Mr. Michael Moroney:

I thank the committee for the opportunity to address it this evening. I will give a summary of our opening statement.

First, what is a land-based contractor? The Association of Farm and Forestry Contractors in Ireland, FCI, land-based farm and forestry contractors are professional sole traders and companies working on behalf of third-party farmers to provide services for arable crops, livestock, forestry and local authority green spaces. They provide agricultural, forestry and landscape mechanisation services employing skilled operators, using the state-of-the-art and modern equipment in a sustainable way for financial reward. Their machinery investment delivers economies of scale for farming, providing practical and sustainable efficiencies to support farmers and the Irish food industry as a world leading, competitive quality food producer.

Farm and forestry contractors provide the bulk of mechanisation services to the Irish farming, accounting for a contracting sector turnover of more than €700 million. Our members play an important role in providing cost-effective and efficient services to Irish farmers and forest owners and support Ireland’s position as a world leader in the production and marketing of low-carbon, high-quality, sustainable and traceable food and wood products in a clean environment.

In practical and measurable terms, the 1,000 farm and forestry contractors now listed on our database each work across an average of three farms per day. This amounts to about 18,000 interactions each week of the working season. Given a working season of about 30 weeks, that equates to about half a million interactions between farmers and their contractors in Ireland each year. That, in a sense, explains just how connected our FCI members are to Irish agriculture. Policymakers need to be aware that without the essential input of farm and forestry contractors, the Irish agrifood and forest production systems would simply not exist.

Farm and forestry contractors employ more than 10,000 people in Ireland in rural areas, operating high-technology and agricultural-specific machines. These machines consume more than 350 million l of agricultural diesel annually, which is about 62% of all agricultural diesel consumed in Ireland. They do that across a fleet of about 25,000 tractors and an additional 5,000 power machines.

Just to put it into context, contractor machines harvest over 90% of the national grass and maize silage crops and manage the handling and spreading of over 50% of animal manures produced on livestock farms. In forestry, their machines prepare lands for planting, construct the forest roads and harvest the nation's entire timber crop. Farm contractors are the dominant providers of slurry spreading machinery systems and their equipment applies the bulk of the 40 million tonnes of animal manures produced annually on Irish farms.

Since the low-emission slurry spreading, LESS, grants were made available, more than 8,000 machine grant applications have been paid out, which equates to more than €55 million paid to farmers for 20% of the potential work output, while contractors, doing most of this work, have been specifically excluded from the targeted agricultural modernisation scheme, TAMS, grants. Despite this, Teagasc research has shown in 2020 that only 3% of slurry is spread through LESS systems. We accept that this has increased significantly since then.

We are aware from the capital-intensive investments now being made by our FCI members in new tractors and equipment systems that digitalisation is creating unprecedented amounts of data. Our members believe that technological innovation and precision agriculture have the potential to improve the productivity, quality, traceability and sustainability of the Irish agrifood system. Our members are already using machines fitted with such technology, including big data and machine learning systems that can bring about fundamental shifts to dramatically alter how we produce food products on Irish farms and how we manage organic waste in a sustainable way. This now provides opportunities for the further development of shared data-driven decision-making on Irish farms and in Irish forests that can only be commercially viable and sustainable through collaboration and the economies of scale provided by farm and forestry contractors. With supported investment in new technology, training and data exchange systems for FCI registered contractors, these technologies can advance circular agriculture through a cost-effective and fairer agriculture transition to a low-carbon farm economy. Farm and forestry contractors must be supported to purchase this appropriate equipment, as proposed in the nitrates action programme, NAP, first stage consultation.

From a climate action perspective, it is clearly more environmentally efficient for several farmers to utilise the services and equipment of a single farm contractor, rather than each individual farmer owning and utilising their own equipment. By purchasing a new tractor or machine grant-aided, supported by the TAMS scheme, overnight a farmer can become a farm contractor, with no registration or affiliation requirement. In doing so, they undermine the cost structure of existing farm contractors who are providing local skilled employment with proper insurance cover. A farm contractor cannot easily become a farmer.

Support for farm contractors to invest at a more rapid pace in newer machinery systems that can guarantee greater accuracy of application of animal and chemical fertilisers, as well as more traceability of the animal food production process and enhanced forest management needs to be examined to demonstrate to customers of Irish food and timber products the seriousness with which we as a nation take on the lower carbon and water quality challenges and as we pursue the transition to a more sustainable and fairer food and timber production system.

