I thank the Chairman and members of the joint committee for giving us the opportunity to address this important issue. I am an agricultural adviser at Barryroe Co-operative Society Limited having graduated from UCD with a masters degree in agricultural science and, subsequently, a diploma in environmental science. I am joined by Mr. Sean O'Sullivan and Mr. John O'Donovan who is vice-chairman of Barryroe Co-operative Society Limited as well as a board member of Cork Co-operative Marts. The key issues I will address are organic nitrogen limits, spreading dates, slurry, storage and, to get down to brass tacks, the effect on the local economy.
Carbery creameries, with a base of over 1,800 milk suppliers and a milk pool of 79 million gallons, covers four co-operative areas which I represent today. They contribute more than €175 million to the economy of the local south-west area annually. The three dairy co-ops in north-west Cork — Boherbue, Newmarket and North Cork — which we also represent today have a combined milk pool of 20 million gallons supplied by another 320 farmers.
The competitiveness of our co-ops is directly related to the competitiveness of farmers. The natural economic and environmental advantage in this southern region is their ability to grow and graze grass at reasonable stocking rates for up to 330 days of the year. Some of the terms under the draft action plan will impinge on the natural competitiveness of the area and the agri-industry in general.
The draft action plan, as it stands, fails on a number of levels. It ignores that nitrate levels have been improving in recent years and will continue to do so. It attempts to put in place expensive infrastructure without taking account of farm practices and local farm conditions. Ultimately, it will undermine the competitiveness of the agri-industry from farm gate to processors to exports.
On organic nitrogen limits, it is our view that a 250 kg of organic nitrogen per hectare of organic manure limit is vital for the future survival of the dairy, beef, pig and poultry industries in the area. Paragraph 2(b) of Annex III of the directive allows for approval of amounts of up to 250 kg of organic nitrogen per hectare. The scientific rationale for our view is based on a long growing season — there is plenty of literature to show we have 330 days growth every season; a long grazing season — with new management practices this can be up to 330 days; adequate rainfall with high denitrification capacity; a predominantly grassland countryside; good crop nitrogen uptake; low atmospheric deposition; and good farming practices.
Farmers in the region must be able to exploit the natural advantages of a mild climate and a longer growing season to maintain viable family farms into the future. Furthermore, if the beef, pig and poultry industries are to be maintained, achieving a derogation to this level is of paramount importance.
The periods proposed in respect of both storage capacity and the land spreading of organic manure are 12 and 16 weeks, respectively, in the Brosnan report and the action plan submitted. We firmly recommend that these be upheld for zone A. Through the process of consultation, all parties agreed — painfully — to accept the Brosnan report which was considered fair. We contend that in free draining early grass growing areas such as those in our hinterland, little nitrate leaching occurs where organic manure is spread in good conditions in early January. I concur with Mr. Dillon's statement that support for the putting in place of storage capacity should be forthcoming from the Government.
A further increase in the closed period as proposed in the action plan may defeat its own objectives in reducing pollution and improving water quality. Because of a lack of labour at farm level, contractors spread a sizable percentage of the organic manure generated. Too long a closed period would further increase the risk of pollution as tanks may overflow as available contractors struggle to service their farmer clients. Widening the spreading period would spread the workload, reduce capital expenditure on farmers and contractors and, most importantly, reduce the risk of pollution, which is what we are trying to achieve in the action plan.
The nitrates directive is appropriate in continental Europe where soil temperatures and growth over four to five months of winter conditions are close to zero. In Ireland, however, especially the south, south east and parts of the west, soil temperatures are higher while growth rates cannot be matched elsewhere in Europe.
No account is taken of the effect of implementation of the action plan on the rural economy outside the farm gate. Within just a 30 mile radius of our area, many jobs are endangered. There are four co-ops within the area with 250 workers; Carbery Milk Products Limited has 500 workers; AIBP has 140 workers and processes 65,000 cattle per annum within an 80 mile radius while Cork Marts has 100 workers. Stauntons, Clona, Irish Yoghurts and others will also be affected. Under the nitrates action programme, all of these groups face a bleak future. They provide the main market for local farmers, provide hundreds of jobs and export local produce.
The Department's figures for the numbers of farmers affected by the directive are flawed. They do not take account of the fact that piggeries, poultry units and food processors such as Carbery Milk Products Limited and others must export organic manures to other farms to recycle nutrients to replace purchased fertiliser. Carbery Milk Products Limited needs approximately 10,000 acres of spread-lands to export organic manure and expects this figure to increase to 17,000 acres. Under the proposed action plan, this required acreage must be increased with associated costs. It is possible that Carbery Milk Products Limited will have no outlets in a mainly grassland area with organic nitrogen limits in excess of 210 kg per hectare. There will also be a knock-on effect for tillage farmers supplying grain to service the feed mill industry as well as associated employment in each of the mills.
