Mr. Hugh Farrell:

I am joined by Mr. Eddie Punch, our general secretary, and Ms Nessa Fitzgibbon. I thank the Chairman and committee members for giving us the opportunity to appear before them.

The ICSA is firmly committed to the goal of TB eradication, as is every other stakeholder at the forum. However, we are adamant that TB policy cannot succeed if the collateral damage caused to farmers unlucky enough to find themselves with a TB outbreak is excessive. We do not disagree with the target of being TB free by 2030, but all farmers are entitled to fair play. More importantly, individual farmers cannot be expected to pay an unfair share of the cost of achieving TB eradication.

The Department of Agriculture, Food and the Marine presented a particular view of where the TB programme should go. Some of it is a reflection of the TB experience in Australia. Key ideas put forward by the Department included the highly contentious proposal to put herd TB history on mart boards.

On the farm representatives’ side of the table, the key issues were fair compensation, using the on-farm market valuation system; allowing independent valuers the freedom to do their job; improvements to other elements of the compensation programme such as the hardship grant and the income supplement; a more comprehensive strategy to deal with the role of wildlife, with a particular concern that wild deer were being ignored; improvements in efficiencies in collecting reactors; better communications to farmers on TB outbreaks and also to explain the measures and strategies underpinning the TB programme; and an acknowledgement that the farmers’ share of the TB programme cost was much higher than official figures when the labour costs associated with testing and other tasks related to TB were taken into account.

The key principles that must underpin any TB programme are as follows. Compensation must be fair and reflect 100% of the loss sustained. Wildlife factors need to be fully researched and the results acted on accordingly. All farmers must be treated fairly and those who have outbreaks cannot be isolated or expected to carry an unfair burden. Farmers pay a significant portion of the cost of the programme, but the benefits of TB eradication are much wider and benefit processors, livestock exporters and the economy in general. These benefits should be reflected in the allocation of costs.

The information on TB status is sensitive and can devalue a farmer’s livestock values. Therefore, any sharing of such information must be approached with caution in an era in which data protection standards are becoming much more stringent.

We greatly appreciated participating in the TB forum. There was considerable difficulty moving forward at times. It felt one-sided at times where it was all pain and no gain for farmers. I respectfully suggest that, while lessons can be learned from Australia, comparisons are limited by the scale of difference in farm and herd size, systems of farming, and climate.

The TB forum met seven times and there were also a number of bilateral meetings. Arising from the process, an interim report was submitted to the Minister. Our concern is that this interim report will be implemented while the outstanding issues on compensation, cost-benefit analysis, wildlife, including deer, and how to handle herd categorisation remain unresolved.

The ICSA is supportive of the elements of the interim report that were agreed, including the provision of biosecurity advice, breakdown communications, black spot action plans, and the importance of the badger programme. However, the association believes that the outstanding issues are critical for farmers.

The first outstanding issue relates to wildlife. While the introduction of culling of infected badgers has been the most significant development in TB policy for many years, the ICSA is still uncomfortable with badger vaccination as a medium-term replacement for culling. The association also believes that higher levels of badger testing are necessary.

Our greatest concern is the Department's approach to deer as a factor in TB. Its mantra is that there is no evidence that deer are a significant factor in the spread of disease. Yet deer are undoubtedly a problem in black spot areas such as Wicklow. The prevalence of TB in deer in Wicklow has been shown to be between 8% and 16%, according to two studies. Outside of Wicklow, only three out of 73 deer tested were positive, which is a rate of 4%.

The ICSA cannot understand the Department's reluctance on this issue. We believe it is urgent to conduct targeted research in this area with a view to developing a programme for more sustained deer culling in badly affected areas. Even in Wicklow, where farmers are adamant that deer is a significant factor and where research shows higher than normal levels, the Department's approach is to leave it to voluntary culling, without any official intervention, which is not good enough. The association believes we need urgent research into the role of deer and an appropriate Department-led programme to cull deer if research results warrant it.

Another issue is compensation and cost benefit. The stakeholders’ forum did not resolve outstanding issues on compensation. A proposal on herd information being put up on mart boards was highly controversial. However, the amazing thing is that this proposal came from the Department, which did not seem to realise this meant decimating the value of livestock for farmers who had TB in the past but who are now clear.

No TB strategy will be acceptable or workable unless compensation is seen to be fair. It was unfortunate that any credence was given to the notion that less than 100% compensation was the optimum strategy for TB eradication.

I refer to what the ICSA sees as the main points of disagreement on compensation. There is concern that the Department is putting pressure on the independent valuers and second-guessing their valuations, in addition to the fact that both sides are entitled to appeal. Upper limits on certain categories of breeding stock are unwarranted and lead to unfair outcomes for farmers. The €500,000 spent on sending departmental officials to marts to report on prices was utterly wasteful given that this information is widely available and could be done as a desktop exercise.

Limitations on the supplementary payments are a hardship in certain cases. Income supplement should apply regardless of what proportion of the herd is removed, and the payment should apply from the date of restriction. Pro rata payments should be made in respect of part months for income supplement in order that each day of restriction is paid for. The income supplement rate for suckler cows of €38 and for all other animals of €25.39 needs to be increased significantly. The hardship grant, which is to help with additional winter feed costs, is not payable to any farmer with off-farm income, which we believe is very unfair. The forum has decided to get an independent report on cost benefit analysis of the TB programme and the on-farm market valuation, OMFV element.

The ICSA has outlined its view that farmers, in addition to their €32 million financial contribution, also contribute a massive amount in terms of unpaid labour. We have assessed the labour costs farmers incurred in testing cattle to be in the order of €12.5 million. If bookwork and other TB-associated tasks are taken into account, the figure is even higher. The association believes that Department costs of €26 million can be reduced. Unfortunately, even though we looked for it, we did not get a breakdown of this substantial sum. The association believes much money could be saved in this regard, through, for example, greater use of technical agricultural officers, TAOs, rather than vets, forcing factories to pay full market value for TB reactors that still end up in the food chain, and elimination of unnecessary duplication in staff deployment.

The next issue is herd categorisation. Fortunately, the forum did not accept the idea of putting TB information up on boards. However, we are concerned that herd categorisation needs to be managed carefully to ensure data rights are not infringed upon and that livestock in TB-free herds is not devalued. It is unacceptable that codes are appearing on letters to farmers that indicate their herd risk status when most farmers have no clue what these codes mean. It was agreed to review this, and a new coding system has been suggested, but we remain wary about what use these codes might be put to at a later stage. The ICSA is also dubious about whether it is appropriate to look back seven years or more at a herd that has not had TB since and to infer that such a herd is less secure in terms of its TB risk.

The association is not happy that the interim report is now being taken as agreed without the outstanding issues being resolved. We went to the forum on the understanding that everything would be dealt with and that nothing would be agreed until everything was agreed in full. The ICSA wants the forum reconvened to examine the conclusions of the independent consultants on cost benefit and OMFV. Outstanding issues relating to compensation need to be faced up to by the Minister. Eradication of TB will not be possible unless there is a more robust response to wildlife infection such as the deer problem in Wicklow. I thank members for their time. We are happy to take questions.