What measures does the final PAS provide at the source?

IIn the draft PAS, the problems and objectives are analyzed after an introduction that outlines history and rules. This will lead to the steps that the government intends to take.

Source measures

One package of the proposed measures is the so-called source measures. The government aims to achieve some of its objectives with a series of measures aimed at achieving the emission reduction at source. These source measures will affect all livestock farmers.

tipper loaders

The first category that will be affected are the so-called peak loaders. Point loaders are companies (livestock farms, slurry processors, industrial point sources, etc.) whose emissions have a disproportionate impact on the protected nature in the vicinity. As a threshold, companies that contribute more than half of the critical deposit value of the most sensitive habitat are considered here. The livestock farms with such an effect score were previously referred to as the so-called ‘red companies’.

The draft PAS stipulates that the stable emissions from these peak loaders must be stopped by 2025. In other words, these companies must stop keeping animals by the end of 2025. For this forced shutdown, the government provides financial compensation through the so-called flanking policy. Top loaders that voluntarily stop by 2025 will also receive higher financial compensation (20% if they stop in 2023, 10% in 2024).

Pigs and poultry

As with cattle, general measures have been laid down for pigs and poultry, which will apply to all livestock farmers in Flanders. Specifically, the draft PAS stipulates that pig and poultry holdings must achieve a 60% reduction for pigs and poultry still housed in non-AEA stables (non-ammonia emission stables). This reduction must be achieved at barn level and in relation to the emissions in 2015.

The draft PAS leaves to some extent open to how this emission reduction is to be achieved. The draft PAS literally states that where possible, the reduction targets are achieved with investments in the most modern techniques, and that where necessary and / or desired (this is described as a choice for the company) this can also be done with a reduction of number of animals or a combination of both. However, it seems impossible to achieve the full 60% reduction in emissions from pigs or poultry with the most modern techniques. This is also seen where the draft PAS already presupposes a reduction in the number of animals as a result of these source measures.

In addition to these mandatory generally applicable measures, the draft PAS also includes a voluntary measure, in particular a voluntary cessation of a pig holding. In 2022, a notice of termination (at farm or barn level) will be launched for all pig farms with an effect score of over 0.5%. We work with a fixed budget that is awarded to the candidates who sign with the highest effect score. The fees are as follows: fattening pigs 154 euros; wound 900 euros; demolition fee (calculated at 100%) of 40 euros / m².


For cattle farming, the draft PAS contains a mandatory reduction of 15% for beef and dairy cattle and a mandatory reduction of 20% for fattening calves. Once again, this reduction must be achieved in relation to emissions in 2015. The sub-sectors dairy cattle and beef cattle must both achieve a reduction of 15% compared to the reference year 2015, which corresponds to a reduction effort of 7.7 compared to the situation in 2019.% for beef cattle and 23.7% for dairy cattle.

Correction mechanism

The draft PAS also includes a correction mechanism for small and organic farms. Certain small and organic farms will exceptionally be exempted from the generic measures taken. Small businesses that have an annual emission of less than 500 kg of ammonia and a power score lower than 0.025% are exempt from the mandatory generic nitrogen reduction percentages. However, these companies need to take other appropriate measures. Organic enterprises with an impact score between 0.025 and 1% are exempt from the mandatory reduction percentages, but must implement the measures from the PAS list for the relevant sector that can be incorporated into the ‘biospecifications’. Organic farms with an impact score of more than 1% must achieve the general reduction percentages.

Voluntary termination

For livestock farms with an impact score higher than 20% (the so-called ‘dark orange’ farms), and where the permit has not yet expired, a voluntary company cessation scheme will be temporarily launched via a call in 2023. Here, too, financial compensation is provided through the accompanying policy, which gets higher the earlier you stop. The voluntary cessation is not limited to pigs, but will also apply to cattle and poultry.

Zero fertilization

The next PAS initiative is the introduction of zero fertilization from 1 January 2028 at all green destinations in the special protection zones. Green destinations include all the area designations ‘reserve and nature’, ‘forest’ and ‘other green’.

Fertilizer treatment

Reducing emissions from slurry processors is another PAS measure that is included in the draft. This will be achieved through the mandatory use of (air purification) techniques to reduce ammonia emissions and the legal establishment of design and operating conditions for usable air scrubber systems.

Nutrient quotas

The existing system of emission allowances (NERs) will also be adapted. The growth system provided that the fertilizer treatment is stopped and removed from the fertilizer order. This is already partly in force because the possibility of obtaining new NERs through fertilizer treatment has been phased out since 1 January 2022.

In addition, a system is being developed to skim off the sleeping NERs. The cream measure is aimed at all NERs that were not filled with animals on January 1, 2022 within the last 3 years. A margin of 10% is maintained on the completed or active NER, to catch fluctuations in the barn occupancy. Dormant NERs obtained at the first allocation of NERs in 2007 and which have remained in the company since then are non-refundable. Sleeping NERs, which have been traded since 2007, are bought at 1 euro per. NER.


Any interested party can submit comments and objections to any of these measures until June 17, 2022. This can be done by sending an email or letter to your local council. Late submissions and objections will not be considered.

Jan Opsommer

In a subsequent contribution, we will discuss the assessment framework that is included in the design of the final PAS. In future, this assessment framework will have to be applied to each new permit, both for any request for renewal of an existing permit without renewal and for any request for renewal of an existing permit.
standing permit
or when requesting a completely new permit.

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