Dr. Elaine McGoff:

I thank the committee for the invitation to present here today. I am Dr. Elaine McGoff. I am the natural environment officer with An Taisce. I have a PhD in freshwater ecology. I am joined by my colleague, Ms Phoebe Duvall. I wish to state at the outset that An Taisce supports all of the points and recommendations that were raised by SWAN, but I will focus on agriculture, given that it is the most significant pressure on water quality. I want to address the agricultural measures in the draft river basin management plan, RBMP, and to highlight the critical role that the nitrates action programme, NAP, and good agricultural practice, GAP, regulations play in that. This is the third river basin management plan, and it comes in the midst of an ever-worsening water quality crisis - a crisis that is leading to loss of nature, swimming bans and drinking water contamination. There are a number of catchments in the south and south-east, such as the Barrow, the Slaney and the Lee, which are of particular concern in regard to nitrate pollution from agriculture. More than one third of all river site have increasing levels of nitrate pollution. Clearly, radical changes are necessary in the management of nitrogen inputs to agricultural land to comply with the water framework directive.

On the agricultural measures proposed in the river basin management plan, the RBMP relies heavily on the measures proposed in the nitrates action programme and the good agricultural practice regulations. Beyond that, the other measures proposed are voluntary, somewhat vague, not time-tabled or targeted. This is why the reliance on the measures in the NAP is absolutely critical. If they fail, then the largest pressure on water quality will not be adequately addressed. In reality, if they fail, things will get significantly worse. With that in mind, it should be of grave concern that the Department of Housing, Local Government and Heritage itself has acknowledged that the previous NAP failed because of agricultural industry expansion and poor compliance. To put numbers on that, the dairy herd has increased by approximately 50% since 2010, and artificial fertiliser import has increased by almost 40% in a similar timeframe. This pressure was clearly recognised in the documentation which accompanied the NAP, with the strategic environmental assessment stating: "...reduced stocking rates...offers greater levels of protection to the natural environment and is recommended..." It went on to state that "In a number of cases there is a clear driver from the natural environment for change...but this change has not been adopted within the draft NAP for economic reasons." It is important to note that economics does not come into the nitrates directive, and cannot lawfully be used as an excuse to undermine environmental protection.

We acknowledge some additional measures have been added to the nitrates action programme that will partially address nitrate pollution but, in our view, they are inadequate to tackle it properly. I will give three examples, the first of which relates to the direct nitrate load onto grazing land. Teagasc was asked to conduct some modelling of various scenarios to inform policy decisions to reduce nitrate runoff from agriculture. One of the main drivers that was identified was that cattle urine deposited directly onto fields leads to more than 62% of nitrate loss. It is the main driver of nitrate loss, far above artificial fertiliser and slurry, yet no mitigation for this is provided for in the NAP or GAP regulations. Why is this?

The second measure relates to fertiliser reductions. The nitrates action programme proposes reducing artificial fertiliser loads by up to 15%. While that is welcome, EPA data indicate that in some catchments in the south and the south east, a 50%-plus reduction in nitrogen load will be necessary to meet water quality standards. This raises the question as to what percentage reduction in fertiliser is required to protect water quality in these catchments, and why Teagasc did not model this when it clearly has the capacity.

The third issue to be aware of is compliance. Compliance with the good agricultural practice regulations is recognised by all parties as being low and it has been acknowledged by the Department that fixing it is a key part of addressing water quality declines. However, the NAP does not provide any new enforcement measures for the relevant authorities and proposes open-ended measures such as reviews of local authority capacity and "potentially’" targeting high-risk areas. How can compliance be adequately addressed without tangible, time-tabled measures?

Having laid out the problems, I will propose some recommendations for how agricultural water pollution could be addressed via the river basin management plan. The NAP has been finalised, so we now need to look to the river basin management plan to provide some additional safeguards. The first recommendation is for a catchment or waterbody-based approach. Each waterbody will have only a certain carrying capacity for nutrients, and it is time we took that kind of an approach and figured out what are those thresholds. The second recommendation relates to introducing environmental risk assessments for all intensive farms, including derogation farms, through a permitting or licensing system similar to that by which pig and poultry farms need to abide. Intensification should be permitted only if it can be demonstrated it will not impact on water quality. Third, for existing farms deemed to be a risk, regulatory, voluntary and combined measures should be implemented, including through herd reductions, with compensatory measures put in place to support this where necessary. Most important, we need a solid evidence base to show the measures farmers are putting in place are going to work. We know from the EPA what reductions need to happen and where, while Teagasc can model how we should achieve those reductions. Why has that link not been made? Why are we not joining the dots?

A CSO study last year found 79% of people surveyed put water pollution as their top environmental concern, above all else. The public are not being louder about this because water pollution is often invisible. It is only a matter of time, however, before the public become aware of the scale of the problem we are facing with our water quality, and then they will be looking for answers as to why this was allowed to happen. This is a key opportunity for us to turn things around. The science could not be clearer: we need an ambitious and far-reaching river basin management plan to address this. As I demonstrated, it is not enough to rely on the inadequate nitrates action programme. The river basin management plan we have seen is sorely lacking in ambition and we would very much like it to be addressed.