The issue of chemical P or phosphates has arisen mainly where stock are out-wintered and in that situation the plan, as prepared on the eREP system, does not satisfy the checks and balances system used by the Department. Apparently, in the Department's checks, for instance, C should equal A minus B, but in eREPS, with all stock out-wintered, C should not equal A versus B. The relevant P deduction is done in another way. That is leading to much confusion.
In REPS 4, all plans were prepared on the e-REPS system, a computerised system run by Teagasc and the Agricultural Consultants Association. I am sure the Department had an input as the system had to meet the REPS specifications. If the system is wrong, why has the Minister not checked it out and demanded that it be rectified rather than rejecting individual plans? Why has he not called in the planners and explained the alleged deficiencies, if there are any? Why do these issues only arise when payments are due? Plans were all submitted prior to 15 May 2009.
The administration of REPS 4 is also a major issue. The requirement that all plans had to be submitted by 15 May was a nightmare for planners and farmers. That put unreal pressure on planners and Department staff with the result that bundles of plans were submitted together and the Department did not check these out for perhaps six months. Previous plans were submitted throughout the year and were checked within a week or so of being submitted and any issues were quickly sorted out.
Likewise with inspections, apparently the Department must carry out all inspections before dealing with any problems encountered with the result that following an inspection in June, the farmer may not be written to until December or January. It is understandable that REPS 4 must meet the requirements of the nitrates directive but why can the Minister not sit down with the planners and Teagasc and work out this issue? It is not rocket science.
The Department staff at local level are very helpful and do their best to sort out the issue but their hands are tied by the administrative requirements imposed on them by their superiors — I found this from my experience of dealing with them. Surely, it should be possible to find a better way to administer this system. Brussels is sometimes blamed but if Brussels imposes unworkable requirements, surely it should be possible to go back to it to rectify and simplify them.
To return to chemical P, in e-REPS when dealing with organic and chemical P, if the stock are out-wintered, the planner ticks a box and then the P fraction is deducted automatically from the amount of P the planner has recommended based on table 3, page 34, of the specs, with which the Minister is no doubt familiar. What adds to the confusion is that the planner's full recommendation appears at column 6 of table 1.10. The total in column 7 is not equal to column 4 times column 6 but has been reduced for this fraction and also for the concentrates fed.
To further add to the confusion in making this deduction, the fraction about which I speak is divided by the total forage area whereas the P in the concentrates feed seems to be divided only by the areas that are soil tested and for which a chemical P allowance is recommended. If the stock is not out-wintered, the planner does not tick the said box and then the 18/52 P is not deducted at table 1.10 but is deducted when the planner allocates the slurry. The slurry is adjusted to give the same fraction of total P produced — for example, it is 18 weeks in County Kerry — irrespective of how long the stock are housed for. It is highly technical but can be resolved if the Minister sits down with these people or if he comes to County Kerry to meet the planners.
Even when REPS plans have been completed, are perfect and have been cleared, there is no district superintendent in County Kerry, north or south, to sign off on the applications. I understand this is happening throughout the country and that there are vacancies across the agricultural and environmental sector which are not being filled. It is holding up the whole REPS programme.
In the case of County Kerry, apart from resolving the chemical P problem, I appeal to the Minister to appoint a district superintendent as soon as possible in order that these plans can be cleared because there is much dependency, as he will probably tell me, on REPS in County Kerry for farm income.