The FCI believes that the Departments of Housing, Local Government and Heritage and Agriculture, Food and the Marine should use the NAP and TAMS, respectively, while working with farm and forestry contractors as the dominant on-farm service providers, to improve environmental outcomes on Irish farms and in forests in line with Ireland’s national environmental objectives. Farm and forestry contractors want to take a lead part by providing solutions. This contractor input needs, first of all, to be acknowledged, and then supported. FCI members have always been early adopters and facilitators in the delivery of scientific research and the best farm practices at farm level. Farm and forestry contractors have a track record of working in partnership with generations of Irish farmer clients and advisers. Together we all now strive to achieve new national climate and water quality goals. It is therefore essential that the viability and well-being of farm and forestry contractors are addressed in all future farming and forest strategy programmes.

This is why we must repeat the message that without the essential input of farm and forestry contractors, sustainable Irish agrifood and forest production systems simply cannot exist. The farm and forestry contractor input needs to be acknowledged again and supported.

I will deal with some of the key points in terms of in terms of some of the schemes. In the slurry management area, the association is aware that the nitrates action programme contains the mandatory measures required of all EU member states by the nitrates directive, including closed periods that prohibit the spreading of fertilisers, limits on the amount of livestock manures that may be land-spread, conditions during which fertilisers may not be spread and livestock manure storage capacity requirements. While these are fundamental elements of the directive, at the FCI, we believe that there is scope to introduce measures that provide benefits for water quality and biodiversity. The fundamental issue is that the current nitrates directive calendar farming system of closed periods is simply not working. Extending this system will not ensure that it can function any more satisfactorily. This current system is too simplistic and it is non-scientific. It has been proven not to be practical at farm level and it is now clearly not sustainable. This has been confirmed by the deterioration in water quality as measured by the Environmental Protection Agency, EPA, despite the attempts at the closed period policing, involving the Department of Agriculture, Food and the Marine and local authorities. It is also despite the costly misdirected investment in LESS machinery systems funded by Government grant supports directly to farmers, rather than to farm contractors. This, again, is clearly acknowledged in the nitrates action programme, where it makes the point that contractors must be supported to purchase appropriate equipment.

What is lacking for us is a clear independent and technology-based, decision-making process to identify the best land spreading options based on measured information about air and soil temperatures, soil moisture levels, grass growing conditions, soil type information, predicted rainfall, slurry constituents, slurry volumes being spread and field mapping locations linked to machine tracking. Each of these individual indices is currently available but are they are not co-ordinated to ensure good decision-making. We currently have a simplistic calendar-based programme of work restriction that is not based on either science or technology. It has resulted in a behaviour on farms that is not consistent with the water quality objectives. Overall, the evidence from the agricultural catchments programme, ACP, indicates that supporting farmers to make better decisions regarding how and when they manage nutrient applications is likely to be the single area with the greatest potential to improve outcomes for water quality on Irish farms. That is a really important point.

On slurry storage, one of the reasons for the lack of slurry storage capacity on many farms is a lack of understanding among advisers and policymakers of the process of slurry management. FCI members are front-line providers of the slurry management services on farms. They understand the challenges and have rolled up their sleeves in attempting to develop management strategies that are sympathetic to our natural environment.

Slurry management in Ireland is significantly different to that in other European countries, meaning that the single application policies cannot function or be sustained. Some 80% of all silage now made is baled silage and during feeding, a large proportion of the silage ends up in slurry pits. There is a requirement to revise upwards, by at least 50%, the slurry storage requirements to take account of the long and high dry matter silage when mixed with the slurry and the resultant dilution needs when agitating this type of slurry product.

FCI believes that tillage farmers should also be grant-aided to invest in slurry storage facilities on their farms to store large volumes of liquid slurry exported from expanded and future expanding dairy, pig and beef farms that have limited land resources and face slurry storage challenges. This nutrient resource should be transferred to these tillage farms during the closed period of spreading, alleviating slurry storage challenges on highly stocked dairy and beef farms. Using modern precision farming systems it is possible to incorporate real-time traceability systems on slurry transfer machines of FCI registered contractors, linking that to a national database of slurry nutrients and movement managed by the Department of Agriculture, Food and the Marine. This proposed system will ensure more timely slurry use at its most efficient site of application on tillage farms, reducing the need for artificial fertilisers. This will provide longer seasonal work opportunities for skilled machinery operators within the contractor sector and retain rural-based machine operation expertise while boosting organic matter levels on Irish tillage farms, enhancing soil structures and supporting biodiversity.

On soiled water issues, our members provide soiled water management services on thousands of farms and they understand why the control and management of soiled water from farmyards needs greater emphasis across all delivery mechanisms under the nitrates action programme. The addition of soiled water to slurry tanks is causing many of the issues related to storage capacity. FCI supports the use of soiled water as a dilutant for the purposes of slurry agitation prior to spreading, reducing the need to import large volumes of clean water on the farm by means of proper management and engineering design.

