooling). This data is not collected in any of the regular farm surveys. However, according to the pig
advisory service (Schweine-Spezialberatung Schleswig-Holstein) techniques like slurry acidification or
slurry cooling are not being used in Schleswig-Holstein. Also, slatted floors are still common practice
in new pig fattening units. In addition, most new pig housing investments remain below the critical
animal numbers of the Filter Decree. It is common practice to build fattening units with 1,500 places
– in safe distance of the 2,000 places that would trigger the requirement to install air filters. On the
other hand, if farmers want to build “big” they would build units much in excess of the 2,000 places
threshold. These cases are very rare, however. In general, the current spirit in the pig industry is
pessimistic due to a combination of low pig prices, poor acceptance of pig (and poultry) installations
among the public and a general uncertainty about the future of the regulatory framework for the
industry. The only abatement technique that is now commonly applied in new pig housing
installations is the covering of manure containers (usually with a floating layer, only in exceptional
cases with a tent).2
2 Personal communication with Martin Knees, Schweinespezialberatung Schleswig-Holstein.
16
2.3. Case study farms
In order to facilitate comparison of results across national borders, we base our analysis on the same
case study farms as in the Danish and the Dutch study. These include dairy cows, finishers and
broilers. The dairy farm keeps 120 cows in a loose-housing system and can be considered typical of
the resource settings of Schleswig-Holstein. The pig farm produces finishers in an open system (with
piglets being bought from other farms) and has a capacity of 2,500 fattening places. Given 2.88
production cycles per year, the farm produces 7,200 finishers (28-115 kg) per year. It thus represents
an example of a larger-sized pig fattening unit in Schleswig-Holstein. The poultry farm has 40,000
broiler fattening places with an annual production of 30,000 broilers. Whereas the dairy farm is
highly specialized in milk production (including the rearing of calves and heifers), the pig and poultry
enterprises are part of larger arable farms which grow wheat, barley and oilseed rape.
Extensions of livestock production normally happen by “mirroring” the existing housing capacity. This
means that farmers just double the capacity of their existing animal houses. Typically, new animal
houses are erected in a way that allows mirroring the existing unit at a later point in time. We
therefore assume that the case study farms expand their current production by 100% at their current
production site (i.e. no relocation to avoid critical neighbourhoods).
The three case study farms are assumed to be located in close proximity to a FFH site (400 m
distance) and further away from a FFH site (2000 m distance), respectively.
In contrast to the Danish study, there is no distinct categorization of the nitrogen-sensitive habitats
(Category 1, 2, 3). Rather, different habitat types are characterized by distinct Critical Load (CL)
values (see next chapter). We will base our analysis of ammonia abatement costs on both habitat
type with a low and a higher CL. Another difference from the Danish study is that the administrative
procedures in Germany do not explicitly take into account the number of neighbouring farms but
rather the initial level of ambient pollution (Vorbelastung) in the vicinity of a planned animal housing
installation (see next chapter). In this respect, our analysis will consider two cases: one where the
initial level of pollution lies below the Critical Load for the habitat, and one where it is above the CL.
Table 2.5 provides an overview of the three case study farms before and after the intended
extension.
17
Table 2.5: Livestock production on case study farms before and after extension
Before expansion After expansion
Finishers
Housing capacity of 2,500 places
which is equivalent to an annual
production of 7,200 finishers of 28-
115 kg
Multiple area pens with a separate
dung area (33% drained floor and
66% slatted floor)
Temperature-insulated building
shell with forced ventilation
Slurry tanks with cover
Housing capacity of 5,000
places; equivalent to an
annual production of 14,400
finishers of 28-115 kg
Dairy cows
120 dairy cows, including calves
and heifers
Partially open building, free
ventilation
Cubicles with slatted flooring and a
recirculation manure pit
Slurry tanks without cover
240 dairy cows, including
calves and heifers
Broilers
Housing capacity of 40,000 places,
equivalent to an annual production
of 300.000 slaughter chickens.
Deep litter of straw or wood
shavings, loose housing system
Solid manure
Housing capacity of 80,000
places, equivalent to an
annual production of 600,000
slaughter chickens.
18
3. The legal framework and administrative procedures for regulating
ammonia emissions from livestock holdings in Germany
The legal basis for controlling ammonia emissions from livestock farming are
(1) the Bundesimmssionsschutzgesetz (Federal Emission Control Act) and its delegated legislation in
the form of the Technische Anleitung zur Reinhaltung der Luft (acronym TA Luft = Technical
Instructions on Air Quality Control),
(2) the Umweltverträglichkeitsprüfungsgesetz (Environmental Impact Assessment Act),
(3) the Habitats Directive (Council Directive 92/34 EEC) of 21 May 1992, in conjunction with
(4) the Bundesnaturschutzgesetz (Federal Nature Conservation Act), especially §34 and §36, which
implements the Habitats Directive in national law, and
(5) the Filtererlass (Filter Decree) of the federal state of Schleswig-Holstein.
3.1. TA Luft (Technical Instructions on Air Quality Control)
The TA Luft (2002) specifies the emission abatement requirements of the
Bundesimmissionschutzgesetz for installations that emit airborne pollutants. The TA Luft
specifications are legally binding for regulatory authorities. Applications for planning permission for
animal housing facilities and plans for their extension or alteration need to be checked and decided
by the relevant authorities against the criteria of the TA Luft. The TA Luft applies only to larger animal
housing facilities which exceed certain threshold sizes (Table 3.1). Installations below these sizes
require only permission under building law, not under emission law.
