The Irish Farmers' Association - IFA

Lobbying Organisation The Irish Farmers' Association - IFA

Date published 17 May, 2022

Relevant Matter Public policy or programme

Public Policy Area Agriculture

Period 1 Jan, 2022 to 30 Apr, 2022

Specific Details Draft River Basin Management Plan for Ireland 2022-2027 (RBMP)

Intended results The following is the Summary of the IFA Submission to the public consultation on the Draft River Basin Management Plan for Ireland - The draft River Basin Management Plan (RBMP) will have significant implications for farmers across all sectors of Irish Agriculture. - IFA support the approach being adopted in the draft plan – the right measure in the right place. This is very much in line with the findings of the Agricultural Catchments Programme (ACP), which has shown that a one-size-fits-all approach is not effective mitigation strategy for nutrient losses to water due to the inherent variability found between and within catchments. - Sustainability in agricultural cannot not be confined to environmental issues. To maximise farmers' uptake of environmental measures, the actions should encompass all aspects of sustainability – economic, social and environmental. - Agriculture accounts for 68% of the national land cover, so it is not surprising that it is has been identified as the most common significant pressure on water quality. - Although the results from the most recent EPA water quality were disappointing and showed a decrease from 55% to 53% of surface waterbodies at good or high status from the previous 2010-2015 period, it is important to acknowledge that due to delays implementing the 2nd RBMP that the majority of the actions taken by farmers were not captured in the assessment of water bodies for the period 2013 – 2018 - The RBMP must fully acknowledge the investment being made by farmers to protect and improve water quality, and ensure that time is given to accurately evaluate the effectiveness of these measures on improving water quality. - In the new CAP 2023 – 2027, 34.3% of the overall CAP budget (Pillar 1 & 2) is being allocated to environmental measures compared with an EU average of 30.5%. - It is critical that our scientists and policymakers better explain the complex nature of improving water quality so that stakeholders appreciate that immediate solutions should not be expected. Indeed, a lack of understanding of hydrological principles may lead the public to believe that current intervention measures are not working, when in reality time is required to demonstrate the effectiveness of the measure on water quality. - Given the success of the Agricultural Catchment Programme and Agricultural Sustainability Support Programme in improving water quality in the PAA's a mechanism to improve the knowledge exchange from with the wider farming community needs to be pursued and financially supported. - A key barrier to meeting the increased ambition in the draft RBMP is the financial vulnerability of many farms. The development of a comprehensive financial strategy to support the implementation of measures in the RBMP including Accelerated Capital Allowance (ACA) schemes. In addition, new and innovative funding mechanisms outside of CAP should be considered that reward farmers for the wider eco-system services provided by their actions. - The water quality monitoring regimes need to increase to improve both spatial and temporal resolution of the data to provide a more realistic assessment of the nitrate status of a catchment. In addition, the greater accessibility of data needs to be provided to facilitate statistical trend analysis taking account of both localised and seasonal weather impacts. - There is ample evidence that a consideration of time lags should become standard in the design of water quality policies. By quantifying time lag the most effective management and mitigation practices can be designed, so expectations can be adjusted accordingly. - The establishment of LAWPRO and ASSAP in the 2nd RBMP cycle significantly increased outreach, knowledge and understanding of the agriculture pressures on water quality. Both programmes have established good working relationships with farmers and communities that will be important as we enter into the next cycle. - The scale of the challenge to meet the increased ambition set out in the 3rd RBMP cycle must not be underestimated. Continued collaboration and improved knowledge exchange with farmers and advisors to optimise the use of inputs and support farmers to change practices to protect and improve water quality will be crucial. - The scale of the challenge to meet the increased ambition set out in the 3rd RBMP cycle must not be underestimated. Continued collaboration and improved knowledge exchange with farmers and advisors to optimise the use of inputs and support farmers to change practices to protect and improve water quality will be crucial. - The proposed Nature-Based Solutions must be introduced on a voluntary capacity. All operational and management costs are funded, and any loss of productive area is fully compensated. In addition, a supplementary payment that values the multiple eco-system services provided is needed to ensure sufficient coverage of spatially targeted buffer zones in critical source areas. - Given the importance of Nutrient Management Planning (NMP) to water quality there needs to be greater focus in the plan to financially support farmers to develop tailored NMP for their farms. Mainstreaming the use Nutrient Management Plan (NMP), while simplify the process for farmers should a key objective. - A simplified forestry regulatory system, based on sustainable management plans, similar to those operated elsewhere in Europe needs to be introduced. The current regulatory system is not fit for purpose and will not support the proposal to establish 12,500 hectares of native riparian woodland. In addition, until the system supports planting small scale woodlands it is unlikely that farmers will be willing to commit land to forestry in any instance. - It is vital that we continue this journey of collaboration and knowledge exchange to help farmers understand and implement the right measure, in the right place at farm level. The expansion of the programmes like ASSAP and Smart Farming that work with farmers to deliver behavioural change will be essential to meeting the increased ambition. 2. Introduction

Name of person primarily responsible for lobbying on this activity Elaine Farrell IFA Director of Governance & Oireachtas Engagement

Did any Designated Public Official(DPO) or former Designated Public Official(DPO) carry out lobbying activities on your behalf in relation to this return? You must include yourself, and answer Yes, if you are a current DPO or a DPO at any time in the past. (What is a Designated Public Official?) No

Did you manage or direct a grassroots campaign? No

Was this lobbying done on behalf of a client? No

Lobbying activity

The following activities occurred for this specific Subject Matter Area.

Email (2-5)

Submission (1)

Designated public officials lobbied

The following DPOs were lobbied during this return period on this specific Subject Matter Area. These DPOs were involved in at least one of the Lobbying Activities listed above, but not necessarily all of them. As returns are specific to a Subject Matter Area the above Lobbying Activities may be associated with multiple returns.

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 Ring 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)

Victor Boyhan Senator (Seanad)

Lynn Boylan Senator (Seanad)

Paul Daly Senator (Seanad)

Tim Lombard Senator (Seanad)

Denis O'Donovan Senator (Seanad)

Richard Bruton TD (Dáil Éireann, the Oireachtas)

Réada Cronin TD (Dáil Éireann, the Oireachtas)

Cormac Devlin TD (Dáil Éireann, the Oireachtas)

Alan Farrell TD (Dáil Éireann, the Oireachtas)

Darren O'Rourke TD (Dáil Éireann, the Oireachtas)

Christopher O'Sullivan TD (Dáil Éireann, the Oireachtas)

Bríd Smith TD (Dáil Éireann, the Oireachtas)

Jennifer Whitmore TD (Dáil Éireann, the Oireachtas)

Timmy Dooley Senator (Seanad)

Alice-Mary Higgins Senator (Seanad)

John McGahon Senator (Seanad)

Pauline O'Reilly Senator (Seanad)

Mary Fitzpatrick Senator (Seanad)