Jackie Cahill (Tipperary, Fianna Fail)
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The agenda for this morning’s meeting is the new nitrates action programme. The public consultation for this programme is ongoing and the deadline for submissions is Monday, 20 September. That is why we felt it was appropriate to give farming organisations an opportunity to put their views before the committee this morning.

I welcome the following witnesses to the committee: Mr. Tim Cullinan, president of the Irish Farmers’ Association, IFA; Mr. Paul O’Brien, environmental chair of the Irish Farmers’ Association; Ms Geraldine O’Sullivan, senior policy executive for the environment and forestry at the Irish Farmers’ Association; Mr. Pat McCormack, president of the Irish Creamery Milk Suppliers Association, ICMSA; Mr. John Enright, general secretary of the Irish Creamery Milk Suppliers Association; Mr. John Keane, national president of Macra na Feirme; Ms Gillian Richardson, agricultural and rural affairs policy officer at Macra na Feirme; Mr. Henry O'Donnell, the Donegal national council representative with the Irish Natura and Hill Farmers Association, INHFA; and Mr. Joe Condon, policy adviser at the Irish Natura and Hill Farmers Association.

All witnesses are joining the meeting remotely via Teams. They are all very welcome. I note that representatives of the Irish Cattle & Sheep Farmers’ Association were invited but were unable to attend this morning’s meeting. They have been invited to send in a written submission instead. We have received the witnesses’ opening statements, which have been circulated to members. All opening statements are published on the Oireachtas website and are publicly available.

Before we begin, I have an important notice on parliamentary privilege. Witnesses are protected by absolute privilege in respect of their evidence to the committee. However, if they are directed by the committee to cease giving evidence on a particular matter and they continue to so do, they are entitled thereafter only to a qualified privilege in respect of their evidence. They are directed that only evidence connected with the subject matter of these proceedings is to be given and they are asked to respect the parliamentary practice to the effect that, where possible, they should not criticise nor make charges against any person, persons or entity by name or in such a way as to make him, her or it identifiable. Participants in the committee meeting who are in locations outside the parliamentary precincts are asked to note that the constitutional protections afforded to those participating from within the parliamentary precincts do not extend to them. No clear guidance can be given on whether or the extent to which participation is covered by the absolute privilege of a statutory nature.

I will ask the four organisations to give a five-minute opening statement about where they see the main issues with nitrates and the main points they want to see addressed in the ongoing discussion on the nitrates situation. We will then take questions from members. I call Mr. Cullinan.

Mr. Tim Cullinan:

I compliment the Chairman on organising this event this morning because we are at a crucial time with another submission going in. It is concerning for us that the Department left this submission very late, coming near the endgame. We have to look at the key sector that is going to be impacted by this. Other sectors such as livestock and tillage will be impacted to a lesser extent but we must look at the dairy sector and the investment that has gone into it since the abolition of quotas. Farmers have put in excess of €2.2 billion of their own funding into developing their businesses over the last number of years. Their co-op infrastructure has put in approximately €1.5 billion as well. That is a massive amount of money. Overall, we have continued during Covid and during the crash in 2008 we were the one sector in the country that kept performing. We have exports of €14 billion a year and for every €10 that is exported out of the country, €9 goes back into the local rural economy.

That is what it is about.

We have some key issues on this. First, we must ensure Department officials, when they go back to Brussels, retain the derogation for farmers. It has been around since 2005. It has helped farmers to expand their herds and brought efficiencies to those herds. Many measures have been put in place. Farmers are working to those and we need time to see those measures work.

We have great concern around water quality and the testing of water by the Environmental Protection Agency, EPA. We have been trying to get some of those results. There are testing stations downstream from major towns and cities. We know there are concerns around the water treatment plants in those towns and cities and we cannot be the whipping boys taking the blame for what is going on there. The results downstream from those plants should be made available to us as farmers. We want to be part of the solution here. We want to be able to assess water quality in a proper manner and to see what is going on there.

The second issue I want to raise is the storage and management of soiled water. The practice to date has been that farmers are distributing the soiled water over lands during the winter period. This has to continue. There are 3.3 units of nitrogen per 2,500 gallons where with slurry there are 16 units per 2,500 gallons. There is no comparison whatsoever. It is a practice that was agreed a number of years ago between us and the Department and it needs to continue.

My next concern is around the covering of outdoor storage tanks. This is being done is for abatement on ammonia-----

Mr. Tim Cullinan:

We are moving in the wrong direction there. We are very clear there is no need for covering outdoor storage tanks.

Another issue is the compulsory use of low-emission slurry spreading on farms above 100 kg organic nitrogen. We cannot see the benefit in that. The data equipment has been grant-aided through the targeted agricultural modernisation scheme, TAMS. We all know that if it becomes a legal requirement, it will not be grant-aided. If there is going to be change here, there must be proper grant aid for those measures.

The proposal on slurry closing dates makes no sense, good bad or indifferent. Farmers are grazing their paddocks up to mid-October. At the moment, chemical fertiliser application finishes on 15 September. Farmers have a valuable resource in organic fertiliser. As the Chairman would know himself, if a farmer is to apply organic fertiliser to his paddocks when he is finishing his last round of grazing up to mid-October - we have looked at this - at least 30% more grass will be available for the first round of grazing in the spring without using any chemical nitrogen. It decreases costs coming into the farm and decreases imports into the country. Can anybody explain to me the logic in preventing farmers from using a valuable resource that is readily available on their farms and that they can apply after the last round of grazing? That is essential. This is a red line issue for us.

I understand the Department is looking at the technical tables in the nitrates directive. That is very concerning for us. For any of this process to move forward, we need proper negotiations with the Department, not what we have seen over the past while, namely, putting out consultations without negotiations.

This is not the way we work. As farmers, we are partners in the review and we want to be around the table and negotiating how this is going to go forward and the impact it is going to have on the sector. I ask you, as Chairman of the committee, to bring the findings that will come out of today's meeting directly to the Minister. We spoke to the Minister on this last week. We need cool heads on this now and we need to get a practical solution so that farmers can continue to farm in a very efficient and environmentally-friendly manner.

Mr. Pat McCormack:

I thank committee members for the opportunity to put forward our views on behalf of the ICMSA as we begin to go to print with our final submission for the close of the nitrates review next Monday. I agree with Mr. Cullinan on an awful lot of things. Farmers have invested hugely in the targeted agricultural modernisation scheme, TAMS. It goes back over a decade to the farm waste management scheme where there has been continuous investment, in particular by dairy farmers post quotas. The changes to be implemented leave the sector extremely vulnerable due to the level of debt it carries at this point. I acknowledge that the trend as regards water quality has not been going in a favourable direction for us. Further analysis will show particular areas where the trend is improving. Great credit is due to all the stakeholders involved for their co-operation - farmers, farm organisations, the co-op movement and the advisory authority - in the way the agricultural sustainability support and advice programme, ASSAP, has been conducted. The programme has been conducted in a positive light with a helping hand rather than a stick to beat the farmer. All too often we read about penalising farmers and the ASSAP highlights that a lot can be achieved in a positive light with a helping hand.

As regards the chemical fertiliser register, it needs to be kept as simple as possible for farmers. We deal with Mother Nature and no two years are the same. In the past we have seen years of fodder crisis due to drought and flexibility is needed to accommodate such effects as we move forward.

Compliance is a huge challenge, but rather than promoting additional regulations we need to focus on the existing regulations. There is a need to abide by those regulations in order to see improvements in areas such as water quality and biodiversity in the months and years ahead. Equally, when we talk about those regulations, we need to see the TAMS improve. We all understand the situation. Farmers contact me every day of the week who have applied for TAMS grants and some have even been fortunate enough to get approvals, but their costings are totally out of sync. We need to see the €80,000 ceiling substantially increased to a minimum of €120,000 as we move forward. Huge investment is ongoing on farms and it needs to be supported by TAMS. We fully acknowledge the 60% that is available to young farmers but, given the challenges, 60% must be available to all farmers when it comes to improved compliance for the years ahead. We also need to see an agri-environmental programme available for potentially 70,000 farmers with a minimum payment of €15,000 per farm so that it is an attractive proposition for all commercial farmers. I mentioned the ASSAP, which has been a huge benefit in particular areas and must be rolled out nationwide.

Regarding the proposals on slurry, we must be very conscious that we predominantly represent the dairy farmers of Ireland who have invested substantial sums of money in tanks to accommodate the soiled water. Much of the work in recent years has been grant-aided.

Farmers have invested in tankers and various spray systems whereby a tractor never needs to go into a field to spread soiled water over the entire 12 months of the year. Any change to this would have a substantial implication for the day-to-day running of farms. This cannot be either tolerated or implemented as we move forward because farmers have received grant aid to do the contrary in recent years, to good effect we would have to say. The notion of separating soiled water and slurry on farms, particularly those farms that can accommodate the entirety, is nonsensical. In recent years, there has been more widespread use of the dribble bar and the trailing shoe on dairy farms. From a practical point of view, farmers are adding water. The notion of separating the two and then putting them back together for spreading makes absolutely no sense to practical people on the ground. We encourage the use of low emissions slurry spreading. Equally, we must be cognisant of the 12-month waiting period to purchase tankers or systems. There needs to be a bit of leeway for those farmers who were fortunate enough to get approval but unfortunately will not have the tank within the required period.

Even if the proposal on the banding of cows from a livestock excretion waste point of view were to be acceptable, introducing it within three months is totally out of sync. We need to see the data behind it. There needs to be greater industry discussion on the figures. We have seen organic nitrogen move from 85 kg to 89 kg. This has created substantial pain for farmers. According to our figures and analysis, a farmer with 100 acres and in excess of 6,500 l could potentially lose 18 dairy cows. Ultimately, this could undermine his or her business and would undermine the entire dairy industry if it were to happen. I attended my advisory co-operative board meeting last night. There is huge fear among farmers about what they will be able to do in future. Will they be able to honour their financial commitments as a result of these proposals? The industry is also in fear about whether it will be in a position to get milk in future. We certainly have to see more detail and there has to be far greater industry discussion and input into the figures with regard to banding.

