Mr. Barry Fox:

With respect to the questions posed by the committee, IFI comments are as follows. Questions 1 and 2 are outside of IFI’s area of expertise. Question 3 asked "Is it possible to maintain Ireland’s Nitrates Derogation at its current level, while ensuring that there are improvements to Ireland’s water quality?" Given the issues identified by IFI staff on the ground, this would likely require a significant investment in targeted measures including storage infrastructure and capacity combined with detailed nutrient management planning, which should clearly demonstrate a nutrient balance on lands whether on the farm of origin or the lands where organic fertiliser is to be exported. Increased awareness-raising and advice on water quality as well as increased compliance and enforcement activity would be critical.

Question 4 asked "Is the Nitrates Action Programme fit for purpose in protecting Ireland’s water quality?" The programme is fit for purpose in principle but there are challenges to effective implementation that need to be addressed potentially requiring further investment in infrastructure, awareness, compliance and enforcement.

Question 5 asked "Are there additional supports required to ensure farmers can be compliant with the Nitrates Action Programme?" In IFI’s experience, challenges to compliance most often relate to organic fertiliser management and land-use practice. Additional supports could include: supports for investment in storage infrastructure; increased training supports for farmers, contractors and advisers to increase awareness of the value of good water quality, potential value of slurry and soiled water as a fertiliser and the potential negative impacts on the environment of poor practices; support for detailed nutrient management planning with associated soil sampling so landowners are aware of the nutrient requirements in more detail with the aim of achieving a nutrient balance and sustainable management of nutrient load; supports to restrict cattle access to waters for all landowners, not just derogation farmers, and supports to further protect riparian and in-stream habitats through the creation of buffer zones where multiple co-benefits, including biodiversity, climate, water quality, would accrue; associated supports to install drinkers away from watercourses; supports for clear span farm watercourse crossings protecting water quality; and supports to increase awareness of the potential negative ecological impacts of bankside and in-stream works and best practice if the work is required.

Question 6 asked "Are there additional resources required to ensure the measures required by the Nitrates Action Programme are adequately resourced?" IFI notes and welcomes the relevant resources in respect of supports and enforcement outlined by Mr. Bill Callanan of the Department of Agriculture, Food and the Marine at this committee’s meeting held on 6 March.

IFI is also a member of the Environmental Protection Agency's national agricultural inspection programme working group, which is seeking to harmonise inspections between the Department and the local authorities and move those inspections to a risk-based approach.

IFI and its staff are passionate about the protection and preservation of good water quality. This goal is fully aligned with good and high ecological status under the water framework directive and IFI’s statutory remit to conserve, protect and manage the inland fisheries resource in the most sustainable way possible. IFI works with all relevant authorities and stakeholders to maintain high and good status waters where they exist, and to prevent deterioration of ecological status in all waters. As an organisation we are committed to expanding our resources and efforts to restore and protect our environment and enforce legislation where necessary, particularly where it can support the restoration of water quality and aquatic biodiversity. We are equally committed to continued collaboration and partnership with all stakeholders to safeguard the sustainability of Ireland’s fish populations for the benefit of all into the future.

IFI recommends that funding should be made available to install a network of high-frequency real-time monitoring devices for nitrogen and phosphates in catchments at high risk from excessive nutrient inputs. These sensors should have and Internet of things capability, and the real-time data could be made available to farmers and other stakeholders to inform on farm activities.

The protection of diminishing water resources is becoming more complicated due to climate change. Extra provision must therefore be made in the nitrates action programme to adapt to extreme events such as floods, droughts and heatwaves. IFI has initiated a research programme to bridge a knowledge gap related to the impacts of climate change on Ireland’s fish species and their habitats. The project is measuring long-term changes in water temperature and other environmental variables in Irish rivers, lakes and estuaries through a series of over 300 high-frequency data loggers measuring environmental variables every 15 minutes. Advances in mapping tools are making it possible to identify areas in catchments at risk from climate change and other environmental impacts. IFI would encourage farmers to participate in any proposed mitigation activities once the national risk maps from this project have been published. Additional funding for measures for farmers could be targeted in these high-risk catchments.

Along with our colleagues in University College Dublin, IFI is working with the Waters of Life project to develop a bespoke multidisciplinary monitoring programme to detect change and assess the effectiveness of measures to protect and restore high status objective water bodies. IFI would encourage farmers to participate in the Waters of Life voluntary results-based payment schemes as part of this and other EIPs.