2019 Nitrates Derogation Review
An Taisce welcome the opportunity to comment on 2019 Nitrates Derogation Review. However, we would highlight that there is a lack of clarity regarding the exact purpose of this review, and a lack of transparency regarding the motivation to undertake this review, and in relation to the end purpose of the consultation. The review document states that: ‘The purpose of this public consultation is to seek views on the potential revisions to the terms and conditions of the current nitrates derogation’
It is outlined that the review will: ‘examine further opportunities for derogation farmers to improve efficiencies and to reduce their environmental footprint. A public consultation will provide an opportunity for stakeholders to submit their views as regard the derogation and related issues. Following this consultation, an expert group comprising officials from DAFM, DHPLG, EPA and Teagasc will draw up recommendations in relation to the conditions that show costs to farmers benefiting from the derogation. It is expected that the outcome of this review, including recommendations, will be published mid-year, in order to allow derogation farmers sufficient time to plan for 2020 and beyond.’
However, it is unclear what precisely DAFM intend to do with these responses. The current derogation runs until the end of 2021, but the document makes reference to 2020. An Taisce would query what exactly the DAFM will do with these recommendations? Will they be legally binding for derogation farmers? Will they form part of the 5th Nitrates Action Programme, or is this something the DAFM intend to implement within the lifetime of the current derogation?
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