Table 3.1: Animal housing facilities requiring approval under emission law
Type of installation Housing capacity1)
Finishers (> 30 kg) 1,500 (2,000) places
Sows (incl. piglets < 30 kg) 560 (750) places
Piglet raising (10-30 kg) 4,500 (6,000) places
Laying hens 15,000 (40,000) places
Young hens 30,000 (40,000) places
Poultry fattening 30,000 (40,000) places
Turkeys 15,000 (40,000) places
Cattle 600 ( - ) places
Calves (fattening) 500 ( - ) places
Fur animals 750 (1,000) places
Slurry containers 6,500 m³
1) If the numbers in parenthesis are exceeded, the approval procedure must involve public participation
Source: Pöhlmann and Neser (2014)
The TA Luft requires the approving authorities to check whether the prospective ammonia emissions
from a planned project are likely to have adverse local environmental effects. For this purpose,
19
Appendix 1 of the TA Luft specifies minimum distance requirements of animal housing installations
from nitrogen-sensitive plants and ecosystems (without specifying the types of ecosystems). The
minimum distance function takes the following functional form:
𝑋𝑚𝑖𝑛 = √𝐹 ∙ 𝑄 (1)
F is a constant with a given value of 41668 and is measured in 𝑚2∙𝑎
𝑡. Variable Q represents the
prospective ammonia emission rate from a project in tonnes per annum (𝑡
𝑎). It is computed based on
the emission factors shown in Table 3.2 below. An extension of a pig fattening facility from 2,500 to
5,000 fattening places would thus result in total emissions of Q = 3.64 𝑘𝑔
𝑝𝑙𝑎𝑐𝑒* 5000 places = 18.2
𝑡
𝑎.
Inserting this value into the above formula yields a minimum distance of 870 meters from nitrogen-
sensitive areas. Likewise, an extension of a dairy herd from 120 to 240 places (not accounting for
heifer raising) would result in total ammonia emissions of Q = 14.57 𝑘𝑔
𝑐𝑜𝑤* 240 places = 3.5
𝑡
𝑎 and a
minimum distance of 382 metres.
Table 3.2: TA Luft ammonia emission factors
Animal species, housing system, manure storage Ammonia emission factor
(kg NH3/place*year)
Finishers
Forced ventilation, liquid manure (slatted or partly slatted floor) 3.64
Forced ventilation, solid manure 4.86
Freely ventilated housing systems (liquid and solid manure) 2.43
Freely ventilated housing system (on straw or compost) 4.86
Sows (all housing systems) with piglets < 25 kg 7.29
Laying hens (aviary housing with ventilated manure conveyer belt) 0.0911
Laying hens (deep litter, de-manuring once per cycle) 0.3157
Broiler fattening (deep litter) 0.0486
Duck fattening 0.1457
Turkey fattening 0.7286
Dairy cows (tethered, liquid and solid manure) 4.86
Dairy cows (loose-housing, liquid and solid manure) 14.57
Dairy cows (loose-housing, deep litter) 15.79
Fattening bulls and young cattle raising (0.5 to 2 years) tethered
(solid and liquid manure)
2.43
Fattening bulls and young cattle raising (0.5 to 2 years), loose-
housing system, liquid manure
3.04
Fattening bulls and young cattle raising (0.5 to 2 years), loose-
housing system, deep litter
3.64
Source: TA Luft (2002), Appendix 1, translated from German
20
It is important to note that the approving authorities must take into account all animals kept on a
farm, not only the extension. In computing Q, the emissions from the different livestock enterprises
must be aggregated across all animals kept on the farm.
Figure 3.1 visualises the minimum required distance as a function of Q.
Figure 3.1: TA Luft minimum distance requirements of emitting installations from nitrogen-sensitive
plants and ecosystems
Source: TA Luft (2002), Anhang 1
http://www.lexsoft.de/cgi-
bin/lexsoft/kfw.cgi?templateID=document&chosenIndex=0421&xid=144493,10&chosenIndex=0421
If a proposed animal housing installation meets the minimum distance requirement, the approving
authorities must consider this as an indication that the installation will have no adverse effects on
nitrogen-sensitive ecosystems - even if the initial level of pollution in the area is high. The minimum
distance test is intended to keep the administrative cost at bay by identifying uncritical cases, which
require no further assessment. If a planned installation does not meet the minimum distance
requirements, a detailed assessment of the environmental effects is necessary. This normally takes
the form of ammonia emissions dispersion modelling. The investor will have to demonstrate that the
emissions caused by the planned project are not harmful. According to the TA Luft, this is the case if
the project-related ammonia emissions do not exceed 3 g/m³ or do not result in a total
concentration of more than 10 g/m³ in the reception area.
In addition to the minimum distance requirements, TA Luft contains threshold values for the mass
flow rate of ammonia in the exhaust air (15 kg/hour) and the mass concentration of ammonia in the
exhaust air (30 mg/m³).
It is important to note that the minimum distance requirements of TA Luft (2002) relates to nitrogen-
sensitive plants such as crops and nurseries (i.e. man-made ecosystems). In 2002, potential damage
to nitrogen-sensitive natural ecosystems was not yet of common concern. As will be shown further
Min
imu
m d
ista
nce
in m
etre
s
Ammonia emissions in tonnes per year
http://www.lexsoft.de/cgi-bin/lexsoft/kfw.cgi?templateID=document&chosenIndex=0421&xid=144493,10&chosenIndex=0421http://www.lexsoft.de/cgi-bin/lexsoft/kfw.cgi?templateID=document&chosenIndex=0421&xid=144493,10&chosenIndex=0421
21
below, the minimum distance requirements derived from the FFH-specific legislation are much
stricter. A current draft of a new TA Luft also envisages substantially stricter distance requirements.
