Specific Details
Public Consultation on the Fourth Review of Ireland's Nitrate Action Plan (NAP) Stage 1 Consultation Paper
Intended results
To highlight that the single biggest issue that has been avoided by the Department of Housing and Local Government (HLGH) in the consultation paper is the financial vulnerability of many farms.
To highlight that the Department of Agriculture's (DAFM) lack of communication with farmers in advance of the new measures that were introduced on the 1st January 2021, such as the changes to roadways, fencing and water troughs requirements, was wholly unacceptable and caused considerable confusion and stress amongst farmers.
To point out that the time lag between the adoption of management changes and the detection of measurable improvements in water quality can be significant and may not show definitive results during a monitoring period. It is vital that policy recognises lag times and expectations are adjusted accordingly.
To highlight that the Department's paper fails to highlight the enhanced measures aimed at improving water quality that have taken place on farms, particularly farms stocked above 170kgN/ha in the past year.
That the following issues set out by the DHLGH be considered in the consultation paper :
Cattle access to watercourses - there should be no extension of existing requirements. The last iteration of the NAP focused on preventing cattle accessing watercourses, time must be given to allow these measures to work and the positive impact on water quality to be assessed. That there is no further extension to the current requirements.
Phosphorous build-up - IFA supports the assessment of the uptake and effectiveness of this measure, as it is important to optimise fertiliser use. There needs to be greater communication and promotion of this measure, as many farmers have a poor understanding of the P build up allowance. The P build-up programme should be expanded to include farmers with stocking rates of 100kgN/ha and higher, and training should be provided to increase understanding and encourage wider uptake of this measure.
To support the suggestion to streamline and make the management, maintenance and submission of records less onerous for farmers. Any improvements are welcomed and must be appropriate to scale and farming system. However, the introduction of a regime similiar to the existing one for use of pesticides is not appropriate. That any changes to the current process must be done in consultation with stakeholders, that training be provided to farmers and sufficient lead in time is allocated.
To acknowledge the proposal to increase training for farmers to improve farmers knowledge of Good Agricultural Practices (GAP), regulations and share best practices. That any training provided is subsidised similar to the GLAS training scheme, and participants are reimbursed for attending the training course.
To point out that the existing requirements that all farms stocked over 170kgN/ha must use LESS, and that this requirement covers the majority of slurry produced in this country. Farmers have already invested, with grant support, an estimated €79.6 million in LESS equipment. IFA opposes extending this requirement to smaller farms as the impact would be minimal, the focus on these farmers should be the timing of slurry application rather than application type.
That the DAFM increase the grant to 60% for LESS equipment under TAMS and that LESS equipment be VAT exempt.
To highlight that despite several attempts to simplify the planning process nutrient management plans remain complex to understand and apply. Currently advisors are required to complete NMP. Previous attempts have failed to bring the farmer along with the process; therefore, it is proposed that the next NAP creates a greater understanding and appreciation of soil science and nutrient management.
That prior to mainstreaming the use of NMP, that the process is simplified and a new online tool is developed to be used by farmers.
To highlight that the majority of farmers have invested in slurry storage at considerable cost, but continued investment is needed. That the Nutrient Storage Scheme under TAMS is available to all farmers; (ii) Development charges must be waived and planning permission must be simplified for any development that increases slurry capacity and (iii) Current closed periods should be reviewed to give more flexibility to farmers to spread slurry when weather conditions are appropriate.
That any changes to the criteria set out in Schedule 2 must be based on robust scientific evidence, and done in consultation with stakeholders.
That the regulation of existing requirements relating to the Drinking Water Directive should implemented before applying additional legislation
Potential Additional Requirements:
Liming - support financial incentives for liming programmes for all farmers as set out in the Programme for Government.
Soils - that the phosphorus build-up programme, which has proven beneficial to farmers with low soil indices for P is retained in order to reduce the use of Nitrogen.
Grazing intensity/zero grazing - that, similar to the format of the ASSAP programme, a dedicated resource is put into managing critical source areas for nitrates leaching. This would equip farmers with the necessary skills and tools to actively protect vulnerable hotspots within specific areas and would have a greater impact than blanket application of regulations.
Exports of livestock manure - that the production of both pig slurry and poultry litter which is exported directly off the farm of production, should not be included for calculation of N and P on the farm. (see Court of Justice European Union (CJEU) case C-113/12 Donal Brady v. Environmental Protection Agency)
Large Herds - that funding and resources be directed into addressing hot spot areas by diagnosing the cause of the problem and addressing it with prescriptive actions. Uniform blanket measures are often ineffective and will not have the desired impact of improving water quality, but could have a huge impact on farmers livelihoods.
That an interim Review of the Action Programme every two years is unnecessary and very disruptive.
Compliance with Birds & Habitats Directives - more can be done to promote biodiversity on our farms, but it is more appropriate that this is done through incentives under separate programmes.
Jackie Cahill
TD (Dáil Éireann, the Oireachtas)
Martin Browne
TD (Dáil Éireann, the Oireachtas)
Matt Carthy
TD (Dáil Éireann, the Oireachtas)
Michael Collins
TD (Dáil Éireann, the Oireachtas)
Michael Fitzmaurice
TD (Dáil Éireann, the Oireachtas)
Joe Flaherty
TD (Dáil Éireann, the Oireachtas)
Paul Kehoe
TD (Dáil Éireann, the Oireachtas)
Brian Leddin
TD (Dáil Éireann, the Oireachtas)
Michael Ring
TD (Dáil Éireann, the Oireachtas)
Victor Boyhan
Senator (Seanad)
Lynn Boylan
Senator (Seanad)
Paul Daly
Senator (Seanad)
Tim Lombard
Senator (Seanad)
Denis O'Donovan
Senator (Seanad)
Chris MacManus
MEP (European Parliament)
Deirdre Clune
MEP (European Parliament)
Barry Andrews
MEP (European Parliament)
Luke Ming Flanagan
MEP (European Parliament)
Seán Kelly
MEP (European Parliament)
Frances Fitzgerald
MEP (European Parliament)
Clare Daly
MEP (European Parliament)
Mick Wallace
MEP (European Parliament)
Billy Kelleher
MEP (European Parliament)
Maria Walsh
MEP (European Parliament)
Ciarán Cuffe
MEP (European Parliament)
Grace O'Sullivan
MEP (European Parliament)
Colm Markey
MEP (European Parliament)