As a member of the TB forum, I would like to say it has been extremely frustrating and difficult to make any progress in having the issues that impact directly on farmers addressed in the forum and to make any real progress in tackling the disease. We have provided the committee with a detailed submission of the proposals made by the IFA to the TB forum. I now wish to give you a summary of the key points in the IFA submission.
The effective management and control of wildlife susceptible to TB is vital in eradicating the disease from the country. This must continue to be the key policy in the enhanced TB programme. The existing wildlife control programme must be appropriately resourced to ensure timely and effective captures take place surrounding all TB outbreaks where wildlife is associated with the breakdown.
The programme must be extended to reduce densities of wildlife proactively, including deer, in advance of major infrastructural works and deforestation commencing to protect cattle from TB outbreaks that have been all too common as a result of wildlife disturbance throughout the country. Badger density reduction must continue to be the primary focus of the wildlife unit, with no further expansion to vaccination areas until concerns raised as to its effectiveness have been appropriately addressed. A national deer management strategy must be developed and resourced to reduce deer density throughout the country to the levels that are sustainable within their natural habitat and at which they are not a disease threat to farm animals. The Department must provide the supports and oversight to implement a deer population reduction programme surrounding TB outbreaks.
All controls imposed on farmers in the TB programme must have a sound scientific basis, contribute directly to the eradication of the disease, and be fully compensated for where they impact on the normal functioning of the farm. TB breakdowns do not recognise county or regional office boundaries or veterinary inspector district electoral divisions, DEDs. The Department’s management of TB breakdowns should be based on a breakdown area under single management to ensure consistency of approach and immediate access to all relevant information associated with the outbreak.
A detailed and thorough investigation of all TB breakdowns involving more than one animal must be carried out to identify and remove all sources of the disease in the herd. The Department must target resources and controls at the cases deemed to be the highest risk to remove the disease from the farm. These farms must then be allowed unhindered access to the open competitive market for their animals. These farmers must be fully compensated for all costs and losses incurred during the restriction.
Included in addressing the TB problem on these farms must be earlier consideration, if agreeable, with the herdowner of depopulation to return the farm to normal functioning in the shortest feasible timeframe. Farmers must be supported in removing high-risk animals from their farms if the Department data identify these animals as being at a higher risk of infection or likely to contribute to further TB breakdowns. All herds, once derestricted by the Department of Agriculture, Food and Marine and following intensive investigation, testing and disinfection, must be allowed free unhindered access to the marketplace.
The most suitable tests and testing approach for Irish conditions and disease levels based on solid scientific data must be used, including determining the feasibility and value of environmental screening for TB. The Department must ensure it has the oversight and effective monitoring systems in place to ensure all TB testing is carried out accurately and correctly.
The Department of Agriculture, Food and Marine should issue detailed biosecurity advice to assist farmers in reducing the contact between cattle and potentially TB-infected wildlife. Where infrastructural on-farm changes are necessary, the Department should provide financial supports to farmers to implement these changes.
The Department has identified a number of factors that contribute to TB breakdowns. In response to these risks, and in particular the findings that herds that experience breakdowns remain at higher risk for prolonged periods, the Department has proposed herd categorisation as a tool to address the risk and expedite eradication. The IFA has strongly rejected all three proposals by the Department on herd categorisation to address this risk. The IFA does not dispute the Department's findings on this risk factor. The objection is to the proposed approach in addressing this risk.
The Department's herd categorisation will only serve to increase the enormous financial burden of the controls on farmers, benefit opportunistic buyers in the marketplace having devalued animals from these herds, and fail to address the substantive issue of the ongoing disease risk left on farms or in the environment.
The IFA supports additional measures in higher risk TB breakdown herds that are scientifically based, practical and feasible to implement and that expedite eradication of the disease. These herds must be fully compensated for the losses and costs imposed by current and any additional measures in the TB programme.
The Department has identified that herds with previous TB history are at a higher risk of future breakdowns with TB. This is clearly the result of Department controls on investigations at the time of the breakdown failing to identify and remove all sources of TB from the farm during that episode. The Department proposal to address this issue by categorising these herds and only allowing trade with herds of a similar or lower status is not acceptable to farmers. It is also not feasible to implement for a number of reasons, including severe disruption to the market for live animals. This would potentially include serious implications for the vital live export trade for dairy farmers and suckler farmers and have devastating consequences for those farmers.
All farmers purchasing cattle must have confidence that the cattle allowed for sale by the Department, having met the requirements of the EU trade directives, are at an accepted low risk of being infected with TB. It is the responsibility of the Department of Agriculture, Food and the Marine to ensure all measures necessary to remove the disease from a farm have been implemented before the farm is allowed to trade. The effect on farmers during this process must be fully compensated for the impact of controls on their farm.
The Department of Agriculture, Food and the Marine, in detailing the costs of the TB eradication programme, fails to recognise the full extent of the costs incurred by farmers. To advance the discussion of the costs and benefits of the TB eradication programme in a fair and accurate manner, the Department must first recognise the full contribution of farmers to the programme. The key and substantial contribution by farmers to the programme, not being recognised by the Department, is the cost of labour incurred by farmers in assembling cattle for TB testing, the associated production loss and disinfection requirements prior to derestriction. It is notable that the only contributions made by farmers in Northern Ireland, Scotland and England and Wales to their TB programme are the contributions outlined above, which are clearly accepted and recognised by the relevant authorities in those countries. It must also be recognised that Irish farmers are unique, compared to farmers in those countries, in contributing, directly, an additional €35 million annually to the programme in the form of TB testing costs and disease levies.