3.2. Umweltverträglichkeitsprüfungsgesetz (Environmental Impact Assessment Act)
Depending on the type and size of a farm’s livestock enterprises, an environmental impact
assessment (EIA) may be necessary in addition to the approval under emission law. An EIA is
mandatory for livestock farms above certain threshold sizes (Table 3.3). An EIA involves extensive
documentation, assessment reports and expert opinion on a broad set of environmental indicators
that may be affected by a proposed project. An EIA thus is much broader in scope than the approval
procedure under TA Luft. A full EIA is considered to be very time-consuming and expensive which is
why farmers usually keep the size of their livestock enterprises below the threshold values shown in
column 1 of Table 3.3. However, a (less costly) preliminary EIA survey (EIA screening) is also required
for smaller animal housing facilities as per column 2 of Table 3.3. The purpose of the screening is to
assess whether a full EIA is necessary. A distinction is made between general EIA screening and site-
specific screening. The purpose of a general screening survey is to check whether an intended project
can in principle affect subjects of protection such as biodiversity, human health, soil, water, air
quality, landscape etc. The site-specific screening examines the surrounding environment of a
proposed project. If, for example, sensitive ecosystems are found in the vicinity of the project, the
general preliminary EIA survey will assess whether the project can in principle cause harm to the
ecosystem. If this is found to be the case, a full EIA becomes mandatory.
Table 3.3: Animal housing facilities requiring full EIA (column 1) or EIA screening (column 2)
Animal species Full EIA required
(column 1)
EIA screening required
(column 2)
General EIA screening Site-specific screening
Laying hens 60,000 40,000 15,000
Young hens 60,000 40,000 30,000
Poultry fattening 85,000 40,000 30,000
Turkeys 60,000 40,000 15,000
Bovine cattle - 800 600
Calves (fattening) - 1,000 500
Finishers 3,000 2,000 1,500
Sows 900 750 560
Piglet raising 9,000 6,000 4,500
Fur animals - 1,000 750
Source: Pöhlmann and Neser (2014) based on UVP-Gesetz – Anlage 1 Liste ”UVP-pflichtige
Vorhaben”, translated from German
An EIA does not constitute an approval procedure in its own right. Its main purpose is to inform the
decision of the approving authorities. The results of the EIA shall be taken into account in the
approval procedure.
22
3.3. FFH compatibility assessment
All plans or projects which individually or in interaction with other projects can cause significant
harm to Natura 2000 areas must be subjected to a FFH compatibility assessment as per §34
Bundesnaturschutzgesetz. The purpose of the compatibility check is to assess whether or not the
intended project is compatible with the conservation objectives of the areas concerned. In contrast
to the approval process under emission law (TA Luft) and EIA, there are no minimum threshold sizes
for the FFH compatibility assessment. Rather, all projects which can potentially harm a Natura 2000
area must be subjected to the test. Figure 3.2 gives an overview of the FFH compatibility assessment
process.
Figure 3.2: FFH compatibility assessment procedure (overview)
CL = Critical Load
Source: BMVBS (2013), translated from German
The FFH compatibility assessment starts with a FFH preliminary assessment (FFH-Vorprüfung), i.e. a
screening process to establish whether the project can in principle substantially harm the FFH site in
question. If this is found to be the case, a full FFH compatibility check is required. Central to the FFH
screening process is the Critical Loads concept in conjunction with the so-called cut-off criterion
(Abschneidekriterium). Critical loads are threshold values for nitrogen deposition which are specific
to the type of habitat or ecosystem under consideration. These are laid down in the so-called Berne
List of nitrogen-sensitive ecosystems (Bobbink and Hettelingh, 2011). A summary table of critical
no
no
no
no
no
yes
yes yes
yes
yes
yes
yes
FFH site with a specific CL
Expected total nitrogen deposition
(Gesamtbelastung) > CL
Project-related additional load at
FFH site above 0.3 kg N/ha*year
Cumulative additional load at FFH
site above 3% of CL
Area affected by CL>3% CL exceeds
the assessment values by Lambrecht
and Trautner (2007)
FFH site of
„qualitatively
functional
importance“
Authorities must assume risk of substantive impairment of the
FFH site through nitrogen deposition
Case-specific
review
No
substantive
impairment
through
nitrogen
deposition to
be expected
no
23
loads for key habitat types is shown in the appendix 1. Critical loads are defined for each individual
FFH site with nitrogen-sensitive vegetation. If in a specific case the nitrogen deposition stays within
the limits of the Critical Load of the FFH site in question, the approving authorities can assume that
the project will be compatible with the conservation goals of the site. In that case, no further impact
assessment is required. This is also the case if the additional emissions caused by the intended
project is estimated to remain below 0.3 kg N/ha*a. This so-called cut-off criterion was included in
the approval procedures following a ruling in 2014 of the Federal Constitutional Court
(Bundesverfassungsgericht), arguing that no causal relationship between emission and deposition
can be established below 0.3 kg N/ha*a. The cut-off criterion also applies when the Critical Load is
exceeded.
For assessing whether the Critical Load is exceeded or not, the authorities must take into account the
initial nitrogen deposition (Vorbelastung) and the extra load caused by the project (Zusatzbelastung).
