Mr. Eddie Punch:

The implications are very serious for farmers. I point the committee to Article 9(4) which refers to peatlands. We are talking here about peatlands that have been reclaimed and that are in many cases productive agricultural land. It has set out that by 2030, 30% of such areas will require restoration measures, of which one quarter will be rewetted. It goes to 50% of such areas by 2040, of which at least half shall be rewetted, and 70% of such areas by 2050, of which at least half shall be rewetted. That is a substantial impact. Then there is the wider story of restoration measures for 20% of all agricultural land, and ultimately all ecosystems, by 2050. We are talking about a substantial implication for much of the land in the country. That is the first critical point.

This regulation is full of complexity and ambiguity. Our concern would be that there has been no engagement with the Department of the Environment, Climate and Communications on this with farm organisations to date. This is part of a bigger pattern that troubles us whereby grandiose plans emerge from Brussels based on headline figures. If we roll back a bit, this goes back to the EU biodiversity strategy where essentially a bit of horse-trading at Brussels-level led to a target of 30% of land being designated, one third of which would have strict protection on it. These kind of ideals are being set at a high level without any understanding even at high levels within the member state. We have asked the Department of Agriculture, Food and the Marine what this means and the truth of the matter is that it is not clear. When we come back to this particular off-shoot of the EU biodiversity strategy, the proposed nature restoration regulation, we understand the Minister is minded to be supportive of it but we do not know on what basis and what discussion has been held at Government level to justify that particular position. Our view would be that Ireland should, in the best traditions of EU negotiations, start out with a hostile antipathy to this because this has profound implications.

Economic impact assessment was mentioned earlier. That is absolutely essential. There are financial implications of this, which are quite immense. One figure I heard was 870,000 acres of peatland. With land at €10,000 per acre, that is €8.7 billion worth of land potentially transformed from productive agriculture to less productive or non-productive. This is big money. The document itself suggests that the administrative costs for this are €14 billion. If the bureaucrats administering it are going to spend €14 billion, can one imagine what the cost implication will be for our members whose farming activities are going to be totally decimated and whose land is going to be completely devalued?

Our concern is that the history of designation has been a lamentable one where for a long number of years people with designation had no scheme to compensate them in any way for the implications of it. For example, we had the hen harrier farmers but there were many others as well. Originally, there were National Parks and Wildlife Service, NPWS, schemes. They were then defunded. The agri-environmental schemes were totally and utterly not fit for purpose for the people who had designations. For those reasons, farmers are terrified of what is potentially coming down the track on this. The key thing we want to say for a start is that there must be proper analysis of this and engagement between the Government and the stakeholder representatives before we go anywhere.

In terms of Deputy Carthy's question about international trade deals, an interesting point here is that when the Mercosur deal was done certain caveats were put in which essentially said that countries like Brazil would not do any further damage to rainforests or take further measures that would further damage their climate change situation. It is interesting that we now have a new piece of legislation, a regulation, coming in at EU level that was probably not foreseen when the Mercosur deal was negotiated. If one was to try to apply the logic that has been applied to European farmers, one should say that the equivalent in Brazil would be to look at all of the rainforests that were cut down over the past 70 years and tell them they have to restore them. That would be the equivalent to what is being asked of European farmers for a start. That is not going to happen because it is not provided for in the Mercosur deal.

The point is that we are hamstringing our farmers more and more in Europe and we have no possible way of putting equivalent conditions on trade deals that have now been signed and sealed although not delivered yet, and there is a long pattern of that. That is what we would have to say to start with.