Mr. John Enright:

The Border is certainly an issue for the Department and for the trade. I am going to focus on something the Department has to give clarity on and deal with. When we look at the fertiliser regulation Bill from a farmer's perspective, our concern is that we are almost at a stage where there is forensic checking of what farmers are doing on the nitrates side. We have serious concerns about the direction that is being taken. A farmer who makes a very minor mistake could be excluded from the derogation and suffer penalties under the nitrates directive. We have made a number of very specific points in our submission. Most significantly, we have asked why a farmer needs to apply to be part of the register. All the talk about simplifying matters for farmers and giving them freedom to farm is the biggest joke of all time, to be quite honest. It is getting more and more difficult as we move forward. To give a simple example, why do I have to register to purchase fertiliser? When changes were brought in regarding pesticides, I did not have to register for that. I go into my co-op, give my herd number and get the pesticides required for my farm or whatever I need. We have made some specific points on that. Our big concern from the point of view of the register is around the sanctions to be placed on farmers who make minor errors. It is very easy to make a minor error in relation to fertiliser usage. If a farmer spreads an extra 10 kg of nitrogen in a year, as per the register, what are the sanctions going to be? There is huge frustration about issues like that. We heard earlier about the nature registration law. There is huge frustration about the raft of regulations being introduced. I will not go through the specifics of this matter because it is very detailed but if we are to make it as simple as possible for farmers, we have to address those issues. As I see it, we are setting up a structure that is quite complex. My real concern is that it will get more complex over time as we move forward. We need to get clarity and keep it simple for farmers. There should not be a need or a requirement to apply to be registered. The Department has all the details of every farmer - his name, address, herd number, cattle details and land details. Why in the name of God do we have to go and apply for this again? We need to keep it simpler. I will not go into the detail of the specific points we made in our submission at this time.