The resulting total load (Gesamtbelastung) is then compared to the Critical Load for the concerned
FFH site. GIS-based data on the Vorbelastung are available from the Umweltbundesamt on a 1 km x 1
km grid (http://gis.uba.de/website/depo1/). In the FFH screening process, the project-related extra
load (Zusatzbelastung) is calculated based on an extended version of the minimum distance equation
of the TA Luft (see equation (1) above). The calculation will be described in detail in chapter 5 for the
three case study farms. In computing the extra load, the authorities must apply the accumulation
principle according to a 2011 ruling of the Higher Administrative Court Münster
(Oberverwaltungsgericht Münster). This means that the authorities must take into account also the
prospective emissions from other planned projects in the area (i.e. projects for which applications for
planning permission have been submitted).
In most parts of Schleswig-Holstein the initial nitrogen deposition (Vorbelastung) is in excess of the
Critical Load for nitrogen-sensitive habitat types and ecosystems (compare figure 2.7 with appendix
1). This does not mean, however, that new projects cannot be approved. Instead, further assessment
is required. In the FFH screening process, the approving authorities may consider a project’s
additional load as irrelevant in terms of its impact on the protected ecosystem if it lies below 0.3 kg
N/ha and year (cut-off criterion) in the reception area or below 3% of the Critical Load. The latter is
the so-called de-minimis threshold (Bagatellgrenze) established by a 2010 ruling of the Federal
Constitutional Court (Bundesverfassungsgericht).
If the de-minimis threshold is likely to be exceeded by the intended project, a full FFH compatibility
assessment is required. The ball is then in the field of the investor to prove that appropriate
ammonia abatement measures can keep the project’s additional load within the limits of the de-
minimis threshold. This proof normally involves costly ammonia dispersion modelling based on the
AUSTAL model. Alternative ammonia abatement measures can be simulated by the AUSTAL model.
The farmer/investor and his/her consultant will successively add emission reduction measures until
the model simulations show that the project-related extra load does not cause substantial harm to
the protected ecosystem. This is the case if the extra load can be reduced to a level below the de-
minimis threshold. If the extra load cannot be kept within the limits of the threshold, the authorities
must assess whether the extra load exceeds the assessment values by Lambrecht and Trautner
(2007). These take into account the specificities of the ecosystem under consideration. If these
values are transgressed, the authorities must assume that the project is likely to cause substantial
harm to the protected ecosystem and thus have to reject the application for building permission.
http://gis.uba.de/website/depo1/
24
The last resort for the investor then is to revert to the so-called Ausnahmeprüfung (excemption
check). Under the exception check, an environmentally harmful project may all the same be
approved if it meets the strict requirement that there are no suitable alternatives and that the
project is predominantly in the public’s interest. In addition, the public’s interest in the project must
rank higher than the interest in conserving the FFH site. Since these conditions are not met by animal
housing projects, the exemption check will rarely be relevant in such cases.
3.4. Filtererlass (Filter Decree of the State of Schleswig-Holstein)
The Filter Decree was issued by the regional government of Schleswig-Holstein in 2014. As of 15 July
2014, all new pig housing installations above a certain size must install and operate an exhaust air
cleaning system. The Filter Decree applies to pig housing installations above 2000 fattening places,
750 sows or 6000 piglet raising places. The Filter Decree thus applies to the same pig farming
operations that are subject to an approval procedure with public participation under emission law
(see Table 3.1 above). The obligation to install filters only applies to new installations and substantive
changes to existing installations. Any extension of the housing capacity would thus trigger the
requirement to install filters for the entire installation. There is no general refitting obligation for
existing pig farming installations which exceed the above threshold sizes.3 Refitting requirements are
rather to be decided individually on a case-by-case basis (Wasielewski and Schmidt, 2014).
The Filter Decree further contains the requirement to cover slurry containers. Newly built containers
in excess of 6,500 m³ must be covered by a tent roof. The same applies to all new slurry containers
(irrespective of their size) in pig fattening installations with more than 1,500 fattening places. Slurry
containers and reservoirs that are part of pig farming installations which are not subject to approval
by emission law (i.e. with less than 1,500 fattening places) must at least be covered with a floating
straw layer (Wasielewski and Schmidt, 2014).
In Germany, filter decrees have been issued by the regional governments of Schleswig-Holstein,
Lower Saxony, North Rhine-Westphalia, Thuringia and Brandenburg. The first three states are
characterized by high livestock densities. In the remaining 11 German states, no such legislation
exists. This has given rise to fears over potential competition distortions in pig production within
Germany.
3 In 2014, there were only approximately 40 pig farms in Schleswig-Holstein that exceed the threshold sizes of the Filtererlass (Wasielewski and Schmidt, 2014).
25
4. Ammonia emissions abatement on livestock farms
In livestock facilities, ammonia gas results primarily from the breakdown of urea (part of urine) by
the enzyme urease. Undigested feed protein and wasted feed are additional sources of ammonia in
livestock production systems. The emission of gaseous ammonia from animal housing facilities is
largely influenced by the animal species and production branch. The excrement varies with regard to
protein residues which is different for different animal species so that emission rates also vary by
species. Production techniques can also have an impact on the release of ammonia. In continuous pig
fattening systems, for example, a more uniform emissions profile may be expected than in an all-in-
all-out system (VDI, 2011). Likewise, tethered housing for cattle results in significantly lower
ammonia emissions than loose-housing systems where animals can move freely (Eurich-Menden,
2012).