The labour and other associated costs incurred by farmers in Ireland's TB programme must be fully recognised. TB testing on most farms extends to more than the assumed two days due to larger herd sizes and the dispersal of animals on fragmented holdings on smaller farms. The annual TB test imposes additional labour requirements and, in some cases, time taken off work to facilitate testing. Additional labour and costs are also experienced by herds where breakdowns occur in carrying out the obligatory disinfection. The Department requires farmers to facilitate almost 9 million animal tests each year. This can involve farmers assembling animals on up to ten occasions in a year. All of this requires significant time and labour inputs. The costs of labour alone, assessed conservatively at the minimum wage, provided by farmers the testing and disinfection components of the programme is €20 million.
It is also accepted that convening animals for TB testing impacts on the productivity of the animals and increases levels of animal health issues experienced on farms. In addition, farmers are required to provide and maintain handling facilities to allow their entire herd to be tested in a safe manner. All these incurred costs must be recognised as contributions made by farmers to the current programme. The costs outlined show an additional €20 million contribution made to the TB eradication programme by farmers which has not been recognised in the Department's published costings. The real cost of the TB programme, therefore, is €110 million annually. Of that total cost, farmers contribute some 55%, the Department 41% and the EU 9%. Farmers' direct contributions have increased since 2012 by €4.513 million or 15%, while the national Exchequer and EU contributions have reduced by €289,000 and €1.337 million respectively. When the benefits of the programme are assessed this level of funding leaves farmers with an unfair and disproportionate share of the costs in the TB programme.
The suggestion that the benefits of export market access and improved productivity are solely farm-based is incorrect.
To estimate the value of a programme which supports a sector, it is necessary to look at the impact expenditure has in the sector in its entirety. In addition, the benefits of eradicating TB from the national herd from a human health perspective must be included when identifying the beneficiaries of TB eradication and, by extension, the appropriate funding levels of all stakeholders. The committee is aware of the income crisis on farms, in particular, suckler cow and beef farms. There are a number of factors that are contributing to it that require significant Government intervention. The current TB programme imposed on farmers by the Department of Agriculture, Food and the Marine is further compounding the severe income problem on these farms and can be avoided.
In addition to the proposals from the TB forum, proposals contained in EU Regulation No. 2016/429 of the European Parliament and the Council laying down rules for surveillance, eradication programmes and disease freedom from certain listed and emerging diseases have the potential to dramatically increase the cost of the TB eradication programme in Ireland. The draft regulation lays down rules for surveillance, eradication programmes and disease freedom from certain listed and emerging diseases that will impact directly and primarily on farmers and their livelihoods. In the draft regulation the European Union is proposing a 30-day pre-movement and post-movement test for TB for all animals from herds that are over six months tested in order for herds to maintain TB free status. This targets the lowest TB risk herds in the country for additional controls. There is no justifiable scientific basis for this measure in TB eradication. In addition to the absence of a justified scientific basis for this measure to eradicate TB, the measure severely distorts the normal marketing of animals within Ireland and removes vital competition from the marketplace when associated additional costs and management practices are applied.
The Irish cattle herd consists of a large number of small-scale family farm establishments, with an average herd size of 66 animals based on the latest published Central Statistics Office, CSO, data. These establishments are heavily dependent on the vital competition provided by the live trade for their animals. The costs associated with a pre-movement and post-movement test requirement, or both, renders the live trade for the vast majority of these farmers unviable, removing vital competition from the market. Most of these farmers sell less than five animals. A pre-movement test will impose an additional cost of approximately €100 to the sale. For these low income farmers, this is economically unviable. This requirement will impact severely on marts and throughput in mart sales as the additional costs and inconvenience will drive more farmers directly to factories, removing vital competition to the benefit of factories. This proposal is not scientifically based and will be a major impediment to the competitive marketing of animals. It could cost the Irish TB programme up to €20 million a year, putting Irish farmers at a competitive disadvantage in comparison to other farmers throughout the European Union.
Irish farmers already incur a disproportionate cost burden under the TB programme in comparison with all other farmers throughout the European Union and will not accept this additional cost and anti-competitive measure imposed on them that will not contribute to eradication of the disease. The 30-day TB pre-movement and post-movement test criteria for the movement of animals within member states must be removed and member states must be provided with the flexibility to apply appropriate measures, based on epidemiological risk assessments of the situation within their country, to determine how herds maintain their disease-free status. The regulation must be consistent with the EU policy of simplification and member state autonomy. It has to provide flexibility for individual member states to apply appropriate and practical measures based on the unique circumstances that pertain and the huge variation in production systems in each country. The only beneficiaries of this proposal will be vets and factories at the expense of farmers, marts and the vital live export trade. The proposal must be rejected outright in the interests of Irish farmers and scientifically credible TB control measures. The Minister for Agriculture, Food and the Marine, his officials and Irish Members of the European Parliament must reject the EU proposal to impose a 30-day pre-movement test for animals leaving farms that are over six months tested.
I will hand back to the president to conclude.