Mr. John Keane:

I thank the Chairman and members of the committee for this opportunity to address them and answer any questions they may have. We have consulted directly with our members across the country at different farm walks and events in recent weeks. There is a great deal of concern among our members, particularly young farmers in the dairy industry and livestock sector, about some of the proposed measures and the influence they would have on their businesses based on where their businesses have grown to in recent years. Some of the proposals, essentially, would be a reintroduction of what we previously knew as quotas up to 2015, which we had since the early 1980s. The greatest concern among our members is that their ability to grow their businesses and drive on-farm efficiencies would be impinged on by some of the proposals outlined under the nitrates derogation.

Our members are acutely aware of the importance of protecting water quality and we recognise there has been a challenge in that respect for a number of years. It is important to be cognisant of the role the agricultural sustainability support and advice programme, ASSAP, which was touched on by Mr. McCormack, has in many catchments and its voluntary nature in terms of farmers engaging with it. We are also aware of the local authorities water programme, LAWPRO, which seeks to improve water quality. We seek the roll-out of significant investment across the country to include greater access for farmers to those programmes, more information and more boots on the ground to support those programmes. The more assets and personnel distributed to those programmes, the higher the improvements at farm level, which is important if we are to address the real issues affecting water quality.

Regardless of what measures are introduced, be they measures under the nitrates directive, CAP proposals or eco schemes, our membership stresses that they must be must be complementary to the farming practices and the realities of farming on the ground. We have a pasture-based system in Ireland quite distinct and different from the systems across the EU. The assumption that the principles of agriculture with respect to farming enterprises across the EU are relatable to what happens on Irish farms and in Irish agriculture is simply not reflected in what happens on Irish farms from day to day.

A major issue brought forward by our members relates to farm slurry storage, specifically the need for farmers to separate soiled water from slurry and the recognition that 40% of farmers do not have adequate storage at this time. The introduction of a closed period of a month for the expansion, which is essentially what has been called for, and the introduction of increased capacity for soiled water storage, which has also been called for, would increase the expected storage capacity on the farm by more than 40% in the next 24 months. There is not the capability on the farm to invest in that right now, and nor is there the manpower out there to build such substantial infrastructure on the farm.

Over the past number of months, we have seen the struggles that farmers have encountered when putting up sheds, building tanks and sourcing materials to meet the requirements of the coming winter, not to mention an expansion of upwards of 40% in capacity across all farms in the next 24 months. Also, in respect of introducing these regulations and legislative measures, we have seen that when regulatory requirements are introduced under LESS, grant aid support is no longer allowed. If the 40% of dairy and livestock farmers who do not necessarily have the storage capacity right now are to be given 24 months to become compliant, and up to 40% will be required on top of that again, it will simply not be achievable for farmers out there to do it. Our members are most concerned that the regulations do not make sense and do not reflect the realities of what happens on the farm. This also applies in respect of the proposal around soiled water and the inability of farmers to spread the soiled water after a closed period.

In respect of the efficiency take-up of grass, grass growth rates over the autumn period and the indexes that have been developed - for example, the pasture indexes for the varieties of grass and the extent to which some grass varieties are able to grow over the autumn period - the proposals and the science simply do not talk to one another on the issue. If we are expecting farmers to introduce extended grazing seasons to improve productivity, reduce climate impact and base production off a grass-based system, these proposals simply do not make sense in that context.

On the banding of the livestock, we too would welcome a great deal more consultation, because the impact it is going to have on farmers is significant. It is of great concern to our members. Similar to the point made by Mr. McCormack, some of our members who have been producing over 6,500 l over the past number of years are going to have to reduce their herd size by approximately 20% over the next number of years if the proposal is brought in. Concerns have also been expressed by members that those who are in a certain bandwidth this year - let us say, those who are producing 6,400 l - will be in a higher band bracket next year if they are producing slightly more towards the back end of the year. It is essentially going to be a quota whereby that farmer is not going to want to produce any more because he is reaching the upper limit of that band. There needs to be greater clarification for farmers out there who are making decisions based on how practical it is on the farm.

Our members have also expressed concerns that we are now essentially saying that the dual purpose cow, which historically has had a strong place in Irish agriculture in both beef and milk production, is now being unduly penalised for having a specific genetic make-up. That is a serious concern from our members' point of view.

Overall, from a young farmer's point of view, over €200 million has been awarded to young farmers under TAMS since 2015. It has been used to invest in buildings, slurry storage capacity and other instruments on the farm. These young farmers have taken on this investment with the ambition to improve performance and environmental efficiency and to drive production on the farm. If we are turning around to these farmers and saying, after five or six years of growth, that we will be restricting the ability of their farms to grow and produce in order to meet the repayment capacity and to ensure there is a livelihood for future generations, that is something we need to be hugely cognisant of. Such farmers will come under huge pressure if these measures unduly affect their ability to return a financial reward for themselves.

In the last number of years, we have seen that the dairy industry has become a particularly popular area for young farmers to enter into. If the likes of these measures curtail that and provide a negative outlook for the next number of years if measures of this severity are included, the result will be fewer young people entering the farming sector. Our sector is crying out for young blood across the dairy industry, tillage, beef and all enterprises. These measures, on top of some of the measures which have been suggested under CAP and the lack of ambition we have cited under CAP, are greatly going to reduce the attractiveness of our sector to young people. If our Government and the representatives are serious about ensuring there is a future in our sector for young people, this issue and all the other issues that have been brought to the table in recent months in relation to CAP will have to be addressed.

Finally, I wish to reiterate our commitment to the environment, to improving the environment and to engaging proactively on environmental measures. Our members, as young farmers, are acutely aware of the challenges that are out there in terms of water quality and our environmental impact.

We realise that because our generation of young farmers will be dealing with this for the next 20 or 30 years, the measures brought in must be complementary to farming practices. We believe that they can be, that they can result in improved environmental efficiencies and improvements in water quality, while at the same time driving efficiencies and improvements in financial reward for farmers at farm level. I thank the Chair and the committee members for the opportunity to speak and I look forward to answering their questions.