Mr. John Keane:

I will try to address some of the issues that were raised. Regarding the scope of the Bill and its provisions on veterinary medicines, the number one issue we see concerns the implications around the data that are created, who has access to them and for what purposes. There is reference in the scheme of the Bill to access to the database being given to "such other persons specified by the Minister". As we are aware from the conversation we have had since 5.30 p.m., there is a concern this may include various interest groups with non-relevant knowledge of the sector. The information and data contained within the database could be used against farmers in respect of what they have been doing with veterinary prescriptions and veterinary medicines.

There is an omission in the scheme of the Bill. It mentions sharing data with the likes of Bord Bia for the purposes of inspections relating to that body's quality assurance schemes. However, no consideration is given as to what the implications or consequences might be for failure to comply. Is it Bord Bia that will enforce those requirements or will they be enforced through the regulation itself? There are similar concerns regarding the effort to move the sector forward in terms of improving the overall health of our herd, which Macra na Feirme has supported for many years and continues to support in the context of this Bill, in order to reduce our dependence on, and usage of, certain medicines. However, there is no mention within the scheme of sharing relevant information with our national health bodies, whether that be the Irish Cattle Breeding Federation, ICBF, which is developing genetic testing to improve the genetics of the herd, which is a measurable trait genetically verified within our economic breeding index, EBI, and also within the indexes of beef, or the Animal Health Ireland programme, which is charged with reducing the incidence and occurrence of disease within animals. There is an omission in terms of requirements for sharing these types of data.

The second point raised was around market competition. There is concern about the burden that is being placed on veterinary practitioners. A lot of practices around the country are quite small, particularly in rural areas. Many of our members have noted that veterinary practitioners in some areas now have limited staff who work only certain hours. We all recognise, however, that farming operates on a 24-hour basis. The increased burden that is going to come on those practices in regard to labelling, premises-keeping and record-keeping will be a significant additional time requirement. The overall context to keep in mind when we speak about vets and the supply of large-animal vets into the sector is that there are about 75 vets trained in Ireland annually in the one veterinary medical school we have in the country. We must bear in mind the age profile of the vets we currently have. The number who are leaving the sector due to retirement or because they are entering into small-animal practices for various reasons is in the region of 250 to 300. At the moment, we are exporting people and then importing back the education they have received abroad for four to five years. There is significant work to do in that regard, similar to the generation renewal point we have made many time in respect of farms. There is a significant issue that must be addressed in terms of providing places for veterinary practitioners in more than one veterinary college in the country.

The issue of parasite control was raised and the question of the duration of prescriptions for parasites and also for antibiotics. There is ambiguity as to what should happen in the case of an outbreak of a disease such as cryptosporidiosis, for example, in a dairy or beef herd in springtime. When there is such an outbreak, as we know, all the animals within the group must be treated, whether or not they are showing symptoms, because the likelihood is they are all going to be infected.

What would be the application of this proposed Bill regarding the outbreak of a disease like that in a group of animals where the likelihood is that they would all become infected over time? That is the example relating to cryptosporidiosis.

In terms of the general scheme, it is noted that everybody taking part in 2023 must voluntarily register. A number of users of fertilisers are not herd owners, herd keepers or landowners. They include parks and GAA facilities. What is the proposition for dealing with those small-scale users? We have exemptions for small-scale users of pesticides and herbicides. What is the proposal here in terms of the proposed Bill?

In terms of the fertiliser Bill being used as a baseline to monitor sales and potentially reduce fertiliser usage over time, we are in a period of high input prices and high fertiliser prices. This year is an example. I hear many stakeholders and many people working in the sector championing this year as being a year in which fertiliser sales will reduce. We obviously support the reliance on that but looking at PastureBase Ireland figures, the average tonnage and across hectares on farms on PastureBase is down between 1.5 tonnes and 1.7 tonnes, which, depending on the farm in which you are operating, is a 12% to 18% reduction of annual tonnage grown. If you are at optimisation of that, that is a 12% to 18% reduction of your livestock on that farm.

In terms of enforcement and creating baselines, it is important to recognise where we have been historically in the context of the baseline established under existing Acts with regard to environmental assessments. Other environmental targets are set on the baseline of 2018.