Proposals included in the draft Nitrates Action Programme (NAP) published this week have been described as “excessive” by the Irish Creamery Milk Suppliers’ Assocation (ICMSA).

The draft report outlines the measures in which protecting against nutrient pollution arising from agricultural sources can work in tandem with our food-production system and requirements.

Some of the main measures relate to maximum fertiliser rates; manure storage requirements; periods when manures and soiled water cannot be spread; as well as the establishment of a chemical fertiliser register, among others.

President of the ICMSA, Pat McCormack, has described the measures as excessive, saying they will hit the incomes of farmers, especially commercial family farmers, who he said were the “economic backbone of rural Ireland”.

“Farmers understand the water quality challenge through programmes such as the Agricultural Sustainability Support and Advisory Programme (ASSAP), the Green, Low-Carbon, Agri-Environment Scheme, and the Targeted Agricultural Modernisation Scheme,” he said.

“They are already taking measures that will improve water quality and it’s worth noting that water quality in Ireland compares very favourably with other EU countries,” he added.

“Our water quality is improving and that trend will continue in the years ahead without imposing additional regulation and costs on compliant farmers. It’s just making more expensive a policy we’re already on board with,” he said.

Cow banding – a herd-reduction policy

He identified the cow-banding proposal as having potentially very serious implications for farmers producing over 6,500kg of milk per cow.

It is akin to a herd-reduction policy, he said, adding that this particular proposal should not go ahead until further research is carried out and policy direction is available in terms of the most sustainable dairy cow going forward.

The proposal to reduce chemical nitrogen by 10% in 2022 and possibly by 15% by 2024 will, again, hit the same cohort of full-time economically vital farmers, he said.

“While we all recognise the need to use nitrogen more efficiently, arbitrary cuts like those proposed can have a serious and unnecessary impact on the farmers concerned,” he said.

In relation to the slurry spreading closed periods and the introduction of a soiled water closed period, the ICMSA president said these were also “excessive”.

The ICMSA believes that the current rules in relation to slurry and soiled water should be retained.

He said that expecting farmers to sign up to a document that will see as yet unknown scientific criteria used to extend the period to the October 15 is simply unacceptable and farmers are entitled to full information on this issue before they can make a judgement call on the matter.

“The ASSAP programme made really significant improvements in those water quality ‘hotspot’ areas it was applied and we think that should be rolled out nationwide.

“That and the Teagasc MACC curve are going to give us greater momentum in the right direction. The danger here is that we get the burden and pace wrong and end up derailing a process that’s already working,” he said.