Mr. Michael Moroney:

I thank the Chairman and members for giving us the opportunity to appear before them.

The Association of Farm and Forestry Contractors in Ireland, FCI is run by contractors for contractors. We define a land based contractor as a rural based professional company which is working on behalf of third parties to provide machinery services in the production of arable crops, livestock and forestry and the maintenance of local authority green spaces and hedgerows. It provides mechanisation services which employ skilled operators and use state-of-the-art modern equipment in a sustainable way for financial reward. Most of the time contractors carry out their activities in rural areas, but this does not exclude operations in urban areas and cities such as the maintenance of green spaces and engaging in earth moving activities. Thanks to their expertise and access to advanced technology, they have become key players in the agriculture sector and amenity and forest management.

The FCI has a membership database which includes over 500 legitimate farm and forestry contractors, representing 70% of the land based rural contractor businesses in Ireland. Farm contractors seasonally employ close to 10,000 people who operate high technology agricultural, forestry, earth moving and amenity specific machines.

Our members all work with the soil in moving it, planting in it, fertilising crops that grow in it and harvesting. In that sense, FCI land based contractors are true "soilmates". They support and promote the highest levels of safety in operating farm, earth moving and forestry machinery while on public lands and or in the fields.

Much attention has been paid in the recent past to tractor testing. Research data indicate that tractors are involved in just 1% of all road traffic accidents in Europe and that 69% of these incidents involve tractors more than 12 years old. In Ireland the Road Safety Authority's breakdown of serious injuries by road user type between 2010 and 2012 showed that 0.9% occurred in incidents involving tractors and other vehicles. The 2008 to 2012 vehicle factors report, published in 2016, showed that in 983 fatal collisions, 17, or 1.3%, of the 1,245 vehicles involved were tractors which were among the oldest vehicles measured at the time. They are not typical of the tractors used by FCI farm contractors. Commercial vehicles accounted for more than 15% of all fatal collisions. All of these vehicles are subject to roadworthiness testing. FCI land based contractors are already self-assessing the safety of their tractors in Irish conditions and they are not a significant cause of road collisions.

We are concerned that there has been no consultation on the proposals to introduce tractor roadworthiness testing with land based contractors, even though the proposed legislation will impact on our members more than on farmers because of the size and modern nature of tractors in their fleets. Contractor-owned tractors are not even involved in farm accidents to the same extent as farmer-owned tractors as contractors need to have their machines in top condition all of the time to ensure they are working to the maximum available hours dictated by our variable weather conditions. The proposed tractor NCT will add significant costs for land based contractors in Ireland. Apart from the strict new proposed compliance costs, there will be huge depreciation costs incurred when there is no specific need for to do so. The FCI is calling for clarity on the proposal and the Minister to invoke the option of seeking an exemption from the proposed testing legislation in the Irish market. The United Kingdom has opted to avail of the exemption.

The recent legislation includes a limit of a radius of 100 km for tractors from their base of operations. Many modern tractors are required to transport farm and forestry machines and farm produce over greater distances, where the use of a truck would not be practical or economical owing to the relatively low value of the goods in transit such as straw. The FCI is calling for this limit to be raised to 180 km. Given where he comes from, I am sure the Chairman is aware of the need of many farmers to buy straw from places in east Cork, which is well in excess of the 100 km distance limit. That is why it will impact on them.