Mr. David Flynn:

Deputy Leddin raised a few things about the comments on the report. I did not see the comments so I will not comment specifically on them, but I will speak about the report and the EPA. I have worked closely with many of the people who produce these reports for many years. They are absolute experts in their area. They are dedicated to the work and to the scientific approach. I encourage everyone to read the report in detail before commenting on it. It is a short enough report and is quite accessible. A supplementary report goes with it, which explains the methodologies behind it and the approach of the EPA.

The nitrates directive is a blunt instrument. It is certainly non-selective. Our mantra as regards the approach to the river basin management plan is "the right measure in the right place". We look at the geology and the practices in an area and select our measures based on that. In areas of nitrates risk, we look at different measures from those we look at in areas where phosphorous is a risk. The issue is over land flow in those areas. In those terms, it is not as selective as some of the other instruments that are available to us locally through the river basin management plan and the implementation of the general water framework directive. That being said, it is a 1991 directive so the Commission is looking at the length of time the directive has been in place. All member states have had to address these issues. That is why we are seeing some of the blunter elements of the directive being used at this stage.

On catchment specific measures, there are approximately 1,000 water bodies where agriculture is one of the significant pressures. Some of those are phosphorous, some are nitrates and some are a mix of both. To its credit, the EPA has included targeting on page 21 of its report that was released last week. In many other reports, it included maps showing those areas. If we were to address matters in the absence of this requirement from the Commission, we would be looking to select measures based on the map on page 21.

Mr. Callanan mentioned ASSAP, which is the free-at-the-point-of-use advice available to farmers. There has been huge engagement in that by farmers. Up to 90% of farmers who were approached have engaged in the process. It is based on local authorities using EPA data to look at the catchments and advisers from ASSAP going into those areas with the knowledge of which specific measure is needed. Now we need to show, beyond that engagement, what measures are being implemented on the ground on farms following the ASSAP engagement and what effect they have on water, by measuring that. As Mr. Callanan said, Ireland has a complex geology and hydro-geology. We have a much more heterogenous landscape than some parts of Europe. Part of the work is communicating that to the Commission. However, as I said, it is a 1991 directive.