From a nitrogen allowance perspective, no two farms are the same with regard to the ability to grow grass. It needs to be science based. If farmers are in a position to grow significantly more grass or utilise more nitrogen there should be leeway whereby they can be facilitated.

The proposal to reduce fertiliser by between 10% and 15% is of concern regarding our ability to output. What is hugely of concern to farmers, and it is raised at national council time and again, is the soil index, in particular soil index 3 and optimum P levels. We believe soil index 3 should be divided between high and low so farmers can put out more P to keep within the limits. Often, farmers find themselves slipping out of the limits of soil index 3 through no fault of their own. That is just the reality. It is not sufficient from a maintenance perspective. Those at the lower end of the scale should be in a position to spread that bit more P to maintain soil index 3 status.

On the seven-day requirement for tillage ground, we have all seen years with difficult harvests and years with good harvests. We have to be practical. If the nitrates action programme is not practical, it will not be feasible.

We believe a seven-day turnaround for the shallow cultivation of ground is too short a timeframe. It is not physically possible. The manpower is not there.

With respect to phosphorus levels, the Morgan P test is a critical one. It is the most appropriate test. It is important that is maintained in the years ahead.

There is a variety of reasons that farmers could be fortunate enough to have grazing land 30 km away from the base. It could be their mother-in-law's, father-in-law's or they could have been a favourite nephew or niece. We believe that if a farmer has stock on a block of ground 30 km from the base, he or she has a genuine case.

As regards rough grazing, as we head towards the end of the year, there will be a renewal of leases, new leases coming on board and a small number of conacre agreements. Clarity is needed on the definition of rough grazing. We need to know exactly what it is.

Finally, on air quality, the proposal that all slurry from farms stocked at above 100 kg of nitrogen per hectare from 2023 needs to be spread using low emission slurry spreading, LESS, equipment is not feasible. What is needed to achieve that is not there on the ground and will not be there. That is impractical. A more staged approach is needed to deliver on that in the years ahead.

In the overall context, like Mr. Cullinan, we would like there to be greater consultation with the stakeholders on the relevant issues. If it is not practical for what is proposed to happen on the ground, it is not feasible. I look forward to questions from the various public representatives.

Jackie Cahill (Tipperary, Fianna Fail)
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I thank Mr. McCormack. I call Mr. Keane.

Mr. John Keane:

I thank the Chairman and members of the committee for this opportunity to address them and answer any questions they may have. We have consulted directly with our members across the country at different farm walks and events in recent weeks. There is a great deal of concern among our members, particularly young farmers in the dairy industry and livestock sector, about some of the proposed measures and the influence they would have on their businesses based on where their businesses have grown to in recent years. Some of the proposals, essentially, would be a reintroduction of what we previously knew as quotas up to 2015, which we had since the early 1980s. The greatest concern among our members is that their ability to grow their businesses and drive on-farm efficiencies would be impinged on by some of the proposals outlined under the nitrates derogation.

Our members are acutely aware of the importance of protecting water quality and we recognise there has been a challenge in that respect for a number of years. It is important to be cognisant of the role the agricultural sustainability support and advice programme, ASSAP, which was touched on by Mr. McCormack, has in many catchments and its voluntary nature in terms of farmers engaging with it. We are also aware of the local authorities water programme, LAWPRO, which seeks to improve water quality. We seek the roll-out of significant investment across the country to include greater access for farmers to those programmes, more information and more boots on the ground to support those programmes. The more assets and personnel distributed to those programmes, the higher the improvements at farm level, which is important if we are to address the real issues affecting water quality.

Regardless of what measures are introduced, be they measures under the nitrates directive, CAP proposals or eco schemes, our membership stresses that they must be must be complementary to the farming practices and the realities of farming on the ground. We have a pasture-based system in Ireland quite distinct and different from the systems across the EU. The assumption that the principles of agriculture with respect to farming enterprises across the EU are relatable to what happens on Irish farms and in Irish agriculture is simply not reflected in what happens on Irish farms from day to day.

A major issue brought forward by our members relates to farm slurry storage, specifically the need for farmers to separate soiled water from slurry and the recognition that 40% of farmers do not have adequate storage at this time. The introduction of a closed period of a month for the expansion, which is essentially what has been called for, and the introduction of increased capacity for soiled water storage, which has also been called for, would increase the expected storage capacity on the farm by more than 40% in the next 24 months. There is not the capability on the farm to invest in that right now, and nor is there the manpower out there to build such substantial infrastructure on the farm.

Over the past number of months, we have seen the struggles that farmers have encountered when putting up sheds, building tanks and sourcing materials to meet the requirements of the coming winter, not to mention an expansion of upwards of 40% in capacity across all farms in the next 24 months. Also, in respect of introducing these regulations and legislative measures, we have seen that when regulatory requirements are introduced under LESS, grant aid support is no longer allowed. If the 40% of dairy and livestock farmers who do not necessarily have the storage capacity right now are to be given 24 months to become compliant, and up to 40% will be required on top of that again, it will simply not be achievable for farmers out there to do it. Our members are most concerned that the regulations do not make sense and do not reflect the realities of what happens on the farm. This also applies in respect of the proposal around soiled water and the inability of farmers to spread the soiled water after a closed period.

In respect of the efficiency take-up of grass, grass growth rates over the autumn period and the indexes that have been developed - for example, the pasture indexes for the varieties of grass and the extent to which some grass varieties are able to grow over the autumn period - the proposals and the science simply do not talk to one another on the issue. If we are expecting farmers to introduce extended grazing seasons to improve productivity, reduce climate impact and base production off a grass-based system, these proposals simply do not make sense in that context.

On the banding of the livestock, we too would welcome a great deal more consultation, because the impact it is going to have on farmers is significant. It is of great concern to our members. Similar to the point made by Mr. McCormack, some of our members who have been producing over 6,500 l over the past number of years are going to have to reduce their herd size by approximately 20% over the next number of years if the proposal is brought in. Concerns have also been expressed by members that those who are in a certain bandwidth this year - let us say, those who are producing 6,400 l - will be in a higher band bracket next year if they are producing slightly more towards the back end of the year. It is essentially going to be a quota whereby that farmer is not going to want to produce any more because he is reaching the upper limit of that band. There needs to be greater clarification for farmers out there who are making decisions based on how practical it is on the farm.

Our members have also expressed concerns that we are now essentially saying that the dual purpose cow, which historically has had a strong place in Irish agriculture in both beef and milk production, is now being unduly penalised for having a specific genetic make-up. That is a serious concern from our members' point of view.

Overall, from a young farmer's point of view, over €200 million has been awarded to young farmers under TAMS since 2015. It has been used to invest in buildings, slurry storage capacity and other instruments on the farm. These young farmers have taken on this investment with the ambition to improve performance and environmental efficiency and to drive production on the farm. If we are turning around to these farmers and saying, after five or six years of growth, that we will be restricting the ability of their farms to grow and produce in order to meet the repayment capacity and to ensure there is a livelihood for future generations, that is something we need to be hugely cognisant of. Such farmers will come under huge pressure if these measures unduly affect their ability to return a financial reward for themselves.

In the last number of years, we have seen that the dairy industry has become a particularly popular area for young farmers to enter into. If the likes of these measures curtail that and provide a negative outlook for the next number of years if measures of this severity are included, the result will be fewer young people entering the farming sector. Our sector is crying out for young blood across the dairy industry, tillage, beef and all enterprises. These measures, on top of some of the measures which have been suggested under CAP and the lack of ambition we have cited under CAP, are greatly going to reduce the attractiveness of our sector to young people. If our Government and the representatives are serious about ensuring there is a future in our sector for young people, this issue and all the other issues that have been brought to the table in recent months in relation to CAP will have to be addressed.

Finally, I wish to reiterate our commitment to the environment, to improving the environment and to engaging proactively on environmental measures. Our members, as young farmers, are acutely aware of the challenges that are out there in terms of water quality and our environmental impact.

We realise that because our generation of young farmers will be dealing with this for the next 20 or 30 years, the measures brought in must be complementary to farming practices. We believe that they can be, that they can result in improved environmental efficiencies and improvements in water quality, while at the same time driving efficiencies and improvements in financial reward for farmers at farm level. I thank the Chair and the committee members for the opportunity to speak and I look forward to answering their questions.

Jackie Cahill (Tipperary, Fianna Fail)
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I thank Mr. Keane. I call on Mr. Condon from Irish Natura and Hill Farmers Association, INHFA.

Mr. Joe Condon:

I will give the opening remarks and Mr. O'Donnell will come in later on. I thank the committee for inviting us here today. It was short notice. While many of the farmers that we represent operate extensive farming systems, both on hills and low lands, and are currently within the nitrates regulation, the proposed nitrates action programme, NAP, contains elements that are concerning. One issue of concern relates to cattle accessing our watercourses. Currently, only farmers who require a nitrates derogation stocking rate of over 170 kg of nitrogen per hectare or above are required to fence off watercourses at a minimum distance of 1.5 m.

Based on the consultation process relating to the updating of these regulations, the following general points emerged. The requirement to fence watercourses should be extended to all farms. We believe that given the type of land that we are farming that this is not legally or practically possible. All watercourses identified as being at risk from agricultural pressures should be fenced within three years and the measures should be reviewed in future nitrate action plans, NAPs, to effectively determine its impact. While we appreciate the need to protect watercourses where there is an intensive level of agricultural activity, we do not accept that the same measures are required where farmers' activities are low. On this basis, we are recommending that any farmer with a stocking rate at or below 100 kg of nitrate per hectare should not have to fence off watercourses. For many livestock farmers, especially on our hills and commonages, the requirement to fence off these watercourses would, in most cases, force them out of cattle.

On private hill land, much of which has a Natura 2000 designation, those farmers will face enormous costs not just in terms of fencing materials, but also in getting permission, as this is an activity that requires consent. This would require prior planning permission, something that would not be guaranteed. Farmers in commonage would also face similar costs as many commonages are also subject to the Natura 2000 regulations. However, commonage farmers would have an additional concern through possible objections from other shareholders.

