Madam, - The fundamental impact of the EU Nitrates Directive (The Irish Times, September 21st) on farmers is to force them to reduce stock numbers. That means reduced incomes, at a time when farm incomes are already under pressure and when farmers badly need to scale up to become more competitive.
The problem with the original Irish regulations was that they were based on inadequate scientific advice from Teagasc and were in fact unnecessarily restrictive.
Following a comprehensive scientific review by Teagasc, and with the agreement of the European Commission, Minister for the Environment Dick Roche introduced revised regulations. These provided some additional flexibility for farmers while complying with the nitrates directive and safeguarding water quality.
Ireland is one of several member-states which have or are seeking derogations, as provided for under the directive itself. In Ireland's case, this is primarily to facilitate our top 10,000 dairy farmers, who account for 70 per cent of our annual milk production and are critical to our food industry.
Ireland's submission for a derogation is based on sound science, not electoral considerations or any lowering of anti-pollution standards. Irish agriculture is unique, combining 90 per cent permanent pasture and the longest grass-growing season in Europe. This allows our best grassland managers to use more nitrogen, which is taken up in higher grass growth, without compromising water quality.
It is worth remembering that the use of chemical nitrogen is down 18 per cent since 1999 and both this and the use of organic fertiliser, i.e. manure, are projected to fall further by 2010.
As regards penalties, farmers' main concern is that any penalty is proportionate to the offence involved. There is a world of difference between the penalties that should be applied to the wilful polluter and those that are appropriate for minor infringements relating to record-keeping or a stocking rate miscalculation that leaves the farmer marginally above the threshold. - Yours, etc,
TOM DUNNE, Chairman, IFA Environment Committee, Kilworth, Co Cork.