Strategies to reduce ammonia from animal housing revolve primarily around preventing ammonia
formation and volatilization or downwind transmission of ammonia after it is volatized. A wide range
of measures to abate ammonia emissions from livestock holdings is available. These can be classified
in various ways. A common distinction is between system-integrated measures and end-of-pipe
measures. The former aim to reduce ammonia emissions at their source, i.e. in the production
process, and can be considered as preventive measures. End-of-pipe measures, by contrast, aim to
reduce emissions from animal housing once the ammonia has been volatized in the production
process. The latter group of measures can therefore be classified as curative measures. VDI Guideline
3894 (VDI, 2011) describes the state of art of both production-integrated and end-of-pipe measures.
In addition, KTBL (2006) provides further guidance on end-of-pipe measures in the form exhaust air
cleaning systems (filters). This chapter reviews the different types of practices to reduce ammonia
emissions from livestock housing. Not all of the measures described in this chapter are recognized by
the relevant regulatory bodies as ”good practice” or ”best available technology” (BAT) in the
approval procedure.
4.1. System-integrated measures
The system-integrated abatement measures can apply at different stages of the production process
(VDI, 2011):
Building hull and ventilation techniques
Housing techniques and room structuring (e.g. functional areas)
Littering and de-manuring
Feeding an watering techniques
Storage of liquid and solid manure as well as silage
Utilization, design and management of yards
Pasture use / grazing
System-integrated ammonia abatement measures can therefore be applied in animal housing
facilities, storage facilities, farmyards and land use. Table 4.1 provides an overview of system-
integrated measures for ammonia and odour abatement.
26
Table 4.1: Overview of system-integrated ammonia and odour abatement measures in livestock
production
Source: VDI (2011), pp. 42-43
27
Building hull and ventilation techniques: When the temperature in the animal house is kept as low
as possible with respect to the physiological needs of the animals, microbiological degradation
processes are slowed down and gaseous emissions are reduced. Since the temperature in freely
ventilated animal houses is usually lower on average than in insulated housing facilities with forced
ventilation, their emission potential is lower. In both housing systems, the temperature level during
summer months can be lowered by means of fresh air cooling (e.g. fog evaporation cooling,
geothermal heat exchanger). A lower fresh air temperature also allows the minimum air flow rate for
summer operation to be reduced, resulting in lower flow velocities of fresh air and thus lower
emissions. In order to prevent humidity from condensing on the floor in poultry production (which
would lead to moist litter), the animal houses must be preheated before being littered. In addition,
the floors must be insulated.
Housing techniques and room structuring: Housing techniques which allow separate functional
areas (activity, lying, and dung area) to be established result in a reduction of soiled, emission-active
surfaces and improved animal welfare. Such housing techniques are easier to implement in pig
housing facilities than in cattle housing. In cattle housing, all areas used by animals except for the
lying areas are potential emission surfaces. These areas and the resulting emissions are lowest when
the animals are housed individually and fixed, and they are largest in group housing in loose-housing
systems. However, the latter is BAT with respect to animal welfare, so that trade-offs between
emission reduction on the one hand and improved animal welfare on the other must be considered.
Also, if animal-friendly housing requires access to water, showers and bathing facilities (as is the case
in certain poultry enterprises), these facilities must be designed such that the surrounding litter does
not become wet.
Littering and de-manuring: In cattle housing, repeated daily cleaning of concrete surfaces or
perforated floors with the aid of mechanical de-manuring equipment reduces ammonia emissions.
The less liquid manure flows into the channels, the lower are the emissions. Cattle houses where
liquid manure is stored in a circulation or slalom system under the floor must therefore be
considered unfavourable. The stirring of manure should be avoided in order to keep ammonia
emissions low. This requires the manure channels to have no narrow points or side cuts and that the
passages at the channel ends are wide. In pig housing, flat channels with rinsing equipment which
causes liquid manure quickly to drain from the animal house can help reduce ammonia emissions. In
such a system, a siphon must be installed between the animal house and the outdoor liquid manure
storage in order to prevent gases from flowing back into the animal house. In addition, slurry
channels must be dimensioned such that the filling does not rise beyond 10 cm below the perforated
floor.
In housing systems with solid manure, the animal houses must be littered regularly and sufficiently,
and the litter must be removed on a regular basis. The better faeces and urine are absorbed by the
litter, the lower is the emission of gaseous ammonia. In poultry housing, dung drying inhibits
degradation by microbes and thus reduces the release of ammonia. The dung is dried by collecting it
on transport belts and ventilating it (dung belt ventilation). Depending on the ventilation rate, a dry
matter content of 60% is achieved when the poultry house is de-manured weekly.
Feeding and watering: Reduction of nitrogen excretion is an obvious method to curb ammonia
emissions. When less nitrogen is excreted less ammonia will be formed and volatized. When
common feeds are used in pig diets, crude protein is added to meet the animals’ need for lysine, the
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most limiting amino acid. All other amino acids are consequently supplied in excess and excreted. An
obvious approach of abating ammonia emissions is therefore to supply non-ruminants with the
amino acids they need instead of supplying feeds based on crude protein. In pig and poultry
production, nitrogen excretion can be reduced by up to 10 % for each percentage point production in
dietary crude protein. In practice, reductions in protein (and thus nitrogen) input into the non-
ruminant livestock production system can be achieved by means of multiple-phase feeding. For
example, lowering the protein content of feed rations in pig fattening from 18% in the first phase of
the production process to 15% in phase 2 can reduce ammonia emissions by 10%. A feeding regime
with 3 or 4 phases (with only 13% protein in the final phase) results in 20% less ammonia emissions,
and multiple-phase feeding regimes (with daily adjustments of the protein content) can save up to
40% of ammonia emissions (Eurich-Menden et al., 2011; VDI, 2011). In Germany, phase feeding is
recognized as an abatement technique with a proven reduction potential, that is, there is little
uncertainty about the environmental effectiveness of the measure. For this reason, the relevant
state authorities recognize phase feeding as an effective abatement measure in the approval
procedure of animal housing facilities. Although phase feeding requires additional capital costs for
equipping the feeding system with additional tubes and silos, it has been identified as a cost-effective
abatement measure because a reduction in the crude protein content is normally associated with
variable cost savings. However, the variable cost savings are partly offset by the additional costs of
supplying lysine to the animals’ need. There is consensus in the (German) literature that the
additional capital cost balances with the variable cost savings over the effective lifetime of a pig of
poultry housing facility (see for example, Rößler et al., 2012, for pig production; Thobe and Haxsen,
2013, for poultry production).