The second issue of concern relates to out-wintering of cattle. For many farmers operating on extensive farming systems, this has been an essential part of their ongoing operation, with many of these farmers currently operating all-year round grazing systems. This option must remain part of any future nitrates plan.

A third point relates to additional storage capacity and the possibility of extending the closed period for the spreading of slurry. In relation to storage capacity, this would be reflective of the stocking rate and with regard to extending the closed period, we are not in favour of this.

The recommendation for the proposed NAPs seems to be based on the premise that significant changes are needed, as the current regulations are not delivering to the desired outcomes. However, for the majority of farmers operating under the current regulation, there is a growing sense of frustration, as they see two standards applied. There is also a belief that if the current regulations had been applied without the opt-outs and the blind eye, we would not now have to review and alter them. Any updated plan cannot facilitate further derogations on the exporting of slurry. The rules have to be fair to everyone.

In summary, as detailed, concerns around the possible fencing of watercourses especially on commonages and hill lands are a major issue and something that must not happen. Likewise, farmers who are currently operate all year round grazing must be accommodated. Proper consideration will have to be given to all farmers' stocking rates when accessing storage capacity.

Jackie Cahill (Tipperary, Fianna Fail)
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As Deputies Martin Browne and Carthy have to attend another meeting, I will call on them first. I call Deputy Martin Browne.

Martin Browne (Tipperary, Sinn Fein)
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Go raibh maith agat, Cathaoirleach. I have a quick question for each of the organisations and I will ask the questions in order. If the closed period for the slurry spreading is lifted, as proposed, does Mr. Cullinan have any idea how many farms would be in a position to store slurry, while complying with the new regulations on slurry storage?

What would be the impact on the tillage sector if the slurry spreading period was lengthened? I ask the witnesses to comment on what bearing elements of the nitrates action programme are having on the area of emissions.

In the nitrates action programme, I note the Department is basing its new excretion rate bands on preliminary analysis and regional estimates. The demands based on this will start to come into effect on 1 January. I get very concerned when demands are rushed through based on estimates and preliminary analysis. The ICMSA also noted how quickly it will be introduced and suggested a halfway point of 89 kg of nitrogen per hectare. I am interested to hear the association's views on the banding mechanism and its opinions on how other organisations are settling on the halfway point until further research is done.

Macra na Feirme noted, as did other organisations, that the nitrates action programme omits one key point, namely, the cost to farmers and how farmers will be supported in meeting these demands. Overheads and costs will be considerable, especially for ewe farmers. I am sure this issue came up during the course of the engagements with the Minister. Will Mr. Keane give a summary of the Minister's response and what was Macra na Feirme's reaction to it?

The INHFA expressed considerable concerns about the impact that the requirement to fence all watercourses will have on farmers. Can Mr. Condon expand on that point? Does planning, to which Mr. Condon referred, come into that? What is the situation with hill farmers whose land is different in many ways with regard to watercourses? Mr. Condon raised the issue of excluding commonage land from the draft recommendations and to extend the fencing of watercourses to all farms. Will he also expand on that?

Mr. Tim Cullinan:

I thank Deputy Brown. We have 7,000 farmers in derogation at present. If there are to be changes, obviously all these farmers will be impacted and, perhaps, other farmers outside of this also. A substantial number of farmers may be affected by this. If farmers are to be asked to increase slurry storage again, we have a problem with the availability of builders. Getting a contractor is a major concern. There is a wider issue of labour on farms. This is a major concern for us. Much investment has already been made. For this reason, it is critical that we continue with the system we have.

I stressed earlier that applying organic fertiliser until mid-October is a very effective way of dealing with organic fertiliser coming from farms. We have to continue doing this.

The Deputy raised an excellent point on the tillage sector, particularly in his region of south Tipperary and north and east Cork. A large amount of winter cereal is sown. If we were to have a closing date of 15 September, many of these crops would not even be harvested by then. We hear from the Department that we want to build up organic matter on tillage farms. This is a valuable resource, in particular, from the pig and poultry sector. Traditionally, much of the organic fertiliser coming from these sectors went to tillage farms. Will somebody explain to me how this will work if we are to bring the date back to mid-September? This year was an exception as we had excellent weather. In the normal course, the impact of weather and crops possibly not being sown until the back end of the previous year mean that harvests can run into the first week of October. We have to ensure this window is kept open. We all speak about closing the loop.

We have an excellent example here of where organic fertiliser can be used to grow crops which, in turn, can be used to feed our animals. Somebody has to call a stop to some of these ludicrous proposals that are on the table at the moment.

Mr. Pat McCormack:

I thank Deputy Martin Browne for his question. As I mentioned earlier, we have huge concerns about the bands and the potential for them to go from 85 kg to 105 kg in a very short period. Mr. Cullinan alluded to 7,500 farmers in derogation. The vast majority of them are dairy farmers. There is huge concern. We believe that there needs to be greater stakeholder engagement and discussions. Farmers are adopting best practices. For example, the reduction in crude protein could have a significant impact. We need to see that implemented for a period and to establish facts rather than relying on estimates. There is a substantial gain to be made in reducing the 16% and 18% proteins to 10% and 12% proteins for the dairy animal. It may not be necessary to drive those figures forward to any great extent as the vast majority of the traditional friesian, and the friesian alluded to by Mr. Keane, come very close to the 6,500 l. I refer to the milk processors. As was alluded to at the co-operative meeting in my area last night, they need milk at the shoulders to be economically sustainable. The farmer also needs milk at the shoulders to be economically sustainable. This may drive farmers to be environmentally sustainable and economically vulnerable going forward. We need a lot longer than three months of a lead-in and a lot more discussion on it. We look forward to engaging in that discussion in the months ahead.

Jackie Cahill (Tipperary, Fianna Fail)
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I thank Mr. McCormack and I invite Mr. Keane to respond.

Mr. John Keane:

I thank Deputy Browne for his question, the first part of which was in regard to the young farmers' perspective and the perspective on costs. The biggest concern for our members is in regard to the use of the regulations in this context. In 24 months' time grant-aid support will no longer be provided to a cohort of farmers who do not fall within the requirements. Those farmers who fall outside of the requirements will not be eligible for grant-aid support under the regulations because the regulations state that is law. The concern from our young farmers' point of view is the capacity to meet those requirements in the stated short space of 24 months. A huge proportion of our members have invested significant sums of money under TAMS - €200 million overall in the past five years - in terms of on-farm infrastructures, slurry storage and improving their environmental efficiencies on-farm. Some of them have significant repayments to meet. They are very happy that they will be able to meet those repayments under the current set of proposals to which they are working at farm level, but they are concerned that these proposals, if adopted, coupled with the measures that will reduce the number of livestock numbers which they can carry, which will reduce their productive efficiency, will have a major impact on them being able to meet their repayments right now and may mean they will not be able to meet the requirements suggested under these proposals to make themselves compliant.

From the traditionalist point of view and where the frustration for our members is, over the past number of years the best advice for young farmers starting up has been to invest in cows and grass. That is where our most significant returns are going to come from. That is where the viability of a business will come from. It has been proven that the most efficient and viable place for our farmers to invest is in cows and grass. The question that arises now is, if these regulations are brought in, and in order for a farmer to start-out, he or she must inform us of all the infrastructure invested in, will young farmers have the necessary amount of investment to start-up a business on day one, including investment in all of the slurry storage capacity and compliance measures, as opposed to investing in cows and grass which will provide a return on the investment quite quickly, and investing in all of the slurry storage capacity and the other compliance measures? Our young farmers think that will not necessarily be feasible.

From the Minister's point of view and a costing point of view from within the Department, we would have significant concerns about the proposals in front of us in terms of CAP.

The level of ring-fenced funding being proposed for young farmers under CAP and the Department's lack of ambition in terms of meeting the minimum level that is being set or setting the level higher do not give us great encouragement that the Department will listen to us on measures to support young farmers in this context as we move forward. We had engagements last week and in previous weeks with the Department on this issue. We welcome further engagement with it. While we acknowledge the role TAMS has played over the period of the current CAP, the current proposals, which are indicative of what is going on in CAP for young farmers, and the omission of some key interventions do not inspire us with huge confidence that the needs and requirements of young farmers will be met in other parts of the regulations. That is a major concern from our point of view.

Mr. Joe Condon:

I will put forward a proposal, with the committee's support, for a motion to exclude commonage from the draft recommendations and to extend the fencing of watercourses from bovines to all farms. The justification for this is that commonage is governed by a sustainable stocking rate. It is legally prescribed by the State under commonage framework plans. A sustainable stocking rate is already legally prescribed on these lands, which would justify excluding them. The stocking rate is quite low. I could go into exactly what it is, but in most cases it is one ewe per hectare. If that was transposed to bovines, it would be one bovine per 6 or 7 ha. Stocking rates in these areas are very low, especially in maturer areas. It would be an excessive administrative burden in that situation and there would possibly be regulatory capture in that those farmers would be punished by excessive regulation.

In the case of the Burren, cattle had to be put back onto it again to restore the habitat to a good environmental condition. Losing animals, including cattle, from these areas would be extremely detrimental to those areas. The cost associated with having to fence those areas would be prohibitive. Mr. O'Donnell will comment now as similar types of scenarios will arise in Donegal.

Mr. Henry O'Donnell:

I will more or less reiterate what Mr. Condon said. We are extremely concerned about the impact of some of these actions on uplands, both privately owned and commonage. There have been issues with conservation grazing of these areas and it is becoming more and more apparent that cattle are a very useful tool on uplands. I am involved in a project to reintroduce cattle in a managed way, to remove fire loads, to improve biodiversity and to encourage sheep back onto some areas that, due to past regulation that reduced their numbers, left those areas ungrazeable for sheep.

We are very anxious to ensure the conservation tool of bovines on uplands is not affected by the new nitrates plan. We must have the facility to manage bovines on uplands in a way that does not impose a huge cost on the farmers doing it. In addition to farming these areas and removing fire loads, farmers are performing a public service by keeping uplands in a good environmental and agricultural condition. It would be very unfortunate if new nitrates regulations stopped this activity.

