In its submission Teagasc identified the significant practical and logistical challenges faced by farmers and advisers in implementing the nutrient regulations. In some cases this has led to significant structural P deficits on farms. Director of research in Teagasc, Dr Frank O’Mara said that the current format for implementing the regulations may be over complicated, imposing a significant and unnecessary administrative burden on farmers and agricultural advisers. Teagasc is proposing that the method of calculation of nitrogen and phosphorus allowances is rationalised and simplified.

Regarding the closed period for spreading of animal manures, Teagasc is proposing that the flexibility in the implementation of the “closed periods” applied by the Minister in 2008 and 2009 is regularised and based on an objective assessment of environmental risks.

Teagasc acknowledges the challenges that the Nitrates Regulations present for pig and poultry producers. Changes to the Nitrogen index for tillage crops are proposed to encourage the use of pig and poultry manure by tillage farmers. It is also proposed that the provision of manure storage facilities on tillage farms be encouraged and supported to ensure that the manure is available during the limited time period it can be applied.

Teagasc also propose that the current regulations on the management of soiled water can be simplified.