Mr. John Keane:

I thank the Deputy for the questions, many of which have been covered. I will not restate some of the points that have been made. On the cross-Border question, this is a major issue in regard to the operating of the market on both sides of the Border to undermine the system of trade that operates on the island. It will be a significant issue, not only for farmers and those operating in the Border counties. It will also have wider implications for costs and trade within the island. It is mentioned in the Bill that fertiliser is recorded at the point of dispatch but there is nothing to say, in terms of measuring that, when it comes across the Border into a farmer's yard.

In terms of enforcement, a farmer may be using the market tools at his or her disposal to get the product at the cheapest price possible. At the point of inspection halfway through the year or in a spot inspection later on in the year, the farmer, who has access to the market on a cross-Border basis, may not have registration documentation for some of the fertiliser used. Where would that leave the farmer in the context of meeting the requirements of the inspection and also the enforcement? With the stricter rules under the nitrates derogation, that also raises the question as to whether farmers who may be involved would essentially lose their derogation given how strict this is.

On medicines, we have received opinions and information similar to the Deputy received in relation to the legal opinion the Department has obtained. We are unsure, obviously, what is contained in that but we recognise that the brakes have definitely been put on the development implication and the procedure that was highlighted to us earlier in the summer as to the steps that would be conducted before 1 January. At this stage, a database must be established that is capable of registering this information. Similarly, suppliers in the market must, as has been highlighted, have product on the shelf for farmers as well.

We are aware of the development of the app the Deputy spoke about. We are aware of similar apps that have evolved and been implemented in other markets across the EU and have worked effectively. There is, however, a role for the Department in terms of certification and validation of any and every form of app that would be used with regard to prescriptions, etc. We are unsure as to the timeframe in which something like that may become effective or deliver for farmers. We would welcome any opportunity for that to be developed if it makes the administrative burden on farmers any easier.

On the availability of fertiliser for next year, what we have heard is similar to what Mr. McCormack described. We have significant concerns about the availability of phosphorus, P, and potassium, K, fertiliser. The breakdown in terms of the fertiliser make-up could have on-farm implications as well for farmers who are operating within derogation but also outside of derogation, given that some straights may not be available. Obviously, farmers using more compound fertilisers will reach their ceilings much quicker than they would if they were using straight fertilisers. That must be taken into consideration in the context of the derogation as well.

The progress we should be trying to make on antimicrobial resistance, etc., will depend on the capability of our analysis to keep up with the demand farmers may have for identification, whether of antimicrobials or any disease risk that might come on farm. We will need significant laboratory analysis to identify the issues. We have seen a lack of investment and the attitude of the Department has been to significantly under-resource that sector in terms of forage and laboratory analysis. We have been looking for increased funding for forage and laboratory analysis for farmers to drive demand for six or seven years, during which there has not been any increased support from the Department. That support will be needed if farmers are required to test for worm or egg burdens for parasites for anthelmics. Investment will be needed to support the roll-out of any such measures as well.