Matt Carthy (Cavan-Monaghan, Sinn Fein)
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I thank the Chairman for his indulgence and for arranging this meeting. I thank the guests for being here. I have a number of short questions because each of the organisations has set out its case very distinctly and raised the concerns of its members very clearly and comprehensively. I have a small number of clarifications or side questions.

I refer to low emissions and slurry spreading. Mr. Cullinan made an important point in respect of the distinction between something being a requirement under law and being an eligible product in terms of TAMS or other grant aid schemes. Could he tell us if he has an idea of the percentage of derogation farmers who currently use the LESS-type machinery? What is the gap that needs to be filled? Does he think that the TAMS programme or another CAP scheme could be utilised in such a way so as to meet the same objective, namely, that all farmers who have land suitable for this type of machinery would use it within the next number of years?

We often come across cases that involve a Department of Agriculture, Food and the Marine issue but fall somewhat under the remit of the Department of Housing, Local Government and Heritage. Do the witnesses have a sense of the interaction between the two Departments and whether the process is suitable for the task, which is obviously very important? We are dealing with crucially important issues regarding water quality, the future of family farms and wider environmental concerns. It is important that we get this right. It would be useful if we got a sense of how the interaction between the two Departments operates and whether there could be a more streamlined or efficient way to deal with this at an official level.

A point of discussion among Macra members has been the role anaerobic digestion currently plays and the potential for it to resolve some of the issues about which the Department has concerns. Are there other mechanisms? Can anaerobic digestion play a bigger part? What would need to happen in order for that to be the case?

Mr. McCormack outlined very articulately the concerns of his members. He gave an example of a 100-acre dairy farm. As we approach all of the other debates, notwithstanding nitrates, the future of CAP and all of the discussions that are taking place, are there supports in place? What would need to happen to allow the farmer he referenced to diversify somewhat? Rather than intensifying a dairy herd, there could be other mechanisms in place in order for that farmer to make a profit and perhaps balance some of the concerns the Departments have in respect of nitrates and emissions.

I do not know if Mr. O'Donnell or Mr. Condon is best placed to answer my next question. I refer to non-derogation farmers. I have strong sympathy for the case Mr. Condon and Mr. O'Donnell have raised in respect of hill farmers and others, in particular commonage farmers who have to adhere to rules that will, in some cases, breach other rules that have been put in place and create a very difficult legal and practical situation. Does their organisation have any proposals in terms of how non-derogation farmers, in particular those on peripheral land, can be supported in improving water quality? We have all been on the hills. The water is the freshest one will come across anywhere. It is really important that we protect that. Are there mechanisms, through agri-environmental schemes or otherwise, to ensure that that water is protected into the future? I again thank the Chair for his indulgence and apologise for having to slip out shortly.

Mr. Tim Cullinan:

I thank Deputy Carthy. Any farmer who is in derogation is using low-emission slurry spreading. From that point of view, the availability of contractors is an issue. I am referring, in particular, to having contractors available within a short window. This goes back to the closed period. The more the period in which organic fertiliser can be applied is shortened, the more a bottleneck is being created. There is already a serious bottleneck. The Deputy is absolutely correct about what he is saying. I stressed earlier what the position would be if the requirement for farmers outside derogation became a legal requirement. Those farmers are not able to apply for grant aid under the current system of TAMS. This is something we will have to revisit because we are expecting more farmers to use the very expensive equipment. Some farmers will want to purchase the equipment themselves to be able to apply their fertiliser at different times of the year. In that case, the matter has to be revisited. In the event that farmers are going to add more storage to their farms, and if this is a requirement, they will not come under the grant aid system either. This has to be addressed also. Along with considering grant aid, we must also consider low-interest-rate loans to help farmers to further develop storage on their farms, if that is going to be required.

On anaerobic digestion, our association has been lobbying successive Governments for years. There has been no indication from the Government that there will be support for farmers in this regard. Bearing in mind the regulation concerning how organic fertiliser is treated within this process, we should consider the circumstances even if there were a renewable heat incentive or tariff for farmers to develop the kind of system in question. Organic fertiliser taken from one farm to a neighbouring farm for processing and then applied on the farm of the farmer who supplied it in the first place is not classified as a mineral fertiliser so it does nothing for the loading on the farmer's farm. If anaerobically digested product taken in from a wastewater treatment plant were spread on a farm, it would be treated as a mineral fertiliser and would not affect the organic loading on the farm. Therefore, there is an injustice right from the very start.

Just up the road from Deputy Carthy, in Northern Ireland, we have seen how the system has developed. We have seen how it developed right across Europe over the years. The Deputy talked about farmers diversifying. This is an area into which farmers should be able to diversify but the proper climate has to be put in place so it will be financially viable and create an extra income for farmers on their farms.

If the Deputy does not mind, my colleague, Mr. Paul O'Brien, chairman of our environmental committee, might want to add to what I am saying.

Mr. Paul O'Brien:

I thank the Chairman for the opportunity to speak this morning.

Following on from the president's comments on anaerobic digestion, 17 million tonnes of oil equivalent are generated from anaerobic digestion at present. That amount is forecast to increase to over 70 million tonnes by 2050. This would obviously give us a massive opportunity to be part of the solution. I am referring to taking products from farms, putting the gas that could be used into the grid and bringing the digestate back to farms. This is part of a closed-loop cycle. There is a fantastic opportunity for us to examine, as a country, the use of all these materials. A fossil fuel would be displaced at the end of the day.

On one or two other issues, I might be pre-empting a question that was touched on earlier. It was about Ag-Climatise now being linked to the nitrates action plan for the first time ever.

Some of the measures spoken about or proposed have little to do with water quality. I also highlight that this is another Government policy being brought in through a nitrates action plan. We find it disappointing that the Department is taking a step to try to bring in two policies for the price of one in this regard.

Mr. Pat McCormack:

Deputy Carthy asked about dairy farmers with 100 cows and their ability to do something else or to make their incomes in some other way. Figures from the Teagasc profit monitors indicate, correctly, that there is nothing to replace cows on dairy farms. That is the reality for many of the more traditional family farm units and it is greatly concerning. We must have an agri-environmental scheme that is attractive to commercial farmers. It could in some way compensate in this regard, but only in some way.

Regarding anaerobic digestion, the co-operative movement is looking at Project Clover and the potential to use the by-products produced by different farms. The major issue with all these alternative approaches is access to the grid at a rate that is financially viable in future. The co-operative movement believes it can potentially use its product to drive its processes and facilities and bring down its energy costs. Mr. Enright might wish to comment more on this point. To answer Deputy Carthy's question in a nutshell, there is nothing to replace the 18 cows in the scenario mentioned. This situation does not have to involve dairy farmers with 100 cows. I do not want that message to be the one taken from this meeting. It could be a case, for example, of a man with 50 cows losing nine of them. That outcome could make him equally or more vulnerable.

Mr. John Enright:

To respond to Deputy Carthy, farmers have been listening for the past 40 years to talk about diversification. Unfortunately, there is no existing alternative enterprise which compares with dairy production. That is the reality. Our response to the people talking about diversification is that they must produce an enterprise model that will allow farmers to make a reasonable living. Unfortunately, it does not exist.

Turning to anaerobic digestion, the economic aspects of that system are not right yet and policy will have to move forward quickly to make such digesters economically viable for farmers. More broadly, we are looking at the nitrates regulations today, Ag Climatise was mentioned earlier and a new Common Agricultural Policy, CAP, is also being introduced. Many farmers who will be expected to meet these new regulations will be the same people who are going to lose substantially under that new CAP programme.

Farmers are becoming frustrated that there is a major focus on environmental sustainability, which is understandable, but seemingly a complete absence of focus on economic sustainability. The economic sustainability of farmers must move up the agenda if we are going to deal successfully with the environmental aspects.

Mr. John Keane:

I thank Deputy Carthy for his question on anaerobic digestion. It is a good one and concerns something that our members have been championing for many years. Some of the biggest issues which have arisen during our meetings include, first and foremost, planning and obtaining planning permission for the building of these facilities. It has become an issue in the context of some of the facilities that have been erected and the elongated process in that regard. Another major issue, as mentioned previously, concerns the feed-in tariff to the national grid not being rewarding enough to justify farmers investing in this process and in this source of power.

Regarding diversification, as Mr. Enright said, we have heard this topic mentioned many times before. However, providing viable diversity options is something that has been slow to materialise.

Turning to the anaerobic digestion, and similar to what Mr. Cullinan said, getting the digestate into and out of the plant in the context of where that sits within regulations has become an issue and is remaining an issue for those supplying and running the plant.

There are a number of issues, therefore, and legislation and investment must catch up with the ambition that is there to invest in these facilities. Our members feel that once proper investment is put in place, these facilities can offer a variable income for some of our farming sectors.

Mr. Joe Condon:

In response to Deputy Carthy's question regarding the agri-environment schemes and protection on commonages, there are advances in precision farming technology such as virtual fencing. This has the potential to be a game changer in rethinking an issue such as organic status on commonage lands. There are some research projects up and running at the moment and three upland locations are testing this technology. Basically, extending this research into an organic European innovation partnership, EIP, would be the next step on commonage land. For anyone who would wish to visit any of these farms to see the technology in practice, it is well worth seeing. I believe there is a difficulty at the moment for commonage farmers to achieve organic status but I think this type of technology will be a game changer and from that, one will get the protection onto one's watercourses directly from a move towards organic on those areas. I hope that answers the question.

Mr. Henry O'Donnell:

I will perhaps add a wee bit to that. Deputy Carthy mentioned the fact that the Department of Housing, Local Government and Heritage has a lot to do with this regulation. From our perspective, what we are scared of happening here, which has happened our farmers before, is that there is a broad brush approach to regulation. That can inadvertently damage our livelihoods by having regulations imposed on us that really do not make sense for our farming systems. To answer Deputy Carthy's question, we would be very concerned that we are possibly dealing with people who do not understand that there are different farming systems and each system should be subject to different regulation.

