Mr. Pat McCormack:

I thank committee members for the opportunity to put forward our views on behalf of the ICMSA as we begin to go to print with our final submission for the close of the nitrates review next Monday. I agree with Mr. Cullinan on an awful lot of things. Farmers have invested hugely in the targeted agricultural modernisation scheme, TAMS. It goes back over a decade to the farm waste management scheme where there has been continuous investment, in particular by dairy farmers post quotas. The changes to be implemented leave the sector extremely vulnerable due to the level of debt it carries at this point. I acknowledge that the trend as regards water quality has not been going in a favourable direction for us. Further analysis will show particular areas where the trend is improving. Great credit is due to all the stakeholders involved for their co-operation - farmers, farm organisations, the co-op movement and the advisory authority - in the way the agricultural sustainability support and advice programme, ASSAP, has been conducted. The programme has been conducted in a positive light with a helping hand rather than a stick to beat the farmer. All too often we read about penalising farmers and the ASSAP highlights that a lot can be achieved in a positive light with a helping hand.

As regards the chemical fertiliser register, it needs to be kept as simple as possible for farmers. We deal with Mother Nature and no two years are the same. In the past we have seen years of fodder crisis due to drought and flexibility is needed to accommodate such effects as we move forward.

Compliance is a huge challenge, but rather than promoting additional regulations we need to focus on the existing regulations. There is a need to abide by those regulations in order to see improvements in areas such as water quality and biodiversity in the months and years ahead. Equally, when we talk about those regulations, we need to see the TAMS improve. We all understand the situation. Farmers contact me every day of the week who have applied for TAMS grants and some have even been fortunate enough to get approvals, but their costings are totally out of sync. We need to see the €80,000 ceiling substantially increased to a minimum of €120,000 as we move forward. Huge investment is ongoing on farms and it needs to be supported by TAMS. We fully acknowledge the 60% that is available to young farmers but, given the challenges, 60% must be available to all farmers when it comes to improved compliance for the years ahead. We also need to see an agri-environmental programme available for potentially 70,000 farmers with a minimum payment of €15,000 per farm so that it is an attractive proposition for all commercial farmers. I mentioned the ASSAP, which has been a huge benefit in particular areas and must be rolled out nationwide.

Regarding the proposals on slurry, we must be very conscious that we predominantly represent the dairy farmers of Ireland who have invested substantial sums of money in tanks to accommodate the soiled water. Much of the work in recent years has been grant-aided.

Farmers have invested in tankers and various spray systems whereby a tractor never needs to go into a field to spread soiled water over the entire 12 months of the year. Any change to this would have a substantial implication for the day-to-day running of farms. This cannot be either tolerated or implemented as we move forward because farmers have received grant aid to do the contrary in recent years, to good effect we would have to say. The notion of separating soiled water and slurry on farms, particularly those farms that can accommodate the entirety, is nonsensical. In recent years, there has been more widespread use of the dribble bar and the trailing shoe on dairy farms. From a practical point of view, farmers are adding water. The notion of separating the two and then putting them back together for spreading makes absolutely no sense to practical people on the ground. We encourage the use of low emissions slurry spreading. Equally, we must be cognisant of the 12-month waiting period to purchase tankers or systems. There needs to be a bit of leeway for those farmers who were fortunate enough to get approval but unfortunately will not have the tank within the required period.

Even if the proposal on the banding of cows from a livestock excretion waste point of view were to be acceptable, introducing it within three months is totally out of sync. We need to see the data behind it. There needs to be greater industry discussion on the figures. We have seen organic nitrogen move from 85 kg to 89 kg. This has created substantial pain for farmers. According to our figures and analysis, a farmer with 100 acres and in excess of 6,500 l could potentially lose 18 dairy cows. Ultimately, this could undermine his or her business and would undermine the entire dairy industry if it were to happen. I attended my advisory co-operative board meeting last night. There is huge fear among farmers about what they will be able to do in future. Will they be able to honour their financial commitments as a result of these proposals? The industry is also in fear about whether it will be in a position to get milk in future. We certainly have to see more detail and there has to be far greater industry discussion and input into the figures with regard to banding.

From a nitrogen allowance perspective, no two farms are the same with regard to the ability to grow grass. It needs to be science based. If farmers are in a position to grow significantly more grass or utilise more nitrogen there should be leeway whereby they can be facilitated.

The proposal to reduce fertiliser by between 10% and 15% is of concern regarding our ability to output. What is hugely of concern to farmers, and it is raised at national council time and again, is the soil index, in particular soil index 3 and optimum P levels. We believe soil index 3 should be divided between high and low so farmers can put out more P to keep within the limits. Often, farmers find themselves slipping out of the limits of soil index 3 through no fault of their own. That is just the reality. It is not sufficient from a maintenance perspective. Those at the lower end of the scale should be in a position to spread that bit more P to maintain soil index 3 status.

On the seven-day requirement for tillage ground, we have all seen years with difficult harvests and years with good harvests. We have to be practical. If the nitrates action programme is not practical, it will not be feasible.

We believe a seven-day turnaround for the shallow cultivation of ground is too short a timeframe. It is not physically possible. The manpower is not there.

With respect to phosphorus levels, the Morgan P test is a critical one. It is the most appropriate test. It is important that is maintained in the years ahead.

There is a variety of reasons that farmers could be fortunate enough to have grazing land 30 km away from the base. It could be their mother-in-law's, father-in-law's or they could have been a favourite nephew or niece. We believe that if a farmer has stock on a block of ground 30 km from the base, he or she has a genuine case.

As regards rough grazing, as we head towards the end of the year, there will be a renewal of leases, new leases coming on board and a small number of conacre agreements. Clarity is needed on the definition of rough grazing. We need to know exactly what it is.

Finally, on air quality, the proposal that all slurry from farms stocked at above 100 kg of nitrogen per hectare from 2023 needs to be spread using low emission slurry spreading, LESS, equipment is not feasible. What is needed to achieve that is not there on the ground and will not be there. That is impractical. A more staged approach is needed to deliver on that in the years ahead.

In the overall context, like Mr. Cullinan, we would like there to be greater consultation with the stakeholders on the relevant issues. If it is not practical for what is proposed to happen on the ground, it is not feasible. I look forward to questions from the various public representatives.