Mr. Sean McNamara:

I thank everyone for the opportunity to address the meeting. I will give answers to the questions that were sent.

The first question is: what are the anticipated economic effects for the agricultural sector that would result from a further decrease to the nitrates derogation? The effects can be categorised as follows. There is an impact on the profitability of farms that are dependent on derogation from the loss of output. There is also an impact on other farmers who lose rental land to derogation farmers who wish to maintain total output. This is a big problem for active cattle, sheep and tillage farmers who cannot compete with crazy land-rental prices. We need tillage to reduce dependency on imported feed and it is very difficult to operate suckler or dairy farms without straw at calving time. A decrease to 170 kg N/ha would undermine our grass-based system and the competitive advantage we have compared with our EU neighbours. The grass-fed beef protected geographical indication, PGI, is a recognition that grass-based farming is a traditional and valuable system of farming, which brings many benefits in terms of animal welfare, nutrition and better food for consumers. The overall impact will be to undermine our food exports, which were worth more than €16 billion in 2023.

The second question was what the anticipated social effects are for the agricultural sector that would result from a further decrease to the nitrates derogation. It is our view that the reduction from 250 kg N/ha to 220 kg N/ha has been difficult for farmers because plans have been derailed, and this is a source of frustration. A reduction to 170 kg N/ha would likely undermine the prospects for many young farmers who would question the economics of full-time farming. The point is that the social fabric of rural Ireland is certainly threatened by the lack of young people wanting to farm. More and more inspections, complex rules, penalties and poor prospects for viable farming will only make things worse.

The third question is whether it is possible to maintain Ireland’s nitrates derogation at its current level, while ensuring that there are improvements to Ireland’s water quality. It is difficult to make definite judgments on water quality improvements when we still see Uisce Éireann being fined for allowing polluting materials into water catchments after ten years of ownership of water schemes. There is also the challenge that the science is still evolving and farmers are struggling to keep up with changing advice. For example, farmers have invested billions in slurry storage over the past 20 years in line with the scientific advice. However, it is the case that climate patterns, especially rainfall, have led to questions about whether there is enough storage on farms. As it stands, the storage requirements vary from 16 to 22 weeks depending on what part of the country a farm is in. It looks like this is not enough but there are serious questions about how extra storage can be achieved on farms at a time when interest rates are no longer low, construction costs have rocketed and the TAMS system is broken. How can we expect low-income beef and suckler farmers to invest in additional storage when their income is not enough to cover repayments?

The ICSA believes that it is time for the Minister to take on board the recommendations of the agriculture water quality group to increase the rate of grant for slurry storage. A 70% grant was announced in the budget for tillage farms importing slurry. We think this should apply to all farms. It is far more practical, in most cases, to store the slurry where the animals are kept.

We must also question the advice that was being pushed only a few years ago that dairy expansion could be achieved using topless cubicles and stand-off pads. This, in our view, did nobody any favours, because it pushed people to run faster just to stand still and gave a false view of how cheaply milk could be produced. We must also look at the 2018 experience, where farmers were advised to spread chemical nitrogen after the long hot summer and this advice turned out to be a major mistake. It is unfair to blame farmers when the scientific research is not up to date.

However, on a positive note, there is huge commitment by farmers to do more. Fertiliser sales in 2023 are down 33% since 2021, which is very significant. There is also increased use of protected urea. Total nitrogen sales were down to 280,000 tonnes in 2023, beating the climate action plan target for 2030. Farmers have done a lot in reseeding with clover, but there are still gaps in knowledge about how to manage clover and the potential for excess nitrogen in the soil fixed from the atmosphere by clover. In conclusion, if Uisce Éireann could undertake as much work as farmers are doing at pace, then we could certainly see improvements in water quality. However, in our view, the EPA needs to put the same emphasis on Uisce Éireann as it has on farmers.

The fourth question is whether the nitrates action programme is fit for purpose in protecting Ireland’s water quality. In our view, farmers working with Teagasc and initiatives like the ASSAP, and the work being done by the agriculture water quality group, demonstrate huge commitment by the farming sector. The motivation is a commitment to the nitrates action plan and the retention of derogation. However, it must be said that many farmers are increasingly frustrated by more and more complexity and rules which are hard to keep up with, including the deadlines for slurry spreading, the new rules on soiled water, the new rules on trailing shoe, the new maximums on chemical fertiliser, the new fertiliser database, and the risk of overuse of the slurry ration, etc. There are so many rules people cannot keep with.

The fifth question is whether additional supports are required to ensure farmers can be compliant with the nitrates action programme. I will say again that farmers need a far higher grant rate if they are expected to invest in more slurry storage. They also need better research information delivered in a timely manner. In recent times, we are seeing that Teagasc is on a learning curve, which is fair enough, in relation to things such as how to deal with a drought, but it is not fair to expect farmers to know how to deal with adverse conditions when the advisory service is also struggling to cope.

The sixth question is whether additional resources are required to ensure the measures required by the nitrates action programme are immediately enforced. The ICSA is concerned that farmers are facing a massive increase in inspections at a time when the EU is talking about trying to substantially reduce inspections. It is hard for farmers to put up with local authorities quadrupling their inspection numbers when the local authorities had, for many years, a responsibility for water and sewage that was not fit for purpose. Even under Uisce Éireann, the rate of improvement is not good enough, despite the resources available to it. How can we expect farmers to achieve results at pace, when agencies with far more resources are still struggling?

How about penalties that are appropriate in scale for Uisce Eireann? I think farmers are very committed to improvement, but for many, the economics of investment do not stack up without better supports.