As regards what Mr. Condon touched on regarding non-derogation farmers, again, it is the same thing whereby we cannot have regulation imposed that does not apply but that is being applied to people who are not causing any damage whatsoever to watercourses. We have mentioned that farmers with different stocking levels and different nitrates levels need to be treated differently. The people designing these regulations really need to be cognisant of this and that there is a huge difference between a derogation farmer and a farmer maybe at 50 kg of nitrogen per hectare. That really has to be taken into account in the regulations.

Jackie Cahill (Tipperary, Fianna Fail)
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I call Senator Boyhan.

Mr. Tim Cullinan:

I thank the Senator. His first comments are where we all need to be on this.

We want farming to be viable as well as sustainable from an environmental, social and economic point of view, obviously. If it is not economical, it will not happen. As I think we all know, this session is very important. We are sustaining an indigenous industry that has supported the country for many generations. We have seen that more than ever in the past year and a half through the pandemic. We were right up there with the first responders. We were producing good, wholesome food, and we all need to remember that. I do not want to stray from the matter of nitrates but I just want to make the point that if we do not produce this good, wholesome food here - the world population is increasing - then it will be produced in a less environmentally friendly manner in another country.

Senator Boyhan spoke about the impact on water quality and costs associated with that. That is my point. A number of the proposed measures in the programme, such as shortening the time during which farmers can get out with their valuable resource of organic fertiliser, will only add more cost, and for no gain at all. Low-emission slurry spreading, to which all derogation farmers are adhering as we speak, is already making an impact. It is getting better uptake in the grass of the nitrogen in the organic fertiliser and better utilisation, so we are doing that already. This goes back to our earlier point that if it becomes a legal requirement for other farmers outside of derogation to have this equipment, it will impact cost again. There has to be grant aid for this; there is no point in saying otherwise.

The fertiliser register is a complete game changer because farmers are business people and they will look at the start of the year and may want to buy their fertiliser for the entire year. Again, there is a lot of negotiation around all this. If we are to go down this road, we have to ensure that it will not impact how farmers conduct their businesses going forward.

Compliance is absolutely something we have been after for years. We have had a review of the appeals office to date, and I know the Minister is bringing in legislation around that. The sooner that happens the better in order that we have an independent person in there as well as farmer representation. What we are looking for is a type of yellow card system whereby inspectors will work with farmers - the carrot more than the stick. That is the way we need to go. Senator Boyhan is absolutely right that what we are doing now is ensuring that this will not impact farmers of the future. Mr. Keane is here. There is a duty on all of us as farm leaders to ensure we create an environment that will encourage young people into the sector.

Excretion rates are another thing that will impact the viability of farms. If we are to move in that direction, excretion rates should be brought in over a long period because they would change how a farmer produces milk. You cannot just turn off or on a switch and change that overnight so, again, that needs to be introduced over a protracted period.

Another area that affects the viability of farms is the notion that you cannot out-winter cattle below 140 kg. That is wrong. This has been done for years and years and we have to look at that area. Our expert on environmental matters, Ms O'Sullivan, is our executive for this area. If you do not mind, Chairman, I would like her to be allowed to come in just for a moment to respond to Senator Boyhan. She might like to raise a few other issues as well.

Ms Geraldine O'Sullivan:

I thank the president. He has covered matters very well. Two of the measures in the programme relating to soiled water storage and the covering of slurry tanks have the highest potential costs, yet the justification on a scientific basis for them is not there, so we have to be very careful. Perhaps these measures are being used for compliance and for the climate and to drive those agendas. I reiterate that we need to focus on water quality and its protection and looking at the cost benefit of the proposals in the programme. That is key to this.

The agricultural catchments programme has shown that programmes like the agricultural sustainability support and advisory programme, ASSAP, which work in collaboration with farmers, have the best impact on water quality, so we need to focus and expand on that, rather than on regulations where the impact on water quality is yet to be proven. It is very evident from this morning that further discussion with the Department and with everybody is needed on these proposals and that greater clarity is provided so there is opportunity for everybody here to discuss and go through the points set out.

On compliance, the last nitrates action programme, NAP, contained four legislative amendments over the period. In 2020 there were three legislative changes, three new statutory instruments, so there have been many changes. We need to ensure that the next programme is in place for the four years because these changes are hard to keep up with and cause compliance issues. We need to know that the programme being negotiated at present will be in place for the next four years and that we work on better communication with farmers, and on better education of farmers, and continue to work with farmers to deliver because that will achieve the objectives, rather than introducing measures that are cost-prohibitive and have not been proven to protect or improve water quality.

Jackie Cahill (Tipperary, Fianna Fail)
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I call Mr. McCormack.

Mr. Pat McCormack:

I thank the Chair. I will go back to sport. If you hear everybody giving out about the referee on a Monday morning, you know that it certainly has not worked, and you know that the referee flashing a yellow card, a red card or a black card is not the way to go. In hurling Fergal Horgan, who refereed the all-Ireland, is regarded as one of the best referees out there, and he does not flash cards. He tries to work with the players and to talk to them on the field. I am relating that to the ASSAP, which I outlined earlier and which involves co-operation and working together to try to improve things. If you look at the water quality trends, the areas where the ASSAP took place and which were fully functional were the areas where we have seen the greatest improvement.

The Senator is quite right about sustainability. Economic sustainability will drive social sustainability because the people will stay in the area and they will be in a position to invest, and invest prudently from an environmental perspective. That has been proven down through the years, with the level of investment that has occurred on farms, albeit with the aid of various schemes, including the farm waste management and the targeted agriculture modernisation scheme, TAMS.

There is a huge aspiration driving the nitrates programme and that aspiration comes from the consumer, the general public, who expects standards to be raised. We have young children and we want to see a great environment for them in the years ahead. The reality of it is that economically it is not sustainable for us into the future, unless we see a degree of food price inflation. I started farming 20 years ago and it is hard to believe that in 1995, when I was a leaving certificate student, my father got as much for his milk in that year as I receive today, and this is considered a reasonably good year from a milk price perspective.

In the very same way we have seen this from a beef farming perspective. Ultimately, the primary producer has been forced to do more, to have more and to become as efficient as possible for an ever-decreasing margin, to the point where margins are virtually eroded.

Chairman, I am not telling you your business. Some other day I would love to have that discussion because it is a discussion that we certainly need to have if we are to deliver economic sustainability for agriculture going forward. Farmers have delivered on the various requests that were made in the past but, as I mentioned earlier, rather than further bureaucracy or further demands put on farmers that there is an educational drive and an awareness campaign, because we need to be coherent in terms of the various regulations that exist at the moment. I believe we will see a significant improvement in water quality with the aid of a nationwide ASSAP as well. If we saw the trend improve year-on-year we would be in a far better place to have an educated and a good debate.

However, without a significant move in the price that the farmer gets for his or her product going forward, all will be challenged over the coming decade.

Mr. John Keane:

I thank Senator Boyhan for his question. On the environmental and economic sustainability and what young farmers want to see, a common sense approach is probably what we would like to see. I gave the example earlier of the reduction in the extension of the closed period. We have the number of farmers who have invested in low-emission slurry spreading being told the scientific benefits of that in terms of uptake, usage of nutrients and the extra production in grass growing and farmers have responded to the this. With regard to the investment by these farmers in grass species which are growing longer into the grazing season and more into the winter and all that science to back up that; farmers have invested in that. At the same time, the proposals are there to reduce the time in which farmers can avail of that equipment and use it efficiently to improve the production of their grass swards on-farm. When you see an approach that does not make common sense and does not make farming sense, that is a real challenge for us moving forward. It is a challenge we have with these regulations, among others.

What we would like to see, from a young farmers' point of view, and what has come back and it has been touched on by both Tim Cullinan and Pat McCormack, is a nationwide extension of the asset programme. There is an external review ongoing on that and an expanding of the local authorities water programme, LAWPRO, and the number of people who are assigned to that.

I want to touch on some of the science that stands up behind the asset programme and some of the misnomers that may be communicated out there. If we look at some of the catchment areas that are managed under that asset programme and the organic load per hectare in some of those catchment areas - some of those areas which are in derogation by 80% or 90% which have high organic loads versus some of the areas which have a lower organic load and the water quality trends in those areas - it is not directly correlated to the organic load per hectare in those regions.

The soil science has an enormous role to play in that as well. There is a significant amount of research to be done in terms of the role the organic end load has to play and also in terms of the soil make-up in those areas and how that interacts with water quality. A simple blunt instrument of saying that "X" proportion of dairy farms in derogation in a certain region will result in poorer water quality is simply not the case and is not factually correct. That kind of rhetoric needs to be addressed.

From a young farmers point of view, we have looked at the success of targeted agricultural modernisation schemes, TAMS, in delivering support for young farmers. We have heard calls from farm organisations for increasing the support and we too echo that. We echo that in terms of the Commission's proposal in the CAP with regard to the upper limit of 80% and we have called on the Department to increase that to 80% for funding under TAMS. If you look at the point of view from the upper ceilings for supports for young farmers set at €70,000 over their lifetime, we believe that will become an issue for them in the years to come, given all of these regulations and expectations which will be placed on businesses and enterprises within the farming sector.

To touch on John Enright's and the Senator's points in terms of the ambition for the environment, the feedback from our members is that the ambition is there on the part of young farmers to meet the environmental challenge, both from a climate-change point of view and the nitrates and water quality point of view. Our young farmers are willing to agree to more ambitious targets and goalposts but the supports and the science must back up that and it must back up the farming practices that complement that because one without the other will simply not work.

Our biggest concern from a young farmers' point of view, and it has been such for a long number of years, is that the impact these proposed regulations will have on farm will result in fewer animals being able to be carried and increased competition within the land market right across the country; that is already a huge issue for our young farmers in terms of access to land. It has been highlighted for many years as one of the most of constraining factors for young farmers starting out and also for a young farmer to grow his or her business. If we are talking about making the land market more competitive out there, we are creating an ever-greater disadvantage for young farmers to be able to access that.

