REGULATORY AND INCENTIVE POLICIES TO

REDUCE NITROGEN POLLUTION IN THE

BRITTANY REGION (FRANCE)
L. Loyon

OPAALE research unit, IRSTEA – Avenue de Cucillé, Rennes, France

ABSTRACT: Nitrogen, an essential element for plant nutrition, contributes when it is applied in excess
to the pollution of rivers or groundwater and eutrophication phenomenon by associating with
phosphorus. Mismanagement at the farm level is also responsible for ammonia and greenhouse gas
emissions. To limit these losses that are harmful to the environment, public policies, whether regulatory
or incentive, have been put in place at different times. Some target water pollution (nitrate directive) and
others air quality (NEC Directive) or climate change. This paper proposes to make an inventory of these
different public policies in terms of the management of organic nitrogen from livestock, especially for the
region of Brittany, the main hotspot of nitrogen pollution in France.

1. INTRODUCTION

Brittany, located in the far west of the country, is the main agricultural region of France. The Useful
Agricultural Area (UAA) represents more than 62% of the regional territory (Agreste Bretagne, 2018).
The main agricultural activity in the region is the breeding of pigs, poultry and dairy cows (Table 1). To
support this strong animal production, crop production is oriented towards grass forage, grain corn and
soft wheat (Agreste Bretagne, 2018). Organic SAU is poorly represented and organic farms are mainly
used to feed organic animal production. To achieve this level of agricultural production, a change in
agricultural land (expansion of fields, plowing of grasslands, elimination of hedgerows, etc.) was
necessary (Gascuel-Odoux et al., 2010). In addition, the UAA of farms in Brittany decreased by about
102 000 ha between 1989 and 2017 while the livestock remains more or less stable. This
transformation of Breton agriculture has impacted the quality of the environment by leakage of nitrogen
to the environment. The nitrogen produced by the Breton herd is mainly spread on the land added to
pasture nitrogen (Table 1). This nitrogen production is unevenly distributed over the territory, resulting
in nitrogen flows that are often greater than the agronomic capacity of the land. Brittany has the highest
nitrogen excess (Cgdd, 2018) and one of the highest in the EU-28. In 2017, mineral nitrogen and
organic nitrogen inputs were 65 kgN.ha-1 and 130 kN.ha-1 of UAA, respectively (Agreste Bretagne,
2018). In the 1980s, a large number of Breton rivers have had nitrate concentrations above 50 mg. L-1.
Breton rivers are still loaded with nitrates (Dreal, 2015). These nitrate flows contributed to the
proliferation of green algae that appeared in the 1970s Between 2007 and 2017 the average area of
sandy sites in Brittany covered with green algae is 428 ha.year-1 (OEB, 2018). At the same time,
nitrogen produced during grazing and managed on livestock (building, storage and land spreading)
impacts air quality with ammonia (NH3) emissions and contribute to climate change with the production
of greenhouse gas (GHG) such as nitrous oxide (N2O) and methane (CH4). To limit these pollutions,

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various regulatory and incentive policies have been implemented in Brittany.

Table 1: Key figures of agriculture, nitrogen flow and environmental impact in Brittany in 2017

Agriculture(1) 1.63 million of hectares of utilized agricultural area (UAA); 4.4% UUA in organic;32 150
farms;
0.57, 0.61, 0.32 million of hectares of cereal, grassland and forage corn, respectively
Livestock(1) 21 000** livestocks; 2.04 million cattles; 7.3 million pigs; 104 million poultries
Manure 21.6 millions of tons of manure (off pasture) (2); 281 kt of excreted nitrogen(3); 106 kt of
applied nitrogen(3)
Environmental 78.6 kt of NH3(3); 5.9 million eqCO2(4); 33.5 kgN.ha-1 of nitrogen surplus (1);; 31 mg. NO3-
impact L-1 in water(4), 428 ha.year-1 of green algae(4),
(1) Agreste Bretagne (2018) (2) OBB (2017) (3) Citepa (2019) (4) OEB (2018)

