Mr. Paul Moore:

My name is Paul Moore. I am a seventh-generation farmer living near Midleton in east Cork. Tillage and beef are my farm enterprises. I have been involved in wildlife conservation, mainly with BirdWatch Ireland in my spare time for over 30 years. I am one of the founders of the BRIDE project EIP and I have been a farming for nature ambassador since 2021. In 2022 I became aware of the proposal that arable farmers would have to shallow cultivate stubble fields shortly after harvest as part of the nitrates action programme.

This concerned me from a farming perspective as an added cost and extra workload at a critical and extremely busy time of year on farms when harvesting crops is our priority, and from a bird conservation perspective because I knew the value of cereal crop stubble as a winter farmland bird habitat, both from my own farm and from studies carried out elsewhere.

There has been very little research done in Ireland on how farmland birds use crops and fields during the year and nothing on the use of stubble. Once it became clear that the Department was going to implement this policy, I approached BirdWatch Ireland for scientific advice and then set about finding funding for a study on farms in east Cork. The study was funded by Irish Distillers in Midleton to which I supply grain and the South and East Cork Area Development Partnership through the LEADER programme. Additional support to locate survey farms was provided by Dairygold Co-op and the local east Cork Teagasc office.

We got a great response from local farmers - so much that we were not able to get to survey all the farms that contacted us. In the event over 80 sq. km was surveyed over the winter of 2022-23 by trained ecologists. The results show a clear indication that shallow cultivation, where the field is cultivated to a depth of three to four inches to encourage germination of the seeds in the soil to soak up nutrients, is a poor habitat for farmland birds.

If the practice continues, it will likely result in further losses in the number of threatened species, like the yellowhammer, the hen harrier, the linnet, the skylark, the greenfinch and the snipe, that use stubble fields on farms throughout the winter.

The final report has been made available to the committee. I will not summarise it. We mainly examined stubble, cover crops and shallow cultivation. By late winter, stubble and cover crops had retained their importance but shallow cultivation had not because it held very few birds at that stage. Teagasc recently commenced a study on the effects of shallow cultivation on farmland birds. By the time that is completed, the shallow cultivation requirement on tillage farms will have been in effect for six or seven years, with unknown but potentially severe impacts on farmland birds.

While improving water quality is a very important goal, attempting to solve one environmental problem by creating another is no solution at all. It makes no sense to propose a solution to address water quality which could worsen the biodiversity crisis but that is what we are facing as a result of these changes. Thousands of farmers have been working hard to support farmland birds through of a range of agri-environment schemes over the years. This change could negatively impact these efforts.