A consequence of that will be the access for young farmers to credit. Because they will not have the profile or portfolio of land behind them to support a sustainable business, their ability to access credit will be unduly hampered. Dealing with these nitrate proposals in a bubble in terms of how they will affect water quality is one approach to take. It is not the approach to take if we are looking after the sector and young farmers in the long term. Proposals here will have long-term implications for what we do on water quality and the environment, for the direct nature and practices on farms and for the environment we create in the farming sector. If we are serious about ensuring young farmers enter the sector in the future, the concerns expressed by our members need to be considered with the utmost seriousness. Otherwise, the trend will continue whereby the number of young people entering the sector will decline and the amount of young farmers entering particular sectors will remain a huge challenge.

Our EU counterparts in Austria, Norway and other regions have put huge supports into encouraging young farmers. Our Government seems to think and the thought within this country seems to be that more of the same will result in more young people entering the sector. Taking this in isolation is fine and we have expressed our concerns about these individual regulations, but the wider context and implications of what is proposed here will have far greater consequences in the next four to five years.

Michael Fitzmaurice (Roscommon-Galway, Independent)
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I welcome the different farming organisations. I ask the witnesses to take note of my questions because I have a few lined up and want their thoughts.

With the new proposals on the litreage - the 92, 102 and 82 - is there a fear in the dairy sector and among the farming organisations that the cow producing less milk and not producing a good calf, namely, the Jersey cow, would be used more, thus ensuring that we would have a lesser quality calf going to the beef sector? What is their solution to prevent that? It is not helping the whole situation. That is question one.

In the line of slurry, I agree. I think it was Mr. Cullinan who talked about a lot of towns having sewage going into rivers. Everyone is getting blamed. They are able to differentiate between human sewage and material from the slatted tanks and from cattle abroad in a field. I agree 100% on that but in the line of grants, do the witnesses agree that there is a lot of gear out there that, unfortunately, farmers have not the time or the tractors to drive? Some 80% of it is done by contractors and there is no grant there for them to help in that situation. That is the question two.

Third, will the witnesses explain their thinking on derogations? Some 123,000 farmers - or 125,000 as we are now up a thousand or two - have to abide by the nitrates regulations. Why are we hung up about 5,000, 7,000 or 8,000 farmers? I heard it said earlier that they could have to reduce or do X, Y and Z. Many farmers have to farm within the rules that are there, not look for a derogation and still survive. I am curious to know why there is such a hang-up about those 5,000, 6,000, 7,000 or 8,000 farmers.

On slurry, and this is coming from a farmer, we have to admit that stuff has gone on over the past number of years that is not helpful to the farming sector. Land has been rented in parts of the country, especially mountains, that is basically covering people. Let no one cod themselves that we will haul slurry 100 miles. I certainly never spread slurry for anyone on top of Benbulbin. What is the witnesses' solution to that?

A 30 km limit is being put in place. In view of the reports that have come out on water quality, do the witnesses think the process should be regionalised? I looked at the situation in the north and north west and it is pretty good. Do the witnesses think it should be regionalised along the lines of, say, the closed season? If you have average or poorish land like that in Leitrim or where I am from - I am no different from anyone else - if there is a wettish year, you are in trouble. Should there not be something in place for people doing the slurry?

Am I right in saying that the Department of the Environment, Climate and Communications has put in a submission to the Department of Agriculture, Food and the Marine in regard to all watercourses? The witnesses touched on that point and I know a bit of about it. Some 80% of land west of the River Corrib in Galway is designated. If you have to go fencing watercourses there, it will cost approximately €7,000 or €8,000. With every environmental issue blocking you, you cannot put up a fence. It will stop farmers from farming. I am wondering what the witnesses' thoughts are on that.

I was interested to hear what was said about slurry storage. I understand 40% of farmers around the country are under pressure at the moment with slurry storage. It could be fewer or more of them. My understanding is that people will not get a grant if they are over the threshold at this time. In fairness, is it not a good idea from the Department, as much as we kick them, to bring in a grant? You can still get a grant for soiled water or whatever water or, say, in the case where the water in a yard runs off where the cattle are walking. Does this not give a back door to solve the problem of getting a grant for the soiled water? I noted comments that were made on this issue during the week and I want to know the witnesses' thoughts on it. It was stated that it does not have to be separated if people have enough area to cover it.

My last question is on anaerobic digesters. Everyone is in favour of them but I understand - the witnesses will correct me if I am wrong - that to bring the product to pellet form, it needs some type of incentive or financial help because it is not cost-efficient at the moment.

Jackie Cahill (Tipperary, Fianna Fail)
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The Deputy had a large number of questions. I will go to Mr. Cullinan.

Mr. Tim Cullinan:

I thank Deputy Fitzmaurice. The Chairman is right that there were a lot of questions. I will go through them as fast as I can. The Deputy's first question was on the excretion rate bands and whether they will force farmers more towards Jersey cows or Jersey-cross cows. That is a decision for farmers themselves. Whatever types of animals a farmer wants to farm, we will leave that decision to him or her. We have a proposal under the CAP reform around the dairy herd. It is a dairy beef scheme. There is a proposal there that if farmers are genotyping their animals, there would be a payment around that. That is an area we are looking at.

The Deputy is right in regard to the water treatment plants. It is a concern, as I said in my opening remarks. There are more monitoring points on rivers and they are being monitored by the EPA. We will ask that those results be put on the table. Anything farmers can do that will help with water quality is welcome. We all want to farm in an environmentally sustainable way. We are up for this challenge and we want to see the results. It is important that we are not held in the dark in this regard. It is fine for one side to be able to see what is going on out there, the impact coming from the large towns and the impact further downstream. It is critical that this information is available to us.

The Deputy makes a valuable point around contractors. Approximately 80% of the work is done by contractors.

Again, that comes back to condensing the closed period, putting more pressure on contractors and farmers being able to get a contractor at the proper time. The Deputy referred to grants for contractors. Most contractors are farmers anyway, so they would be covered in that regard. The Deputy is correct that there are 7,300 farmers in derogation. Those are farmers who have taken on a business, driven it and invested substantial amounts of their own money in it. That opportunity is there for any farmer who wishes to go down that road. The other option is to stay within the 170 kg limit. In certain parts of the country, such as areas where a lot of dairy farms were developed, the availability of land is a factor. That goes back again to the excretion rates we are discussing. If there are changes in that regard, it will put pressure on the availability of land, which will be another cost for farmers. All of this change is not going to bring an environmental improvement. However, it will impact on the cost for farmers as well.

The Deputy referred to the 30 km limit. We need to get practical here. For a sheep farmer in his part of the country, for example, 30 km is nothing. I was in County Donegal recently. I know the Deputy travels up and down such counties. It is about farmers who have small pieces of land in different areas, land which they may have inherited or whatever as a result of family circumstances through the years. The proposal is totally impractical. The Deputy also referred to regionalising the dates. We already have longer closed periods in various areas of the country. That is there already.

Deputy Fitzmaurice spoke about grants for slurry stores. His point relates to the situation if a grant for soiled water were to be brought in. We need to be careful here. There is already a system in place to deal with soiled water. There is are minute amounts of nutrients in that soiled water and if it is dispersed in a proper fashion on farmland, extra storage is not needed. The Deputy is right that it would only put more cost on farmers.

As regards the Deputy's final point on anaerobic digestion, without proper funding or a proper feed-in tariff, it is not going to work. It goes back to the point made by Senator Boyhan. We need to look at this as an alternative source of income for farmers.

Mr. Pat McCormack:

I thank Deputy Fitzmaurice for his questions. He spoke about the dairy breed and the banding. We have significant concerns in that regard. As I alluded to in my opening remarks, we need to see more industry consultation and discussion on this issue. We certainly acknowledge the role of the Department in listening to our dairy calves beef proposal last year. Although it is a pilot programme, it is something that can certainly be built upon in the CAP negotiations that will happen in this country or that are currently ongoing. We believe we can improve the beef going from the dairy herd and have it fit for purpose within the beef herd but that is not the question the Deputy asked. I share his concerns in respect of the banding and the potential to go in the wrong direction from an animal welfare point of view.

As regards the lack of grant aid for contractors, Mr. Cullinan alluded to the fact that the vast majority of contractors would be eligible because they have a herd number. However, the issue is that they are not eligible to receive the VAT back if they obtain the grant. That is something that I am sure the contractors' associations are well able to battle and highlight. Obviously, we need to get as many of those machines on the ground as we can, particularly so that they are available when the closed period begins. That is critical for farmers. That is why we cannot go straight from 170 kg down to 100 kg in terms of mandatory slurry spreading through the low-emission slurry spreading. Those machines will not be on the ground. We believe it should be done in a staged process.

The 7,000 or 8,000 dairy farmers in derogation contribute hugely to the dairy industry. We know what that industry did for the economy during the recession of 2008 and 2009, and what it has done since the abolition of quotas. The dairy industry accounts for a considerable part of our exports. Derogation is important to those 7,000 or 8,000 farmers. It is also important to our dairy processors and rural employment. The spin-off effects of the derogation to rural economies cannot be overestimated.

The Deputy also touched on water quality and slurry storage, and described that 40% of farmers are struggling to have sufficient slurry storage. When I look at the proposals as they come forward, an issue about which I have a considerable concern is that farmers will have to be compliant to qualify for the soiled water, from a slurry perspective. It is necessary that, by whatever means, we put the infrastructure on farms that would mean nobody needs to go out during the closed period.

I agree with what the Deputy said about anaerobic digesters. The issue there is getting it to pellet form. This committee has done work on that issue and listened to various proposals. The reality is that needs to be funded or subsidised, certainly initially, and we hope that, over a period of time, the quantities involved will make it economically sustainable. Mr colleague, Mr. Enright, is anxious to come in on that point and provide some clarity.

Mr. John Enright:

I am concerned that there is an incorrect interpretation of what it means for a farmer to farm under a derogation. The facts are that farmers farming under a derogation are probably the best users of nutrients in this country from the point of view of fertilizers and lime. They are technically efficient and have very good facilities. They are the most inspected farmers out there. There is an impression that a derogation farmer is always a large farmer. Many members of our organisation are farmers with a derogation who milk 40, 60 or 70 cows on full-time family farms. They need a derogation to be economically viable. If we lost that derogation tomorrow morning, the economic viability of those farms would be seriously threatened. It is important to say that the science shows that I can farm environmentally and sustainably under derogation conditions. That is important and we should not forget that point.