2. REGULATORY POLICIES
2.1 National policies

In France, regulatory measures mainly come from European directives, but a national regulation is
applied in Brittany. All livestock farms are subject to national regulations which, according to their size,
are the Departmental Sanitary Regulations (RSD) of the Public Health Code or the regulation of
"Installations Classified for the Protection of the Environment" (ICPE, Code of the Environment) (Loyon,
2018). The main ICPE/RSD regulatory measures impacting the management of organic nitrogen
concern (i) the manure storage capacities that must be sufficient to respect minimum storage times
before land application, and (ii) the spreading of manure which must respect distances from third
parties or is prohibited during certain periods or on certain lands. Spreading distances can be reduced
in case of rapid incorporation of manure and slurry. In addition, manure incorporation on bare soils is
mandatory for farms under ICPE. The manure incorporation is known to reduce ammonia emissions
during application. The treatment of manure can also allow spreading at distances less restrictive than
those enacted by the ICPE regulations (Loyon, 2018).

2.2 European policies

2.2.1 IED Directive
The European standards, transposed into French law, are also applied to the ICPE farms targeted
by the specific directive on integrated pollution prevention and control (known as the IED Directive,
formerly IPPC). These farms are obliged to implement the European reference document, called BREF,
describing the best available techniques (BAT) to be put in place by 21 February 2021 to reduce NH3,
dust and odors from these farms. BATs for reducing nitrogen flows are related to the reduction of
excreted nitrogen from animals (reduction of crude protein content by a balanced nitrogen diet,
multiphase feeding), reduction of ammonia emissions to the building (frequent evacuation of livestock
manure, static or mechanized ventilation, drying of droppings, etc.), storage (pit covers) and spreading
(incorporation).

2.2.2 Nitrates Directive

The Directive 91/676 / EEC concerning the protection of waters against pollution caused by nitrates
from agricultural sources, known as the "nitrates" directive, is of particular concern to Brittany, a region
classified as Nitrate Vulnerable Zones (NVZ) throughout its territory since September 1994. This
Directive is locally declined by prefectural decrees regularly evaluated and revised. To date, Brittany is

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implementing its 6th regional program. These programs set the conditions for spreading and nitrogen
fertilization (maximum threshold of 170 kg N.ha-1). More restrictive measures are applied to certain
zones that carry risks of pollution around drinking water catchments. These zones, newly named
Enhanced Action Zones (ZAR), simplify the multiple pre-existing zonings (Structural Surplus Zones
(ZES), Complementary Action Zones (ZAC), green algae catchment (BVAV), contentious watershed
raw water (BVC). In this ZAR farmers have to limit the balance of the Global Nitrogen Balance to 50
kg.ha-1.year-1 or on average over the last three years.

2.2.3 Water Framework Directive

The Water Framework Directive 2000/60/EC (WFD) requires that Member States ensure watershed
management plans (in France, River Basin Management Plan called Sdage developed for 6 years) and
its accompanying Programme of Measures (PDM). The PDM identify measures to achieve the
environmental objectives of WFD. To fight against diffuse pollution in nitrogen and phosphorus, specific
measures are implemented. For nitrogen, the measures of the PDM are in line with those of the
program relating to the nitrates directive. Since 2011, phosphorus fertilization must be balanced and the
application of phosphate from organic and mineral fertilizers is limited from 80 to 95 kg P 2O5.ha-1 in the
areas covered by Sdage. As the phosphorus nitrogen ratio varies according to the organic matter, this
threshold can also limit the quantity of nitrogen applied.

2.2.4 NEC Directive

The National Emission Ceiling (so-called NEC Directive, Directive 2001/81/EC) sets national
emission ceilings for each Member State for four pollutants, including NH3. In accordance with this
directive, the French government adopted in 2017 a national program for the reduction of atmospheric
pollutants (PREPA). This program lists the emission reduction actions to be strengthened and
implemented by all the sectors concerned. Among the actions targeting the agricultural sector, one
concerns the techniques of spreading of organic products in order to ensure the use of less emissive
materials (trailing shoe, injectors) or the incorporation of manure in a timely manner.

3. INCITATIVES POLICIES

Incentive policies are implemented to meet the commitments made by the state at international,
european, national and regional level for the quality of water, air, energy and climate as well as the
agro-ecological transition.

