Mr. Denis Drennan:

If the Deputy allows me, I will provide five recommendations, rather than four. For the first recommendation, I refer to March 2022 and the interim review that was agreed. Article 12 of that derogation decision was an absolute disaster. It allowed the risk of waters becoming eutrophic to be a term and condition of the scheme. We should be looking at trends, not snapshots. The Department signed up to something that compared water quality in 2021 with water quality in 2022. That is not a trend; it is a snapshot. There is a need to look at trends in water quality over three, five or six years, at least. It is about the timing when that sort of thing is being looked at.

The second thing is that slurry storage is always an issue. Planning and TAMS need to be sorted out. We are in a complete log jam with both of them. We have lost 14 months, with nothing done as a result of issues with planning and TAMS.

The third thing we need is a catchment-by-catchment assessment of what the problems in each catchment are. There is no point in just lumping in that agriculture is 60% of the risk. Every river in the country flows through land so, obviously, what happens on the land is a risk and the land itself is a risk. There is a significant build up of nitrogen in all land and a weather event can release that nitrogen, be it a drought or a flood. We need a catchment-by-catchment assessment that looks at what the problems in the catchment are and the right measure to fix them, be it municipal wastewater, agriculture, industry or septic tanks. Everybody needs their shoulders pointing in the right direction, trying to shove the car up the hill and not having somebody sitting on the bonnet when they are trying to shove it up the hill.

The fourth issue is time. The new measures need time to work. There is a lag time. If you look at the agriculture catchments programme, they will tell you that when you put in a measure, there is a lag of between six months and six years when it comes to a measure showing an effect because the measure will take time to filter through the system.

The fifth thing we need is to eliminate a lot of the bureaucracy involved in agriculture. Twenty years ago, a Teagasc adviser was actually an adviser and not a bureaucrat filling out forms for the farmer. This is the way it has gone. If a farmer wants advice on fertiliser, a slurry application or how to implement the nutrient management plan, the adviser is tied up with derogation for the first two months of the year and for the next three months, he is tied up with basic income support for sustainability, BISS, and complementary redistributive income support for sustainability, CRISS, applications and then he is probably looking at an ACRES open date or a tranche of TAMS coming up. Both the agricultural sustainability support and advisory programme, ASSAP, and the agricultural catchments programme give us the tools and show us the way forward as regards how to improve water quality but that advice needs to be disseminated to farmers about what is the best and the right thing to do in the right place to start delivering results. What we then need is for the farmer to be rewarded for those results. It cannot be a case of "tails, you lose and heads, you win", which is what is happening at the moment. Look at the ASSAP areas where ASSAP has worked and water quality has improved, yet those farmers are still being clobbered with a cut. Even though they did what they were asked to do and worked collaboratively to improve water quality, their derogation was still cut.