On chemical fertiliser controls, while it is being proposed that the nitrogen allowances will be reduced by 10% nationally and potentially up to 15% in some areas based on the EPA catchment assessment report, these areas will be determined by the nitrates expert group based on input from the EPA, and any reductions in specific catchments will be undertaken on a phased basis. Changing the dates for work will not guarantee the delivery of the optimum spreading and utilisation strategies. What is required once again is a clear independent and technology-based, decision-making process on spreading times, etc.

Sewage sludges and the use of sludge is managed by Irish Water through its national wastewater sludge management plan. The application of sewage sludge to agricultural land is controlled by local authorities through the maintenance of sludge registers and inspection and enforcement programmes. Much of the land spreading work for this product is carried out by FCI farm contractors. The nitrates expert group aims to work with various stakeholders to address any risks from this nutrient source. FCI believes the association must be included with discussions as a stakeholder as our members provide the machines and operators that carry out this work.

The management, maintenance and submission of organic farm records is becoming a more important element of demonstrating compliance with current water quality regulations. At present all farmers are required to maintain up-to-date paper records of livestock manure and slurry. Failure to produce these records during an inspection can lead to significant payment penalties for farmers. By transferring this responsibility for the management of livestock manure and slurry recording to FCI registered contractors as part of their spreading licence application and to provide precision farming systems, a more streamlined process can be provided to ensure that contractors are able to manage the liquid slurry and manure records of their farmer clients. This will also free up additional time for farm advisers, whose time is often taken up with such record-keeping on behalf of farmers. The fact that poor slurry application decision-making on farms has been measured strongly suggests that there should be serious consideration given to licensing of slurry spreading and the slurry transfer process to registered contractors. These contractors can be licensed and their licence linked to a national database of slurry nutrients and slurry movement using precision farming technology managed by the Department of Agriculture, Food and the Marine in conjunction with a national FCI contractor register created and maintained by the association in partnership with the Department of Agriculture, Food and the Marine.

FCI believes that farm and forestry contractors must be supported to invest in new low-emissions slurry spreading technology in the same way that farmers are currently supported. It has been proposed in the nitrates action programme that this should be the case. If no such supportive action is taken to improve the uptake of precision farming technology on farms below 100 ha, and the average farm size in Ireland 32.4 ha, it will become increasingly difficult for these farms to compete. These farms will also struggle to comply with the EU and national environmental and water quality goals. FCI members have not invested significantly in higher technology slurry management machinery to the same extent as their European counterparts due to the presence of the farmer-focused machinery grant aid system which is making investment in more accurate and more efficient spreading systems that incorporate precision farming systems with high levels of traceability and transparency, totally uncompetitive. How can any farm contractor compete with one of their client farmers who receives a grant aid of 60% for the purchase of low-emission system machine? FCI believes that the current green low-carbon agri-environment scheme, GLAS, grant aid scheme should be extended to all farmers to use low emission slurry spreading, LESS, systems operated by an FCI registered contractor. If all LESS slurry spreading was grant-aided based on FCI contractor invoices, not just to existing GLAS farmers, the cost to the Government would be significantly less than the current cost of machinery grants which have run to more than €55 million. Many of the LESS machines purchased by farmers under the current TAMS II programme were purchased to take the advantage of the grant aid and for taxation benefits, rather than being needed to do the slurry spreading work. There is significant evidence that many of these machines are not being worked and will not be worked. This is a significant loss to the Government, the Irish water environment and Irish taxpayers who have supported investment in machines that will not be or are rarely used.

In regard to water quality in forestry, the risk of diffuse water pollution in Irish forestry is increased by poor site planning, poor management, and poor monitoring of machine work activities. There is often a lack of clear understanding of the forestry contractor’s challenges and responsibilities on site as work conditions often include a combination of high rainfall, heavy machinery, and steep ground. FCI believes forestry contractors and operators should receive funding for training in how to understand fully the forest operational plans, and have an input into their production. There must also be more investment in education for farmers on slurry management rather than investment for the purchase of slurry spreading machinery. Advisory programmes to inform farmers about optimum management of the slurry in their livestock sheds needs to be a priority. Good slurry management strategies save farm contractors significant time during the spreading operation and this will always convert into a financially more cost-effective contractor service for farmer clients.

FCI supports the establishment of a livestock manure and grass-based biodigester sector in Ireland. This approach to producing methane from grass, our best producing and lowest cost crop, will fulfil a significant number of requirements, including management of livestock manures to enhance water quality in an environmentally sensitive way while also contributing to lowering greenhouse gas emissions within the State. FCI believes that grass, as Ireland’s most productive crop, when used in conjunction with excess animal manure, will also mean additional rural-based employment as grass harvesting cannot be outsourced to another country.