3.1 Water quality

Brittany has a special place with regard to incentive policies financed jointly by the French
government and local authorities. In order to combat diffuse nitrate pollution and the proliferation of
green algae, surplus nitrogen has been the subject of specific actions initiated since the 1990s. The
State, territorial partners, Water Agency, agricultural and food-processing professional organizations
mobilized with the help of the European because of the threat of European penalties. In order to respect
the limit of 170 kg.ha-1 of the Nitrates Directive for livestock farmers located in ZES, the resorption
actions (manure treatment, reduction of food inputs, reduction of livestock, etc.) were financially
supported from 1994 to 2007 with two national programs for the control of pollution from agricultural
sources (PMPOA). Other incentive programs have been implemented only in Brittany to reduce the
nitrate content of raw water intended for the production of drinking water. From 1994 to 2006, three
Brittany Pure Water (BEP) programs set up contractual actions aimed at agro-environmental diagnostic,
the financing of experimental manure treatment projects, personalized advice and the individual
commitment of farmers to improve fertilization practices. Specific to the proliferation of green algae on

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the Brittany coast, the regional program called "Prolittoral" worked from 2002 to 2008 on 7 watersheds
with preventive actions against nitrate leaks. In 2007, the 7-year Great Project 5 (GP5) integrated the
content of the Prolittoral program to meet the objectives of the WFD. For nitrogen, these different
incentive programs have made it possible to set up advice on fertilization and spreading, nitrogen
balance measurements, agronomic benchmarks and to develop specific tools to involve farmers
individually in changing fertilization practices. Two plans against green algae proliferation (PLAV) in
Brittany have also been developed by the French government. PLAV 2 (2017-2021) follows the analysis
of PLAV1 (2010-2015) and associated recommendations. To limit the flow of nitrogen to the coast, the
PLAVs set a target for the evolution of agriculture towards production systems with very low nitrogen
leakage. This objective must be realized through territorial projects, based on voluntary and contractual,
mainly prevention measures. The 2 plans are implemented in eight bays mainly affected by
eutrophication phenomena which represent 10% of Breton farms, 7.3% of the UAA and 6% of the
population. All territorial projects have expressed targets expressed in terms of nitrogen pressure.

3.2 Air quality

With the objective of the PREPA to exclude the use of the most emissive materials in NH3 towards
2025, various incitative measures have been implemented by the state. Since 2016, farms subject to
IED regulations can receive support for investments to reduce ammonia emissions (diet, building,
storage and spreading). A call for projects "Agr'Air" was launched in 2017 to finance pilot group
operations over five years to test and evaluate the application of agricultural practices beneficial to air
quality. In addition, a national action plan must be prepared in the near future to ensure the use of less
emissive materials (trailing shoe, injectors, manure incorporation).

3.3 Energy Transition and Climate Change

Through its contribution to GHG emissions, the management of organic nitrogen in farms is targeted
by various recent national policies arising from the French strategy for energy and climate. In line with
the French commitments to the European Union and in the framework of the 2015 Paris Agreement,
this strategy, set out in the 2015 Green Energy Transition Law (LTECV) and the 2017 Climate Plan,
aims to reduce greenhouse gas (GHG) emissions by 40% in 2030 compared to 1990 and to achieve
carbon neutrality by 2050 for French territory. For agricultural GHG emissions, the objective is to reduce
them to more than 12% by 2028 compared to 2013 and by 48% by 2050. This strategy for energy and
climate change is based mainly on three documents provided for by the LTECV law: the Multiannual
Energy Program (PPE), the National Low Carbon Strategy (SNBC) and the National Strategy for
Mobilization of Biomass (SNMB). One of the objectives is to reduce the amount of nitrogen fertilizers
and to develop anaerobic digestion in order to integrate 23% of renewable energies in gross final
energy consumption in 2020 and 32% in 2030.

3.2 Agro-ecological transition

Since the end of 2012, the "agro-ecological project for France" articulates a set of public policies,
communication tools and legislative devices in order to reconcile the economic, environmental and
social issues of agricultural practices. Agro-ecology is included in the Future Law on Agriculture, Food
and Forestry of 2014 (LAAF). The project aims to convert more than 50% of farms to agro-ecology by
2025. An action plan composed of sixteen projects is articulated with eight specific plans, some of
which have been launched since 2009. The agro-ecological project also incorporates specific plans,
including those relating to better management of nitrogen by valuing organic nitrogen and developing
on-farm methanisation (EMAA Plan) and the development of organic farming (Program "Bio Ambition
2017", Plan "Bio 2022"), the development of vegetable proteins (PVE, 2014-2020) to promote forage
autonomy and agroforestry.