There is less scope for phase feeding in dairy cattle systems (Spiekers et al., 2016). Dairy cows must
be fed adapted feed rations while standing dry and during the lactation phase. There is ongoing
research on the use of feed additives (urease inhibitors) in dairy cow feeding. While there is tentative
evidence that urease inhibitors can contribute to ammonia emission reduction, state authorities do
not recognize this an effective abatement measure in the approval procedure of animal housing
facilities.
Storage of liquid and solid manure as well as silage: German fertilizer legislation (Düngeverordnung)
requires the storage capacity for solid and liquid manure to be dimensioned such that the spreading
can occur at an agronomically suitable time. For liquid manure, a storage capacity of at least 6
months is required by law. The following attributes of manure storage facilities are recommended
(but not legally required) to reduce ammonia emissions:
Small container diameter and a small manure area exposed to the wind
Low wind velocity above the liquid manure surface (low filling height or high freeboard,
natural floating layer, chopped straw cover, granulate or film cover, tent roofs)
Low temperature of the stored manure (underground tanks, shading)
Avoidance of manure movement (pumping, stirring, homogenizing – only when wind does
not blow in the direction of sensitive habitats)
Solid covers (tent roofs and concrete) are recognized by state authorities as effective abatement
measures, but they are at the same time the most expensive types of cover. Table 4.2 gives an
overview of the environmental effectiveness of different liquid manure storage covers.
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Table 4.2: Emission reduction (%) through different liquid manure container covers
Source: VDI, 2011
The options for abating ammonia emissions from solid manure storage are relatively limited. Storage
of solid manure requires construction of a paved dung storage facility. In order to keep emissions
low, the storage facility should be compact and have a small surface area exposed to the wind. This
means that the facility should have walls on three sides. Slurry and rainwater must be collected and
drained into a closed slurry container. Dry poultry dung must be stored in dry conditions – under a
cover or a roof in order to prevent remoisturing. In closed halls, condensation must be prevented by
taking appropriate measures such as temperature insulation.
There are also only few options for reducing ammonia emissions from silage storage facilities.
Upright silos are the form of silage storage with the lowest emissions. However, these silos are very
expensive and only suitable for smaller farms. When planning a silo storage facility, it is
recommended that the silo cut area faces north and not in the main wind direction.
Utilization, design and management of yards: Yards are features of animal-friendly housing facilities
which give animals access to outside air. However, they can cause additional emissions. Yards should
therefore be kept clean and dry. This is supported by perforated floors, separate dung areas (only in
pig housing) and daily removal of excrements. Rinsing with water contributes to emission reduction,
but increases the quantity of liquid manure to be stored and spread.
Pasture use / grazing: Grazing animals emit less ammonia than animals kept inside. This effect is
mainly due to the better absorption of faeces and urine by pasture compared to concrete surfaces in
animal houses or yards. However, to the best of the author’s knowledge, there exists no research
which has tried to quantify the emission reduction caused by grazing.
It is important to note that only some of the above ammonia abatement measures (such as liquid
manure storage covers or multiple-phase feeding) have a proven reduction potential and are thus
recognized as ”good practice” or BAT by authorising agencies or regulatory bodies. The impact of
such measures on ambient emission levels (e.g. in a nearby FFH area) can be simulated by means of
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ammonia dispersion models. As explained above, the farmer or investor must decide on the
appropriate combination of emission control measures. He or she is in charge of demonstrating that
the extra emissions caused by the intended investment will not result in nitrogen deposition in FFH
areas exceeding critical limits. It remains at the discretion of the authorising agencies, however,
whether or not they recognize individual abatement measures as sufficient.
4.2. End-of-pipe measures
Exhaust air cleaning: The use of an exhaust air cleaning system allows emissions from animal houses
with forced ventilation to be reduced significantly (by 70 to 90%). This technique can only be used in
housing systems with forced ventilation because the exhaust air must be collected and lead through
the cleaning system. Freely ventilated animal houses cannot therefore be equipped with an exhaust
air cleaning system. The main area of application is currently pig housing. Recently, the technique has
also been used in poultry houses, after filters have been developed that can cope with the higher
concentrations of dust in the exhaust air of poultry houses.
Installation and operation of exhaust air cleaning systems is very expensive both in terms of
investment outlays and operating costs (KTBL, 2006). For reasons of proportionality, they are
generally used only when all system-integrated measures of ammonia abatement have been
exhausted and the protection of the environment against harmful impacts cannot be guaranteed
otherwise. This practice has changed since July 2014. As described above, the Schleswig-Holstein
Filter Decree obliges all new pig farming installations with more than 2,000 fattening places, 750
sows or 6000 piglet raising places to install and operate an exhaust air cleaning system.
