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/

11

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