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4. EFFECT OF POLICIES ON NITROGEN POLLUTION IN BRITTANY

Through the different water quality policies, measures to reduce nitrogen fluxes such as feeding and
fertilization strategies, spreading techniques (in strips, immediate incorporation), improved manure
management equipment has been deployed more widely in Brittany. More recently, the measures of the
different plans of the "agro-ecological project for France" that will impact the nitrogen flow are aerobic
digestion, the feeding of animals raised in organic production. Regulatory actions related to water
quality include the reduction of nitrogen pressure and fertilization equilibrium practices by reducing the
organic nitrogen to be applied by on-farm developments or the implementation of transfer processes or
resorption. The treatment of manure is only mandatory under the Nitrates Directive for farms located in
ZAR. Manure treatment is also mandatory under the Water Framework Directive to ensure an
agronomic balance of phosphorus. Treatment is also mandatory when using manure or digestate from
aerobic digestion as an amendment or organic fertilizer as defined by French standards (Loyon, 2018).
Aerobic digestion is a measure found in the various policies because this treatment makes it possible to
manage nitrogen flows on livestock, reduce GHGs and produce energy. Manure spreading remains the
main mode of organic nitrogen management (Loyon, 2018), but local authorities aim to reach 100 MW
of energy production through the methanisation of manure and other materials now until 2020.
These different regulatory and incentive policies have undeniably made it possible to reduce the
quantities of nitrogen applied in Brittany and the nitrate contents in the water. These decreased from
204 kgN.ha-1 in 2000 to 181 kgN.ha-1 in 2015 for the quantities of nitrogen applied and from 50 mg.L-1 in
2000 to 31.6 mg.L-1 in 2015 for average nitrate levels in Breton waters (Dreal, 2015). Nevertheless,
critics remain strong on the management of organic nitrogen in Brittany. Indeed, the proliferation of
green algae persists (OEB, 2018). For NGOs, the state has failed to meet its obligations as to the
speed of implementation of the measures, regulatory or incentive. It must be emphasized, however,
that the state must continually negotiate with the agricultural profession, which is more or less resistant
to implementing environmental measures.

5. CONCLUSIONS

Brittany is a specific region of France that has been struggling for 30 years against nitrogenous flows
from farms above the agronomic capacity of agricultural soils that have led to pollution of rivers by
nitrates and the proliferation of green algae on parts of the coastline. To combat these two problems,
various regulatory and incentive policies have been set up in partnership between the state, local
authorities and the agricultural profession. Mandatory resorption programs have been set up in the
most sensitive areas for nitrates and green algae. Awareness-raising actions for farmers have also
been implemented. These policies have made it possible to reduce the levels of nitrates but little the
proliferation of green algae. According to the origin of the analyzes (State, NGO, agricultural
professsion), these measures are necessary, insufficient or too restrictive. It is also the same analysis
on air quality policies that specifically target the nitrogen fluxes of farms. On the other hand, more
recently, nitrogen fluxes are indirectly targeted by public policies relating to climate and energy that
have objectives of mobilization of livestock waste.

REFERENCES

Agreste Bretagne (2018). Mémento de la statistique agricole. 17p.

CGDD (2018). Environnement & agriculture Les chiffres clés – Édition 2018. 124p.
DREAL (2015). L'eau en Bretagne. Bilan annuel 2015. 52p.
Gascuel-Odoux, C., Aurousseau, P., Durand, P., Ruiz, L., and Molenat, J. (2010). The role of climate on inter-
annual variation in stream nitrate fluxes and concentrations. Science of The Total Environment 408, 5657-
5666.

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Loyon, L. (2018). Overview of Animal Manure Management for Beef, Pig, and Poultry Farms in France. Frontiers
in Sustainable Food Systems. Policy and Practice Reviews. Volume 2, Issue 36. Published 2018-July-10.
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