The Northern Ireland Grain Trade Association is pleased to have the opportunity to respond to the consultation on the proposals’ for taking forward NI climate change legislation.

The association represents the businesses which supply the animal feeds and fertiliser required by the provinces farmers and which are a vital link in the local food chain.

The agrifood sector in Northern Ireland is our biggest private sector employer (supporting 100,000 jobs) and is our biggest export earner. The sector is based on intensive livestock production and the substantial growth of recent years has been built on the high levels of husbandry and stockmanship on our family farms, supported by sophisticated processing and marketing organisations.

The chart below details the growth in value of the sector in the last 20 years and highlights the extent to which export markets have been developed and have become essential to the economy of the Northern Ireland.

Source: www.dardni.gov.uk

Over 70% of the product from the sector is now marketed outside the province, with mainland UK the main consumer, but with significant exports placed on the wider global market.

The increase in production over the last twenty years has been achieved through efficient farming, a high level of nutrient management and through much improved use of resources.

Farmers have made substantial reductions to the carbon footprint of every litre of milk or kilo of meat produced over this period and continue to strive for further reductions supported by highly effective and well focussed industry led initiatives.

The Greenhouse Gas Implementation plan is promoting a program of measures to drive nutrient efficiency and reduce GHG Intensity under the heading - “Efficient Farming cuts Greenhouse Gases”. The major potential of pastures to sequester carbon is being fully explored and guidance issued to farmers on how to maximise the carbon sink effect of grassland as well as the trees and hedgerows.

Our association, representing the businesses which supply feeds and fertilisers to farmers have actively invested in Research & Development and in staff training to ensure not just the efficacy of products supplied but that the correct advice and guidance is provided at the point of sale by competent staff. The Feed Advisors Register (FAR) promotes professional standards through an online CPD training program with verification of technical competence. 120 field sales advisors are currently registered and receiving ongoing training on precision nutrition to minimize the environmental impact of intensive farming. This approach has led to much more efficient use of farm manures – resulting in a 50% reduction in the use of chemical fertilizer in the last 20 years.

N. Ireland has a world class food industry producing quality food with a low carbon footprint.

The intensity of emissions has been reduced through precision farming and will reduce further through industry programs. As an industry we are concerned that the Climate Change Bill, by setting absolute limits on emissions will create a one dimensional approach which overlooks the great improvements in GHG intensity and the considerable mitigation effect of pastures sequestering carbon. Limits which restrict the productivity of our efficient and sustainable local farms will impact on the economy of Northern Ireland but will also lead to an increase in imports of food from regions where the carbon footprint is much higher. There is a real risk that we end up with a perverse outcome whereby the most efficient region in environmental terms is prevented from developing its output while the increasing demand for food is met from the less efficient producers.

A flexible approach based on lowest carbon intensity per kilo of output and factoring in the contribution of farmland to sequestration would create a framework that promotes carbon efficient outcomes rather than off-shoring our agrifood industry to the less efficient regions of the world. The current industry program supported by incentives in the form of the various Rural Development Program (RDP) initiatives are influencing farmer behavior and producing environmental benefits in a way that cannot be delivered through regulation.