Mr. Denis Drennan:

Maybe a little bit of understanding is needed as to why the derogation was cut. It was not cut just because of nitrates in the water. It was cut for four reasons. It was stated that there were nitrates in a catchment above 50 mg/l, and there are hardly any parts of the country at that. It was stated that there was an increase of nitrates in the water. If you look at the results from the agricultural catchments programme, which is monitoring the water coming out of certain catchments every ten minutes, they have seen over the last 14 years that if you get a drought or a flood, it can increase the nitrates by up to 5 mg/l. What we were judged on between 2021 and 2022 - it was not a trend but a snapshot between two years - is that if there was an increase of 1 mg/l, your catchment failed, even thought a drought or a flood could cause 5 mg/l of a change. There was actually very little of the country caught on higher nitrates in the water. The two big ones that caught the country were eutrophication, which is very small in the country as well, and "at risk of becoming eutrophic", which was the biggest one. That is the one that caught nearly the whole country, not excessive nitrates or an increase in nitrates. "Increased nitrates" is very unfair because any sort of weather event could cause that.

"At risk of becoming eutrophic" is the judgment that has really caused the problem in most of the country, and that is why cutting the derogation was so unfair. The terms and conditions that were signed up to included a cut from 250 kg N/ha to 220 kg N/ha. If there is one thing we need to make sure of, it is that we do not sign up to something like that again. It is complete unfair and totally unrealistic on farmers.