The type of exhaust air scrubber is mainly chosen based on the kind of emissions to be abated, the
intended area of application of the technique, and the required cleaning capacity (KTBL, 2006). Table
4.3 summarises the most important cleaning techniques available on the market.
Table 4.3: Overview of available exhaust air cleaning systems for animal houses
Source: VDI (2011), p. 58.
In Germany, the DLG (Deutsche Landwirtschaftsgesellschaft – German Agricultural Society) has
developed a certification procedure for exhaust air filter systems. The certificate verifies the
environmental effectiveness of the system. In principle, only cleaning systems that have passed the
DLG suitability test are recognized by regulatory bodies and authorising agencies.
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Continuously high cleaning performance requires the facility to be correctly dimensioned and
properly operated. The operator must guarantee this through regular monitoring and maintenance
and proper documentation of all actions.
Treatment of solid and liquid manure: Acidification of slurry is a proven method for reducing
ammonia emissions from livestock manure. Slurry acidification techniques can be used to reduce
ammonia losses from livestock manure in livestock housing, manure storages and from fields during
manure spreading. The three main types of slurry acidification systems are:
In-house acidification of livestock slurry
In-storage acidification of stored livestock slurry
In-field acidification of livestock slurry during field spreading.
For all systems, concentrated sulphuric acid (96% H2SO4) is used for acidification. The aim is to reduce
ammonia volatilisation and hence nitrogen losses. Use of acidification ensures that the majority of
nitrogen in the slurry is retained in the form of ammonium (NH4+), instead of ammonia (NH3), which
can volatilise. Lowering the pH from 7 to around 5.5 is very effective for this, since at pH < 6
ammonia losses are minimal.
Slurry acidification technologies have been developed in Denmark over a decade ago. These
technologies have been tested under Danish conditions and are approved by the Danish
Environmental Protection Agency as BAT for reducing ammonia emissions from livestock farms by up
to 70 %.
Slurry acidification is expensive since it requires investments in the relevant facilities on farm as well
as operating costs for purchasing concentrated sulfuric acid. A case study of a Danish pig fattening
facility with an annual output of approximately 9000 finishers has yielded cost estimates of
around. DKK 25 or €3.40 per ton of slurry acidified by means of the in-field system (Haargaard, 2017).
Additional costs and potential human health hazards can arise from the need to handle a highly toxic
substance: sulphuric acid. On the other hand, slurry acidification has the potential to benefit farmers
by increasing the nitrogen use efficiency of their manure, thereby reducing their reliance on
purchased mineral nitrogen. Further financial benefits arise from the use of sulphuric acid which acts
as a sulphur fertilizer and thus saves the cost of purchasing mineral sulphur. In addition, the odour
nuisances from manure in the pig house, during storage and during field spreading can be expected
to decline. Less dust has been observed in pig houses where the slurry is acidified.
Bussink et al. (2012) report the costs for in-house slurry acidification on a Dutch dairy farm with 150
cows to be €84 per cow and year or €5.57 per kg NH3 abated. The full calculation is shown in Table
4.4. A cost calculation by Jonassen (2016) for in-house slurry acidification on Danish dairy and pig
farms yields lower costs for larger units (Table 4.5). The results of the calculations in tables 4.4. and
4.5 suggest that one can expect a substantial fixed cost degression as one increases the size of animal
housing facilities (here only shown for dairy units): from €84/cow at 150 cows down to €38 per cow
at 375 cows. If one assumes the same amount of emission reduction (15 kg NH3 per cow and year),
the cost degression is from €5.57 (at 150 cows) down to €2.52 per kg NH3 abated (at 375 cows). This
may create incentives to invest in larger units. Compared to the cost estimates for the three model
farms in Chapter 5, these abatement costs are relatively low.
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Table 4.4. Costs of in-house cattle slurry acidification on a 150-cow farm in the Netherlands
Equipment (investment) 100.000 €
Effective lifetime 20 years
Interest 2,500 €
Depreciation 5,000 €
Maintenance costs 2,500 €
Sum annual fixed costs 10,000 €
Cost of sulfuric acid 4,170 €
Costs for additional lime 1,893 €
N fertilizer savings -2,700 €
S fertilizer savings -830 €
Sum annual net variable costs 2,533 €
Total annual net costs for farm 12,533 €
Total annual net costs per cow 84 €
Net costs per kg NH3 abated1) 5.57 €
Net costs per kg CH4 abated1) 1.52 €
Net costs per kg CO2 equivalent abated 72 €
1)Assumption: Emission reduction by 15 kg NH3 and 55 kg CH4 per cow and year
Source : Bussink et al. (2012)
Table 4.5. Costs of in-house slurry acidification for a Danish dairy farm (375 cows) and a Danish pig
farm (18,000 finishers per year)
Finishers Dairy cows
Number of animals 18,000 per year 375
Quantity of slurry 9,500 tonnes per year 8,000 tonnes per year
Equipment (investment) 250,000 € 100,000 €
Maintenance costs per year 4,000 € 1,000 €
Depreciation 12,500 € 5,000 €
Interest 6,250 € 2,500 €
Total fixed costs per year 22,750 € 8,500 €
Costs of sulfuric acid 7,500 € 7,500 €
Costs for extra energy 3,200 € 3,200 €
Extra labour costs 100 € 2,000 €
Costs for additional lime 1,500 € 1,500 €
N and S fertilizer savings -11,000 € -8,500 €
Sum annual net variable costs 1,300 € 5,700 €
Total annual net costs for farm 24,050 € 14,200 €
Total annual net costs per animal 1.34 € 38 € Total annual net costs per tonne of slurry 2.53 € 1.78 €
Source: Jonassen (2016), amended by author to make it comparable with Table 4.4
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There are fewer sound cost calculations for in-field slurry acidification. Variable costs result from the
use of sulfuric acid and the requirement to apply lime to keep soil pH constant. The application rate
for slurry acidification lies between 1.5 and 3 litres per m3. For digestate from biogas plants it is much
higher (7 litres and more because of its higher pH). The price of sulfuric acid has been fluctuating
between €0.25 and €0.55 per litre. If one assumes €0.33 per litre and an application rate of 1.5 litre
per m3 of slurry, the variable cost is €0.50 per m3 of slurry. Roughly the same amount must be added
for compensatory lime application. Tamm et al. (2013) argue that the extra cost charged by a
contractor for spreading acidified slurry is only €0.55 per m3, but given the high investment costs
(€54,000 to equip one tractor)4, this value seems rather low. Sticking with the above figures, the total
costs are around €1.50 (or higher) per m3 of slurry. From these costs one must deduct the savings in
mineral N and S fertilizer. There is also an indication that application of acidified slurry can result in
(slightly) higher yields (Neumann, personal communication)5. Depending on the size of the savings
and/or yield increases, in-field application can potentially lead to a net gain in income for the farmer,
but a net cost seems more likely in most circumstances.
