Dr. Aine O'Connell:

My understanding is that the model referred to this morning is known as the source load apportionment model.

We understand that looks at the number of cows in an area, attributes an equal volume of nitrogen to each cow and that total input is put in as a cumulative value. It does not account for the management of those cows. If you have one farm with 100 cows managed poorly versus another farm with 100 cows managed better in protecting water quality, my understanding is the latter would have a better impact on water quality and yet the management is not being captured in that source load apportionment, SLA, model. That would be a critical issue because since 2018, more than 30 measures have been introduced into the ntrates action programme, NAP. The programme has got increasingly enhanced. We are now in the fifth round of the NAP and there is a lot of change occurring on farms that needs time to work. We know in an Irish context that it can sometimes take decades for these to deliver.

If the 220 kg N/ha comes in in January 2024, the concern I would have is that if water quality improvements were seen, it would apportioned all to the fact that stocking rate dropped to 220 kg N/ha. It would neither recognise nor acknowledge all the measures that have been taken on farms since 1991 since the directive was introduced, and particularly the measures that have been introduced since 2018, most notably nitrogen banding, which, in itself, is a reduction in stocking rate only introduced in 2023 and which is not even recognised or acknowledged in Article 12 because Article 12 will only allow you compare water quality data from 2022 to 2021.

We are taking on more measures. The fertiliser register is yet to come in. It is meant to come in this year. Banding came in. There are extensions to our closed periods. We are willing to adopt more and engage with that working group to look at alternative measures and solutions to addressing water quality. However, the reduction from 250 kg N/ha to 220 kg N/ha, in our opinion, is a very blunt instrument. The red map shows just how blunt it is because there is a clear misalignment in some areas of the location of the derogation farms and the location of the areas affected by 220 kg N/ha.

We need to look at measures that do not impact income because for farmers to make more changes on their farm they need to have stable incomes, but to look at measures that address water quality in different ways. We need to spend more time on that and get a resolution to the 220 kg N/ha.