Mr. Edward Carr:

A legitimate concern is the impact a further reduction in the derogation will have on generational renewal. Unfortunately, large question marks hang over the future of the next generation. This generation of farmers is well educated on climate change, water quality and the environment. They are embracing new technologies and willing to adapt to change. However, the constant change in policy is not allowing farm businesses time to deliver the improvements in water quality.

Farmers are responding to climate and water quality challenges. By way of example, the application of lime to correct soil pH has increased nationally from over 800,000 tonnes applied annually to more than 1 million tonnes. Furthermore, farmers are making better use of slurry and improved methods of applying it. Currently, 75% of all dairy farmers use low-emission slurry spreading methods. In addition, an increasing number of dairy farmers are incorporating clover and multispecies swards to reduce their nitrogen usage.

The Government and the European Commission must acknowledge that the range of new actions undertaken by farmers will require time to be implemented. In advance of the next negotiations, the Government should prepare a strong science-based document, with EPA input, similar to the marginal abatement cost curve, MACC, for greenhouse gas emissions. A compelling case is needed for the European Commission. The State should map out the most effective mitigation measures on a catchment scale and provide realistic time horizons for the actions adopted by farmers.

The agriculture water quality working group recommends a strong focus on improving slurry storage capacity on farms. While we welcome the current provision of accelerated capital allowances for slurry storage and the intention to provide a separate ceiling for slurry storage under TAMS, additional measures will be needed to de-risk the situation now facing farmers who want to increase their storage and do the right thing. The increased uncertainty over the future of the derogation is a significant blockage to overcome. Increased rainfall due to climate change and a review of slurry storage requirements are also significant factors. The working group has called on the Government to consider all possible ways to achieve this. It has recommended that a 70% capital grant should be available for all farmers investing in slurry storage facilities; investments in slurry storage should be prioritised for fast-track TAMS approvals; planning issues should be dealt with; and access to grant aid for farmers who are not in full compliance with regulatory requirements should be considered for situations where they commit to going beyond the regulatory requirements. ICOS calls on the joint committee to endorse the working group's proposals on slurry storage and for the Government to fund a national slurry storage project through the new climate and nature fund.

The dairy co-op sector has developed a wide range of sustainability initiatives to support their members and farm families, including: long-standing co-op joint programmes with Teagasc that have sustainability as a core element; the roll-out of demonstration or focus farm initiatives under the signpost farm programme; since 2013, the implementation of the sustainable dairy assurance scheme, including carbon footprinting and farmer feedback reports; individual co-op programmes focused on soil fertility, renewable energy, native tree planting and sustainability education and training; since 2018, employment of dedicated sustainability advisers under the innovative water quality agricultural sustainability support and advisory programme, ASSAP; ongoing roll-out of dedicated co-op sustainability programmes with milk payment incentives; and provision of co-funding for the national genotyping programme and development of other animal welfare initiatives.

Co-ops have supported the extension and expansion of the ASSAP. The industry commitment to the programme has trebled in recent years. There are now 42 dedicated ASSAP advisers, of whom 23 are employed by dairy co-ops. The EPA data has shown a net improvement in water quality across the priority areas for action where ASSAP teams are located. This shows that a voluntary scheme, designed and implemented in partnership with farmers, can and does work.

Furthermore, dairy co-ops have brought forward new sustainability programmes to incentivise farmers, designed to enhance the environmental and economic sustainability of their family farms. More co-ops are actively considering programmes for their members.

We acknowledge the importance of compliance and enforcement with respect to water quality. However, we underline the importance of improving awareness of water quality issues at a local and catchment level, providing education and training and the establishment of advisory supports and incentives to deliver long-term improvements to water quality.

Irish agriculture has a strong track-record of key stakeholders collaborating and working together. There needs to be a high priority focus on water quality by all stakeholders to secure the derogation into the long term.

Ireland has a strong research base led by Teagasc, an extensive advisory service and willing farmers who want to do the right thing for water quality and the environment. ICOS believes that in the immediate term, there should be a high priority focus across all advisory services focussed on water quality.

I thank the committee for its time and we look forward to addressing any questions on our opening statement and detailed submission provided to the committee.