In Germany, slurry acidification does not yet belong to the set of best available technologies. The
technique is limited to pilot installations and demonstration projects. Concerns about road safety
(transportation of large quantities of sulphuric acid in tractor-mounted containers on public roads)
have proven a key obstacle to in-field acidification of slurry (Stauss, 2017, personal communication)6
Another technique to reduce ammonia emissions from animal manure is anaerobic treatment of the
manure in biogas plants. The emission-reducing effect of biogas plants are, however, of secondary
importance for investment decisions. The primary motivation lies with the high profitability of biogas
plants. Emission reductions from anaerobic treatment of manure in biogas plants can therefore be
considered at most a positive side effect of bioenergy production rather than an abatement
technique in its own right.
4.3. Measures for reducing exposure to critical ammonia concentrations
Besides the emission-reducing measures described above, farmers/investors can reduce the
exposure of nitrogen sensitive habitats to ammonia by choosing the location of a planned animal
housing facility. In this respect, the following aspects should be considered (VDI, 2011):
Keeping sufficient distance from areas in need of protection, observing potential previous
emission concentrations
Taking into account the main wind direction and choosing the location such that nitrogen-
sensitive areas do not lie in the main wind direction
Taking account of the orography and topography and their effects on the flow conditions
Planning sufficient reserves for a potential extension of the facility in the future.
4 Personal communication with Michael Zacharias, Landesamt für Landwirtschaft, Umwelt und Ländliche Räume (the state agency in charge of approving animal housing projects) 5 Kiel University, Department of Agronomy. Higher wheat yields were measured in field trials at Hohenschulen experimental farm of Kiel University. Data not yet completely analysed, results tentative. 6 Landesamt für Landwirtschaft, Umwelt und Ländliche Räume
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In Schleswig-Holstein, most critical neighbourhoods can be resolved by choosing the right location for
a planned livestock facility (Holzgräfe, 2017, personal communication)7. Only in situations where an
existing facility is to be extended at its present location, the siting of the new installation is not a
decision variable to avoid critical neighbourhoods. In such cases, system-integrated and end-of-pipe
abatement measures are called for. In other German federal states (Bundesländer) with higher
population densities, choice of location is less of an option than in the sparsely populated rural areas
of Schleswig-Holstein, and investors must rely more on the abatement measures described in
sections 3.1 and 3.2.
4.4. Best available technology
Best available technology (BAT) in Germany is currently defined by the “Reference Document on Best
Available Techniques for Intensive Rearing of Poultry and Pigs” published in 2003.8 This document is
available on the website of the Umweltbundesamt and is intended to provide state authorities with
guidance in the approval procedure of new animal housing facilities.
The document lists some general principles for pig housing facilities. These include:
Reduction of emitting manure surfaces
Removing slurry from the pit to an external slurry store
Applying an additional treatment, such as aeration, to obtain flushing liquid
Using surfaces that are smooth and easy to clean
For finisher production, the document mentions housing systems with a fully-slatted floor with a
deep manure pit and mechanical ventilation as the reference technology against which the following
BAT are to be assessed:
Fully-slatted floor with a vacuum system for frequent removal of slurry
Partly-slatted floor with a reduced manure pit, including slanted walls and a vacuum system
Partly-slatted floor with a central, convex solid floor or an inclined solid floor at the front of
the pen, a manure gutter with slanted sidewalls and a sloped manure pit
The document explicitly excludes from the list of BAT for new pig housing facilities the following
techniques:
Manure cooling (too expensive)
Partly-slatted flooring with manure scrapers underneath (operational difficulties) and
Fully or partly-slatted floor systems with flushing gutters or tubes underneath when
operated with aerated liquid (odour peaks, operational problems).
7 Ministerium für Energiewende, Landwirtschaft, Umwelt und Ländliche Räume des Landes Schleswig-Holstein. 8 https://www.umweltbundesamt.de/sites/default/files/medien/419/dokumente/bvt_intensivtierhaltung_zf_1.pdf
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For broiler production, the traditional housing system is described as a simple closed building
construction of concrete or wood with natural light or windowless with a light system, thermally
insulated and force-ventila