I thank the committee for inviting pig farmer representatives to meet it to discuss the impact the nitrates action programme will have on the Irish pig and poultry sectors, which are valued at €1 billion. This is our first opportunity to meet the committee directly on this issue. I support the IFA's clear position on issues such as the minimum storage requirement for farms and the closed periods for application of fertilisers.
Let me focus on the impact the nitrates action programme will have on pig and poultry farmers. The pig and poultry sectors developed on small-scale holdings and the manure produced on the farms is distributed to tillage and grassland farmers locally who need it to grow their crops. These inter-farm relationships are directly threatened by the proposed nitrates action programme.
I will give an overview of the Irish pig and poultry sectors to put their significance to Irish agriculture in context. I include the poultry sector in my comments because the action programme will have a significant impact on that sector also. Both these sectors are already highly regulated as these are the only two farming sectors licensable by the EPA. Most of those involved are bound by stringent planning permission conditions while many others operate in areas where by-laws are in operation. There are 500 pig producers in Ireland, producing over 3.5 million pigs per year from 160,000 sows. Primary production and processing provides direct employment for over 6,500 people and supports many other service industry jobs. On poultry production, there are over 800 poultry farmers producing 65 million chickens, 3.5 million turkeys and 850 million eggs annually. This sector supports 3,000 jobs directly and many more indirectly.
As highlighted in a recent Irish Farmers’ Journal article, the pig and poultry sectors are key users of native Irish cereals and finished feedstuffs. The sectors use 1.5 million tonnes of finished feed annually and, based on current feed prices, this trade is estimated to be worth €330 million per year. These two sectors use diets comprising 75% cereal. This is a major market for native produced cereals as it consumes 1.1 million tonnes of cereal annually at a value of €140 million. The cereal sector consists of 16,500 tillage farmers with an average acreage of 100 acres. The three sectors account for approximately 7%, 3% and 4% of gross agricultural output, respectively, totalling approximately 14%, but they are collectively at least half as important as either the dairy sector or cattle sector and should not be undervalued or written off without consideration.
As I pointed out, pig manure is distributed locally to commercial farmers who use it in accordance with the relevant good farming practice code to produce cereals or grass. These farmers will be further subjected to cross-compliance controls in regard to the single farm payment. We estimate there are currently 15,000 to 20,000 farms that use pig or poultry manure to supply part of their annual fertiliser needs. Many of these are good commercial grassland or tillage farms with higher than average productivity. The value placed on this product in nutrient terms is in excess of €10 million.
The total amounts of nutrients available for the users of pig manure are approximately 3,000 tonnes of phosphorus and approximately 10,000 tonnes of nitrogen. In both cases, the quantities are a small fraction of the 43,000 tonnes of phosphorus and 360,000 tonnes of nitrogen imported in chemical form from outside the country. Most farms can be divided into three categories of fertiliser usage: high to medium output farms; REPS farms and low output non-REPS farms.
The high to medium output farms are those that need a large quantity of nutrients and carry a high level of livestock. Many of these are high users of pig manure and farm close to or above the proposed 170 kg organic nitrogen limit. Many of these farmers could be prevented from using pig manure or be put off using it as a fertiliser given the level of paperwork involved in using this product, with or without a derogation.
The REPS farmers of which there are more than 40,000 - a figure expected to rise to 70,000 in the next few years - are not large users of pig and poultry manure as the unnecessary paperwork involved puts most of them off even considering it. The low output non-REPS farms are generally cattle and sheep farms, many of which are in extensive farming areas, are remote from a source of pig manure, and are not significant users of pig manure at any time. Low output farms have low nitrogen and phosphorus requirements. Soil phosphorus levels can rise rapidly in response to relatively low pig manure applications due to the low productivity and nutrient demand.
A serious problem faces pig and poultry farms if the proposals are eventually implemented. As part of a submission from the pigs sector to the Minister for the Environment, Heritage and Local Government, Deputy Roche, and the Minister for Agriculture and Food, Deputy Coughlan, we have outlined some areas where relief is sought to protect these sectors. A system of preferred nutrient sources should promote the use of locally available fertilisers as far as possible. The draft nitrates action programme and guidance document refer to but do not support, and in numerous instances seriously undermine, this objective.
The action programme differentiates between "chemical", "organic fertilisers" and "livestock manures". It points out that the general limit of 170 kg per hectare applies only to livestock manure. This creates an unequal situation because any farmer using pig manure could be prevented from doing so because the organic nitrogen content of this manure is added to his or her own farm production. However, if this farmer were to use other organic fertilisers such as sewage, sludge or factory by-products, the organic nitrogen content of such products is not included in his or her overall organic nitrogen figure.
A possible alternative to this is that the general limit of 170 kg or 230 kg should apply only to livestock manure produced on-site. Livestock manures that farms acquire as a substitute for chemical fertiliser should not be accountable in the specified organic nitrogen limit on the farm using such material. The Government seeks a derogation from the Commission for some farms to exceed the 170 kg nitrogen per hectare limit. The derogation sought is for up to 250 kg nitrogen per hectare from animal manure. If granted to farms, irrespective of stock levels, it would be helpful to the pig and poultry sectors. It has been signalled, however, that a derogation is unlikely to be granted just to allow one farm to use animal manure from another farm.
The level of paper work and detail for a farmer intending to apply for a derogation as outlined in the "derogation document" would deter many tillage and grassland farmers from using pig manure. Equally, the derogation proposed on a per farm or even a per field basis as suggested will discourage the intermittent user of pig manure. It is also proposed that any farmer applying for a derogation has a 5% chance of an inspection compared to a 1% chance if no derogation is sought. This will also impede use of this product.
The Department of the Environment, Heritage and Local Government and the Department of Agriculture and Food guidance document contains a requirement to have a written contract between the exporter and importer of livestock manure if it is to be traded. This would discourage many current or potential users of pig manure and promote the use of imported chemical fertiliser instead of fertiliser locally available from pig farms.
The guidance document states that nitrogen may not be applied under any circumstances to cereal or tillage crops in autumn and winter. This should be changed as some of the pig farmer's best customers for the manure are winter cereal producers. The recommendation would prevent that trade in future, with severe implications for tillage farmers and pig and poultry farmers. Closed periods as specified will be respected.
The Department of Agriculture and Food should remain the competent authority for all farming enterprises, regardless of the source of their fertiliser. Attention must also be given to the issue of access to individual farmers' commercial information. To date the Department has not permitted any public access to an individual farmer's file. This must be preserved in the action programme.
Having considered the implications outlined above arising from the draft action plan and the draft guidance document, pig and poultry farmers expect that most of the existing grassland and tillage users of pig manure will no longer use pig manure to fill any part of their nutrient needs. The problems posed for commercial farmers by the proposed action programme are difficult to accept when the document submitted to support the request for a derogation to 250 kg emphasises that the need for a whole-country designation approach is questionable when fewer than ten Irish soils are classifiable as medium to high risk with regard to nitrogen leaching.
It is easy to predict the effect that further restrictions will have on the pig and poultry sectors and by implication their effect on the cereal sector. Pig farmers support a sustainable environmental policy for Ireland but there is a danger that a few broad strokes to solve a perceived problem will close down a large element of animal production along with dependent sectors, without any improvement in environmental standards.
If it is not possible to win special relief for these two sectors the Government needs to review its approach from the start to the implementation of this directive to take account of these sectors. I thank the Chairman and committee members for their attention.