Mr. John Keane:

I thank the Deputy for his questions. He asked about the fear that exists in the dairy sector over the selection of cow type and size. An individual farmer's selection of cow type is his or her decision but, on the greater side of things, our members are expressing to us that the proposals on the banding are going to result in farmers choosing cows that are producing less. It may not necessarily be compatible with the dual dairy-beef system we see in many herds across the country at the moment. We have seen the use of the dairy beef index, DBI, over recent years to improve the value of the dairy bull calf. We have, in recent weeks, heard the Moorepark announcement about the development of the sexed semen laboratory, which we welcome and have called for over the course of many years. Our fear around the proposals relate to the issues around the dual purpose cow and issues that have been raised in some circles around welfare and the viability of outcomes and incomes from the beef side of the dairy herd. Those matters are of concern under these proposals. A certain type of cow is being unduly penalised.

The Deputy also asked the use of equipment on farms. Mr. Cullinan and Mr. McCormack addressed the equipment piece of the question but there is a larger piece to consider. The proposals are that the enforcement will mean more farmers will have to spread slurry through thelow emission slurry spreading, LESS, methods. The equipment required is one side of things. One also needs equipment to power the slurry tankers which are used across the country. The 135 tractor one uses for scraping the yard is not going to be able to drive a 2,500 gallon slurry tank for LESS. There are also considerable costs associated with that.

Simply saying that if we get enough grant aid support for low emissions slurry, everything will be fine and rosy is not practical and will not reflect the realities of what will happen on the ground.

Also, I and other young farmers have heard from contractors locally that there is a phenomenal amount of pressure on contractors in the weeks leading up to closed periods are opened and after they are closed. With that in mind, if you lengthen the closed period, that will create an increased amount of pressure on those individuals and on the amount of slurry that will be put out in a short space of time.

On the question in terms of the land rented, within our organisation we have a large proportion of young farmers who are farming at their home blocks, whether that be on dairy enterprises or oral livestock enterprises. Given they are in a highly competitive area for land, they have had to travel significant distances, whether that be more than 30 km or whatever, for out blocks to rear young stock, grow silage and other means of supporting their businesses. I am not sure the spreading of slurry on Ben Bulben is reflective of what is going on throughout the country. From a young farmer's point of view, in areas which are heavily stocked and which are moving forward, and where these are young farmers who are trying to progress their access to land, as I touched on-----

Michael Fitzmaurice (Roscommon-Galway, Independent)
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My question is, does anyone bring slurry 100 miles? We must have a bit of common sense about this.

Mr. John Keane:

The proposal is around whether the land is greater than 30 km away.

Michael Fitzmaurice (Roscommon-Galway, Independent)
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I am asking does anyone bring it 100 miles. It is a straight question. In fairness, that is what I am referring to.

Mr. John Keane:

From our farmers' point of view, the slurry is one piece but the inclusion in the overall farm stocking rate is a very important piece as well. That cannot be forgotten because you will have to rear all your young stock. If that is not being included in your overall on-farm stocking rate, it increases your milking farm stocking rate which will reduce the amount of stock you can carry. That will have an undue effect on the profitability of your enterprise. There are two elements to that too.

In terms of the grant aid support, I definitely welcome grant aid support for soil water storage and for slurry storage. The issue is, in terms of the regulations when they are imposed, those who fall outside the current limits who are under pressure for storage right now will not be able to avail of grant aid support. There are a significant number of farmers who will not be able to avail of grant aid support at the time given their circumstances. They will have to become compliant to avail of that grant aid support and that will put undue pressure on them. It will alienate them and leave them at a significant disadvantage.

On the anaerobic digestion question, something we touched on a little earlier, we would be very much in favour of the development of that. We mentioned the feeding tariff and the need for improvements there around the planning as well. The issue the Deputy brought up around pelleting also needs considerable support to make it viable.

Mr. Joe Condon:

In answer to Deputy Fitzmaurice's question on where this consultation process is emanating from, it is from the Department of Housing, Local Government and Heritage and the person involved is Mr. Jim Coll of the water advisory unit.

On the second point where the Deputy spoke about 80% west of a specific river being a mature area, a possible solution would be that in the old review there was a graduation of levels where you had more intense and less intense. They all had a kilogram of nitrates involved in them, down to extensive farming which, I think, was approximately 140 kg. If there was a conservation grazing category under 100 kg, this would cover many of those areas. This would be a category that would exclude those areas from those fencing requirements where you would have to apply for planning permission on those Natura areas. That is one possible solution.

This review is a two-stage process. This is the second stage. The first stage recommended that the fencing of water courses be extended to all farmers. It is at point 4.4 in the document. This is the last stage. If that recommendation goes through and if it is not pushed back by this committee, it will cause serious difficulties for farmers in those areas who want to continue farming, especially with bovines.

Joe Flaherty (Longford-Westmeath, Fianna Fail)
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I will be very brief as I know there is time pressure. I thank everybody for the excellent information and presentations. There is just another point that is an undue additional pressure on farmers, which is the eight-week period particularly for dairy farmers relating to soil and water. The IFA has done extensive work on this. In December and January, it reckoned on 65 l per cow to wash down the parlour on a daily basis. Currently, it is ten to 15 days for a storage period. As a result, we are looking at something of the order of a sixfold increase in the storage time. Based on the IFA's reckoning, this has the potential to add €20,000 to €30,000 to the operational cost of a farm over the course of a year.

Everybody in the Dáil agrees that we need farmers to be involved in working on environmental challenges. We appreciate that they are probably our foremost environmentalists and we really should not be trying to do anything that puts additional pressure on them. I want to be brief because of the time but the witnesses have clearly looked at what is happening across Europe. What is the norm across Europe in terms of soil and water storage? Have we gone to the extreme with these proposals? What about our contemporaries in France, the UK and other notable dairy producers in Europe? What are their guidelines for soil water storage?

Michael Collins (Cork South West, Independent)
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I will be brief because we are at the end of the allotted time and many questions have already been raised that have been answered. I welcome our guests here today. There are a few Deputies who have been looking at the attack on Irish agriculture over the past number of years. The dairy sector is now under pressure with the nitrates review going on. My worry is that this may lead to a solution that might affect the suckler or sheep farmer being promoted. It looks like the Government and the Department of Agriculture, Food and the Marine are targeting Irish farmers and they could be wiped out of business by them. There was a climate action Bill and a carbon tax; this is one attack on top of another on rural living and Irish farmers.

I have listened to Deputies who told us when the climate action legislation was going through the Houses that we should not worry as it would not lead to a cull of cattle. Look where we stand now, particularly as we have a nitrates review. I can only imagine that if I were in the Brazilian department of agriculture or a Brazilian farmer, I would be rolling around in stitches laughing at the way our Department of Agriculture, Food and the Marine is treating Irish farmers.

I had a few questions but some have been asked already, in fairness. If these nitrates proposals go forward as proposed - they are being railroaded through - are we going to see a reduction in the size of cattle herds on Irish farms?

Tim Lombard (Fine Gael)
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I welcome the witnesses. This has been a positive discussion. The contribution from the farming organisations has been really good and it has helped the debate on the proposals. I will touch on the higher banding of cows in particular, those producing over 650 l of milk. Taking that into consideration, I spent yesterday afternoon at Grange going over the new proposal of calf to beef and how that is interacting with the idea of having a sustainable beef product. The lack of joined-up thinking in bringing in banding for bigger cows and calf to beef research done at Grange in Meath does not seem logical.

What are the views of the witnesses on the matters we must consider in that banding? Should we consider more bands or a different way of measuring? The banding is done in litres of milk.

Most of us traditionally deal in kilograms of milk. We have moved away from the litre model when measuring volumes of cow's milk. Could we debate the issue of how to get an appropriate banding system that would suit the farming regime? There are 22 or 23 different elements within this proposal, which I have read. Most of the farmers who have used low-emission spreading say that it has been a fantastic tool over the past three or four years, since we really got into it. However, the biggest issue for us is trying to get capacity in the sector to deliver that on the ground. I was talking to the company, Lynch and McCarthy, yesterday and it would be 12 months before a tanker would be available if I was to buy one tomorrow morning. That is the lead-in time we are looking at. Could we look at, and talk about, the issue of the time required to get that kind of infrastructure in place?

The targeted agriculture modernisation schemes, TAMS, also play a role. I am open to correction but it is my understanding that this is the last year for derogation farmers. They can no longer apply for support for low-emission spreading. That will have an impact as we try to ensure that there is appropriate equipment on the ground, the knock-on effect of these efforts being that farmers must have capacity to get grants for such equipment. It does not seem to be logical. There are so many issues we need to tie up together in this regard. I will move on to the biggest issue I have come across. It is to be hoped that climate change will be sorted by our scientists but the biggest issue will be the financial infrastructure and the money we need for storage infrastructure for the next decade. How we are going to fund that is a significant issue, which has to be discussed.

For me, soiled water is the biggest issue in town. How the separation of soiled water works, the storage times involved and the four weeks have the potential to affect nearly every farmer in derogation. That is probably the most crucial element of these entire talks. I realise that we are very tight on time so I will leave the witnesses with those thoughts. It is about trying to make sure that these proposals are suitable going forward because, at the moment, that suitability is lacking.

Mr. Tim Cullinan:

I thank the Senator and Deputies. I will respond to Deputy Flaherty first. He is right. We have done costings on this and it could cost the average farmer €30,000, which is a substantial amount of money for something such as soiled water, which there is already a system in place to deal with. If we are going down the road of increasing storage, we are very clear that there has to be grant aid and, in conjunction with that, loans at low interest rates. The Deputy asked about the situation across Europe. The system of farming, and particularly dairy farming, across Europe is more indoors. The impact would be somewhat different across Europe. We must always keep in the back of our minds that the system we have in Ireland, in which cows are out nine or ten months of the year, is an excellent system. It is the most efficient system in the world. If we are to increase the costs in this system by requiring the storage of soiled water when we know it is not having an impact on the environment, so be it.

