Mr. Bill Callanan:

Regarding flexibility, the first fundamental principle is that slurry must be considered a fertiliser. From the agricultural catchments programme, which we have supported and Teagasc has implemented over many years, the evidence is quite clear that the greatest loss of nutrient occurs with the application of slurry over the winter period.

To put it in context, before the nitrates regulations, and I have been there from the beginning, less than 5% of slurries were spread at that time of the year. We seem to be fixated on that, although it is a relatively modest volume.

Second, in terms of fertiliser value, a typical four-bay double-sided shed, which every farmer would understand, has about €1,000 worth of fertiliser. The inherent difficulty with applications towards the back end is that one has to ask whether somebody would go out and buy €1,000 worth of fertiliser and spread it on this day of the year, and the answer is generally "No". We have brought up this issue of calendar farming and we discussed it with the Commission at one stage in regard to the question of flexibility. The Commission was quite clear in its direction to us that if one wants to consider flexibility, one has to recognise it cuts both ways, and that could result in the increasing of the closed period instead of decreasing it, if that is what people want. That requires more concrete action. Basically, people have to increase their storage requirement if that is the approach they want to take.

I would caution farmers in general. When we explained to them the reality of the closed period and seeking flexibility, and how it is going to increase if the weather conditions are not right, which would mean farmers have to construct additional storage to cover that, it becomes a more focused conversation.

We structurally changed the system to allow dairy farmers to spread soiled water during winter and to dilute it. However, we still seem to have a problem where farmers are not using as much slurry as they can in the springtime and the summer, which is more ideal than autumn spreading, because, when the growth is not there, they are not getting a return on the fertiliser. The evidence is clear that the spreading of slurry during the winter months leads to higher nutrient loss. I must also confirm that the nitrates regulations are under the Department of Housing, Planning and Local Government, although we give a lot of assistance.

We must also reflect on the fact that our nutrient load has been increasing. Our fertiliser usage in the past three years has been growing and, at the same time, our water quality has been diminishing. We are about 3% down in terms of water quality over the last reporting period and while we do not have data for the most recent couple of years, we do not expect that this trend has been reversed. People have to reflect on that. While I appreciate fully that it is a frustration for farmers, we have to recognise that, within our climate change objectives, we see slurry as a fertiliser best used with the likes of trailing shoe technology and at the most appropriate time of year.