The Irish Farmers' Association - IFA

Lobbying Organisation The Irish Farmers' Association - IFA

Date published 21 May, 2023

Relevant Matter Legislation

Public Policy Area Agriculture

Period 1 Jan, 2023 to 30 Apr, 2023

Specific Details Sustainable Use of Pesticides Directive (SUD)

Intended results • The Irish tillage sector is made up of 10,000 growers with 5,000 of these being specialist producers. In 2020 the sector was estimated to contribute over €1.3 billion in direct economic output and supports 11,000 full time equivalent jobs.1 • The Irish horticulture sector is a highly productive and specialised food production industry with farm gate production valued at €467 million in 2020. Despite the small land area dedicated to Irish Horticulture, it accounts for 11% of total agricultural jobs through direct and downstream employment and is the fourth largest contributor to Irish agricultural output. • A mandatory requirement to reduce the use of pesticides by 50% by 2030 will have a very significant impact on all agricultural sectors across Ireland. This will be felt most significantly in the tillage and horticultural industries where viability and competitiveness will be severely undermined due to the unique climatic conditions and high plant disease pressure Ireland faces on an annual basis. • In the climate action plan the tillage and horticulture sectors are described as the most carbon-efficient sectors of Irish agriculture and the importance that the areas under cultivation in these areas is increased. • Irish governmental policy has set a specific target to increase the national tillage area to 400,000ha. These targets will not be met if a 50% cut in pesticide use is implemented. • IFA believes a full impact assessment of the SUR proposals on Irish agriculture must be undertaken by a competent authority in Ireland before any national reduction targets are agreed to at EU level. • A blanket 50% pesticide reduction policy implemented across Europe is far too simplistic, any reduction targets must be based on credible agronomic or scientific evidence. • A 100% ban on the use of pesticides in areas deemed sensitive is an arbitrary and draconian target with little foresight given to the impact on food production. • The areas defined as ‘sensitive areas' must be revised and exemptions must be allowed for in certain scenarios. The prohibition of the use of plant protection products in all public areas is too ambiguous and would prevent many commercial activities on horticulture farms. • Nitrate vulnerable zones (NVZs) must be removed from the list of areas classified as sensitive to avoid Ireland becoming severely disadvantaged in all forms of agricultural production. • Full clarification is required on the determination of buffer zones between productive areas and the GAEC 8 space for nature areas. Mitigation practices should be allowed to reduce buffer zone requirements between space for nature and productive areas. 3m must be the maximum buffer zone requirement for agricultural scenarios. • The use of 3-year average sales data to determine reduction targets for more hazardous pesticides is too narrow of a time frame. The EU Commission must seek to develop a wider range of indicators which reflect actual pesticide usage. • The requirement for electronic registers monitoring the use of Integrated Pest Management (IPM) only serves to further increase the administrative burden on farmers. IFA have concerns about ownership and protection of farmers sensitive data generated in these registers. • The mandatory requirement for farmers to receive independent advice will be challenging to implement due to a lack of independent agronomists practising in Ireland. For this objective to become feasible, IFA believes a long-term strategic plan with appropriate financial incentives is needed to encourage people into developing careers as independent agronomists.

Name of person primarily responsible for lobbying on this activity Kieran McEvoy IFA Grain Chairperson, Max Potterton IFA Grain Policy Executive

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.

Submission (1)

Informal communication (2-5)

Email (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.

Brian Leddin TD (Dáil Éireann, the Oireachtas)

Denis O'Donovan Senator (Seanad)

Jackie Cahill TD (Dáil Éireann, the Oireachtas)

Joe Flaherty TD (Dáil Éireann, the Oireachtas)

Lynn Boylan Senator (Seanad)

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)

Michael Ring TD (Dáil Éireann, the Oireachtas)

Paul Daly Senator (Seanad)

Paul Kehoe TD (Dáil Éireann, the Oireachtas)

Tim Lombard Senator (Seanad)

Victor Boyhan Senator (Seanad)