Deputy Collins is right. There are elements of this, particularly not being able to outwinter cattle on farms with stocking rates from 140 kg N/ha down and having to use low-emission slurry equipment on farms operating above 100 kg livestock N/ha, will result in massive costs for the suckler and sheep sectors. The Deputy is right. We have had the climate action Bill and Ag Climatise. A number of people on this call, including myself, were involved with the development of the agriculture strategy to 2030. We have had all of these reports. We were very clear, particularly in respect of the strategy to 2030. We agreed to sustainable growth in our sector without impacts or serious costs for farmers. What is the point in all of us wasting time being part of putting these reports together if we are not going to follow through on them? We have moved on again and we now have the Department trying to ram proposals down farmers' necks without proper negotiation. I will make my point again, before this goes any further.

For all farmers, and the people who represent them, there must be proper negotiations around all of this because these measures can have a catastrophic impact on farmers.

Senator Lombard mentioned the banding system. Any farmer in derogation across the European Union and other countries already has banding. What we need here is time, more consultation or negotiation, and we need a long period because there is no point changing the practices of farming overnight. A point was also made about the calf and beef, which is an area throughout where attention needs to be brought to bear as well.

In terms of the availability of low-emissions slurry spreading, the Senator is absolutely right that there is a serious time lag with the manufacture of the equipment. Again, we need proper lead-in times for any of these measures and there is no point saying anything else. Again, it was mentioned, and there is no point saying this, but the lack of consultation about the soiled water issue is very concerning for us all.

Jackie Cahill (Tipperary, Fianna Fail)
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I call Mr. McCormack.

Mr. Pat McCormack:

Please do not panic, given that the Chairman and I are from the same constituency I would not like him to think that I had ambitions to become a Deputy.

The challenges that face farmers will certainly keep one occupied. Deputy Joe Flaherty said there has been a six-fold increase in soiled water and there is a necessity to keep it retained. That just highlights the fact that we need substantial grant aid of up to 60% to be made available to all.

Are we saying what was done in the recent past is null and void? The ten to 15 days slurry storage requirement with the sprinkler system or, indeed, any other system was valid at the time. That must remain a compliance-positive story and we cannot in any way be non-compliant because it would be a huge cost. It would also put in question the milk at the shoulder. For the processing plants that is a huge issue.

As regards what Deputy Collins said about the nitrates review and a drop in the size of the national herd, certainly we do not want to see that. In a broader context, our generation must acknowledge climate change but, equally, we must acknowledge any efficiencies in production. When it comes to dairy, beef, lamb and, indeed, cereal production, Ireland is one of the most efficient globally. Quite rightly, and I do not know which member said it, farmers in the MERCOSUR countries must smile when they see how Irish and European farmers are being treated in terms of the potential level of bureaucracy that is being further added with this nitrates review.

Earlier Deputy Fitzmaurice and others mentioned banding. There is huge potential for error with banding. All signs indicate that if one decreased the crude protein percentage in the diet then one will greatly reduce the ambition and the excretory levels that are required or have been mentioned. We believe that farmers endorsed that in 2021. It is a pity that the industry at a wider level did not push it a bit more in 2021 and, indeed, in the previous years.

Obviously the low-emissions slurry spreaders and having a 12-month waiting list is huge. That just shows how out of touch the proposal to move from 170 kg down to 100 kg of a compulsory spread is not a real understanding of the availability of these machines. Again, this is something that needs to be staged and staggered.

Senator Lombard alluded to the cost of storing soiled water. All of these things will increase the cost of production and, ultimately, the primary producer, which is who we are all here to represent. The economic sustainability of that primary producer will be questioned with those various levels of bureaucracy in the years ahead unless we see a substantial food inflationary increase.

Mr. John Keane:

I thank members for their questions which I will try to deal with quickly. The Senator and Deputy mentioned the pressure on livestock and sheep numbers and the potential drop in cattle numbers. The reality of these proposals is that we will have higher numbers of farmers who are in derogation and subject to the regulations that go with derogation. The proposals mean that the amount of livestock that can be carried on an area is reduced. The natural result of that is that farmers will not be able to carry the livestock numbers that they have or had planned to grow to over a number of years. We have young farmers across sheep, livestock and dairy enterprises who have taken over businesses in the last few years, who are farming part-time now but who have an ambition to farm full-time in the next number of years. However, that is dependent on their ability to grow their enterprise in order to provide a viable income.

The expression "intensive farming" is one that farmers and farming representatives need to get away from. Irish farming in the context of world agriculture is not intensive farming. Certainly 4,000 cattle locked into 10 ha in Brazil and stuffed with hormones is intensive farming but ten sheep in the west of Ireland, three livestock in Cork or three cows in a field in Tipperary is not. That reality needs to hit home. These proposals, if implemented, will curtail the number of animals that a farmer can stock which will result in decreases in livestock numbers.

Senator Lombard and Deputy Michael Collins also mentioned the banding of cows. As we highlighted earlier, our concern around the banding of cows is that one particular type of system that farmers are using on farm - genetics which they have selected over a long number of years for specific production reasons, whether that be liquid milk supply contracts or their preferred choice of genetics - is going to be unduly affected. People should not be misled on this. Our economic breeding index, EBI, cow is what our system of genetic benefit has been built on over the past 20 years, since the relative breeding index, RBI, was built on from the year 2000. It has been around improving genetic performance based on EBI. A significant number of cows and herds throughout the country are based on this and are supplying over 6,500 l but will now be unduly penalised. The banding issue is going to need more time and considerably more consultation with farmers. What we are being offered right now is a consultation process but input from the affected farmers and farming organisations will be needed.

On the regulations, we would welcome grant-aid support. We have said, on behalf of young farmers, that the Commission's proposal on CAP of up to 80% is something we would welcome from our Government's point of view. However, the reality is that with the enforcement and the regulations that are proposed, farmers in derogation are unable to access grant-aid support for low emission slurry spreading because it is now a requirement under law. If the regulations relating to slurry storage capacity are brought in under law, farmers will not be able to access grant-aid support if they are not compliant at the time of the introduction of that law. It is going to place a huge financial burden on those farmers. We are talking about a lead-in time of two years but based on the supply from the low-emission slurry spreading, the waiting list of one year and considering how much storage would need to built on farms over the course of the next 24 months and the pressure that suppliers are already under in terms of materials and labour, it is going to be a huge challenge. I do not think the challenge can be met, based on these proposals, if farmers are to become compliant.

In the context of the EU as a whole and the cattle numbers that we have here, we must remain efficient and productive. We must continue, as Mr. McCormack said, to be leaders in terms of our productive efficiencies and consumer image. If one looks at the Brazilians and their proposals for expansion of their enterprises or the Australians and their proposals for expansion, one sees that they fell outside the Paris Agreement in 2015 and are unwilling to attend the COP 26 in Glasgow in November.

However, our Government is choosing to enforce these regulations on Irish farmers, who are among the most efficient in the world. We need to take a step back and see who we are promoting and representing. The pressures being placed on farmers to meet these regulations is significant. Consultation with young farmers in particular is needed because it is they who will be dealing with these regulations.

Mr. Joe Condon:

I will make a couple of comments. It has been identified that the excretion bands will reduce stock. An example was cited of a herd of 50 cows being reduced by nine. No attention has been given to the requirement to fence watercourses being extended to all farms, which will cause a loss of livestock in those areas at the extensive end of the scale. It is difficult for farming organisations to work together when one farmer losing stock is of no interest to other farming organisations and vice versa. If there was a unified approach taken by farming organisations across the board to address both extremes, some headway could be made. Of farmers, 94% are compliant with the limit of 170 kg of nitrates. Above that, farmers will lose stock based on the new banding regulation. There are areas where all farmers could work together in agreement, and this is one of them. The same level of intensity and interest must be shown as where extensive farmers are getting penalised in what is almost a collective punishment, with the teacher keeping the whole class in just because one pupil misbehaved.

Michael Ring (Mayo, Fine Gael)
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I compliment the witnesses, all of whom made good contributions. Will the farming organisations meet the Department of Agriculture, Food and the Marine again? We now know what the problems are, so how do we deal with them? When will the Department meet the farming organisations to see what can be done? This process is being pushed quickly. If the regulations are introduced early next year, I can see there being many problems for farming organisations. Will our committee be inviting departmental officials to a meeting to see what their proposals are?

Jackie Cahill (Tipperary, Fianna Fail)
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I am receiving warnings that we have gone well over time, so we will have the farming organisations respond to the Deputy's questions in writing, if that is okay.

The nitrates action programme is an important issue for all farmers and the agrifood industry as a whole. It could have an economic impact and threaten farmers' viability. Many points have been raised by the organisations, one of which had to do with solids versus volume in terms of milk production and the calves that are produced by dairy cows, which are an essential product for the beef industry. There needs to be clarification on this issue.

Extra storage will be required for dirty water. What nutrients are in that dirty water and what impact could that have on spreading on a 12-month basis? What is the scientific basis for the dates for slurry spreading? Does Teagasc have evidence of growth rates under the current spreading periods? Will there be grants for farmers who are short of storage space or who need to engage in low-emission slurry spreading? There is a need for investment in modern slurry spreading technology to make it viable. This is a matter on which there has not been enough focus in recent years. There is significant technology available. We are considerably behind the rest of Europe in how we deal with slurry on farms. It is not economically viable currently, but that will not be an excuse in future. Modern technology can be used as a tool in tackling climate change and must be embraced.

I thank the four organisations present - the Irish Farmers' Association, the Irish Creamery Milk Suppliers Association, the Irish Natura and Hill Farmers Association and Macra na Feirme - for giving their views. We will discuss this issue in a private meeting and decide how we will proceed in order to make sure the points that were made here this morning are heard in the appropriate areas, that the views of farmers are heard and that the nitrates action programme is fair and achieves the results that we all want to achieve. We should improve our water quality but maintain a sustainable and viable agrifood industry as well. I propose that we have a private meeting about this at 4 p.m. tomorrow.