On the effect of the action plan inside the farm gate, many efficient dairy or beef farmers in the area are stocked at a figure greater than 210 kg per hectare limit. Placing a 170 kg limit on them would effectively cause them to reduce output by at least 20% or incur unnecessary storage and land costs to maintain production. With 79,000 cows producing approximately 79 million gallons of milk, a further 15,000 acres will be needed to sustain milk production in the area but no new land is available. Some 20,000 cattle will be displaced by this process if dairying is to continue.
At a recent meeting we were advised by Dr. James Humphries of Teagasc that milk production could survive at extra cost if dry-stock enterprises were dropped. This implies that neighbouring pig and poultry units should also be left out of the loop to satisfy the organic limit requirements. It is outrageous to think that overnight many farmers will be impeded in their capacity to generate income to maintain any semblance of a livelihood.
I conducted a survey of 40 commercial farmers in the area last year with the ability to use their natural resources. They are not sofa farmers. They make use of early and late grass growth in contrast to continental European farmers. The typical system is dairying and replacements with some engaging in bull beef finishing and the keeping of breeding stock as secondary enterprises. The result of my survey was that the organic nitrogen level on the farms in question was approximately 219 kg per hectare. This does not take account of the fact that, because of the vibrant pig industry in the area, many of the farmers concerned also import pig slurry. If this was taken into account, many would be at the 250 kg per hectare level. The average figure for storage capacity was ten to 11 weeks. Typically, all of the farmers concerned graze their animals when conditions allow. Many of the animals would be kept fully indoors for six weeks and graze early and late. This sustains higher stocking rates.
A commercial farmer with a quota of 80,000 gallons, owning 86 acres and renting 15 would have an organic rate of 222 kg per hectare. Under the new regime, at 170 kg per hectare, he would need an extra 30 acres of land, at a conservative price of €150 per acre, to sustain current stock numbers. Even if he or she made a profit of, for example, €50 an acre on that extra land, it would still involve a lay-out of €3,000 per year. He or she would also, conservatively, have to spend €24,000, after the payment of the grant, on extra storage capacity for a six week period. This amounts to approximately another €3,000 per year over ten years. The overall loss of income involved would be €6,000 per year. If the farmer concerned did not get it right straightaway, his or her single farm payment would also be in the balance. These figures exclude the cost of nutrient management planning and others.
Another issue of concern is the duplication of records. Records must be minimised and simplified. This is possible with modern technology. The CMMS, cattle movement monitoring system, and lACS, integrated administration and control system which deals with area aid matters, should be adequate for competent authority registration purposes. Other farm records being demanded are of no use in the implementation of a successful action plan and will serve only to increase bureaucracy and drive farmers out of business. Farm inspection protocols must be clear and communicated to all farmers. An appeals process should also be available to deal with exceptional circumstances.
On the Government proposal for a derogation, section 3 of the Government consultation document on water quality gives an overview of water quality as backup to the derogation proposal. More up-to-date data showing further improvements in water quality should be presented, for example, that given by Frank O'Flynn to Cork County Council in Blarney last year. It is ironic that in a document making our case for a derogation there are nine pages of data on Irish water quality but only three paragraphs devoted to a favourable comparison with the European Union 25. If we want to make a strong case for a derogation, we should emphasise our climatic and water quality advantages in comparison to the other member states of the European Union rather than point out the glitches in our armour. At every step we should compare our figures with those of our EU counterparts.
Aside from the proposal, it must be argued that any pollution is predominantly point source pollution caused by a minority, be it agricultural, industrial or domestic. In this context, it is unreasonable that the majority should be subjected to such regulation when science can easily prove that it is easily possible to farm at organic levels of up to 330 kg of organic nitrogen per hectare without environmental consequences. On the justification for a derogation, section 6 contains a lot of valuable scientific backup information but does not go far enough in emphasising the unique differential with the rest of Europe.
The action plan has many worthwhile points. We recognise that improvements must be made on-farm to protect our environment. The most serious issue which we would like the joint committee to push for us is the serious justification for a 250 kg of organic nitrogen per hectare limit based on a long growing season in well run grassland or tillage farms. This is the most serious issue facing farmers and agri-business. We have the natural advantages of a mild climate and good farming practice.
As stated in the Brosnan report, the maintenance of the closed period from 15 October to 2 January for zone A is a further issue which should be defended robustly. Any new system should be low cost or free while unnecessary paper trails should be avoided. The current requirements for record-keeping are intrusive and should be revised.
Common sense backed up by science and strong leadership from the Government are needed to bring the nitrates action programme to a successful conclusion. The French can grow grapes — we should be allowed to grow grass.