God be with the days when former EU Agriculture Commissioner Phil Hogan expressed his view that there was too much red tape around the Common Agricultural Policy (CAP).
Indeed, another former EU Agriculture Commissioner, Mariann Fischer Boel, speaking in 2008, said that simplifying the CAP and reducing the burden of red tape was one of his “main priorities” and said that it would not be the last progress on the matter.
What has happened in the intervening decades, however, has been a layering up of rules of regulations at what seems to be an exponential rate.
Granted, not all rules are applicable to all farmers. Tillage farmers, for example, need not concern themselves with the rules pertaining to livestock, but to give you a flavour, here are a selection of some of the rules a farmer must adhere to:
You must tag calves within seven days of birth, register your calves within 27 days, BVD test your calves, ensure your livestock has two tags at all times, record the purchase, usage, storage and disposal of medication, ensure only authorised medication is used, prevent farm animals from entering the food chain until medicine withdrawal periods expire, record the purchase, usage, storage and disposal of pesticides (chemical sprays etc), ensure only authorised pesticides are used, safely dispose of empty containers, record land area to which pesticides applied, the applicable rate and dilution.
You must not cut your ditches between March and August, fence off your rivers, not spread fertiliser after September 14, not spread manure after November 1, not spread slurry after October 15, not spread dairy washings after December 1.
If spreading your slurry or muck on another person’s holding, you must notify the export of the same, with the recipient also formally recording their acceptance.
You must apply for a movement certificate to transfer animals from one holding to another, dispose of fallen animals only to approved knackeries.
Oh, and when shifting your animals, you must adhere to a raft of regulations dealing with animals in transport as well as having the appropriate class of licence for jeep and trailer as the case may be. Sticking with transport, if your fast tractor capable of travelling more than 40km per hour is used other than for purely farming purposes, you may need to get your tractor tested in a commercial vehicle testing centre.
You must spread your slurry using low emission slurry spreading equipment if you are a farmer availing of a nitrates derogation - oh and by the way, if you’re in that category you must apply for approval to obtain a derogation, prepare a fertiliser plan, record your grass growth, analyse your soil for pH, prepare and follow a multi-annual liming plan, reseeding your land must include clover, the concentrate ration you feed your livestock must have restricted protein levels between mid-April and September, spread 50% of your slurry prior to June 15 each year, consider a pollinator-friendly policy suitable for their farm, not import slurry and only plough the land only between March and May inclusive.
You must have adequate prescribed slurry storage for the number of animals you have, as well as adequate storage for dairy washings and silage effluent.
You must, in the coming years, if you have not already done cover your open slurry pits, adhere to maximum chemical fertiliser limits, and maintain a minimum stocking rate of animals on areas of natural constraint whilst not exceeding a maximum stocking rate which varies depending on whether you have opted in or out of derogation.
The number of dairy animals you are allowed to keep on your farm will depend on your average milk yield from the start of 2023 onwards, and if you are privileged enough to be a milk supplier, you must ensure your milking facilities and adhere to minimum specifications, you must report the health status of your herd, and must in virtually all cases be a member of Bord Bia. You must ensure your milk adheres to standards such as Somatic Cell Count, Thermodurics, TBC, and TCMs in order to avoid penalties.
You must have an annual TB test, and more often in the event of 'higher risk' with new rules coming in from February 2023, which will considerably increase the requirements for TB testing if moving animals from one holding to another where the annual TB test was held more than six months previously.
If tillage farming, it is a pre-requisite for most grain purchasers that you are a member of the Irish Grain Assurance Scheme, you must cultivate your tillage land within 14 days of harvest but only between 75% and 80% of said land.
You must have a sufficient variety of cropping (two-crop/three-crop rule) and adhere to sufficient boundaries to rivers and estuaries.
You will also need to plough down dung and slurry within the prescribed time frames.
You must have your sprayer tested, have completed a sprayer user course, and have obtained a pesticide user number or engage such a person to apply pesticides.
You must apply to the Department of Agriculture for screening if you intend on engaging in significant amounts of field boundary removal, recontouring of land or land drainage. You must hold a Health and Safety certificate, and register your affairs with Revenue.
These are just some of the rules that farmers must adhere to, but you better check for yourself as more rules are being added almost day by day.
Once you stay within these parameters, you’re free to farm as you choose. But wait a minute, there’s more to come, including the introduction of a new fertiliser register, nitrates stocking rates adjusting to production banding for dairy stock and enhanced TB testing requirements, all to take effect from 2023.
Layered up over years and years, the burden of rules and regulations isn’t just tying up farmers it’s strangling them.
Many farmers live in a constant state of fear that they may fall foul of a multitude of rules and regulations which would see their farm payments cut.
Perhaps those responsible might recall one too many straws broke the camel’s back.