The Northern Ireland Grain Trade Association is pleased to have the opportunity to respond to the consultation on the Review of Northern Ireland’s non domestic rating system. 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.
Re Question 6 - Should Freight and Transport Relief be removed?
Our association is strongly opposed to the removal of Freight and Transport Relief.
Re Question 6a - What would be the potential consequences of such a move?
Removal of the relief will add cost and reduce the competitiveness of local agricultural businesses.
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 provinces agricultural land and farm structure is largely unsuited to grain production and the vast majority of the feed materials required to support livestock production are imported from Eastern Europe, North America and South America. The provinces ports receive around 2.2 million tonnes of grains and protein feeds each year, and with no manufacturer of chemical fertilisers in Ireland, a further 0.25 million tonnes of fertiliser also arrives by ship.
Over 70% of the product from the sector is marketed outside Northern Ireland, with mainland UK the main consumer, but with significant exports placed on the wider global market.
In simple terms the agrifood sector imports around 95% of its input requirements and exports over 70% of its product. This emphasises the reliance of the sector on the provinces port facilities.
Our concern is that anything which increases the cost of operating these facilities has a double impact on the agrifood sector – a sector which is already suffering heavily from low global demand and prices which are below the cost of production for many commodities.
- Category: Consultations
The Northern Ireland Grain Trade Association represents the importers, manufacturers and distributors of feedstuffs to livestock producers in Northern Ireland. The association is deeply concerned that the EU is proposing to allow member states to restrict or ban the use of authorised Genetically Modified food and feed products.
Northern Ireland imports over 90% of the feed materials it consumes and is totally reliant on the global grain market. Two million tonnes of feed materials enter the province each year from all corners of the globe and much of this material is derived from genetically modified crops grown in other countries. This material is permitted for use in the EU because it has undergone a rigorous risk assessment by the European Food Standards Authority and has been approved as safe for use in food and feed.
Like all Member States we are strongly reliant on these GM imports for the viability of our livestock industry, with 90% of feed produced containing some GM material. Soybean is the most important protein with 230 million tonnes grown globally – mainly in North and South America. Genetic modification is the norm for this crop – only around 2 M tonnes can be classified as Non GM (less than 1% of global production) This involves segregation of the crop at harvest and Identity Preservation throughout the supply chain.
Imported maize and maize by-products from the starch and ethanol industries are also key protein sources and bring the EU consumption of feed materials derived from GM crops to 32 million tonnes. Regions which reject these GM imports will be unable to sustain intensive livestock production and will face food shortages and inflated food prices.
The only demand for non GM food comes from within the EU where the feed industry offers the option of non-GM feed supply chains for specific demand. However interest in Non GM food has declined as the retailers perceived that a Non GM requirement adds cost without adding any value. Given that the market solutions already exist and non GM foods can be supplied where necessary the proposed regulation is both unnecessary and damaging.
Response to Questions
1.The sectors affected by member states banning GM food and feeds include,
a. Feed Importers and who would face massive logistical challenges and increased costs in shipping feed materials into the different regions of the EU.
b. Feed manufacturers who may not be able to trade into neighbouring states and could find it impossible to formulate feeds to meet the nutritional requirements of livestock as many key ingredients would no longer be available.
c. Farmers and consumers - Increasing the demand for non GM feed would drive up the premiums which it commands and drive up costs to primary producers and ultimately the consumer.
2. Price of Non GM feed
Currently the premium for Non GM soya is around £100/tonne - this adds about £30/tonne (15%) to the price of a typical non GM ration . However any increase in demand would immediately inflate these premiums but regardless of price, the reality is that there would not be sufficient material to meet demand in those countries ruling against GM.
3. Additional Costs
The additional costs of livestock production, food processing, distribution, retailing and the regulation necessary to police the ban would be astronomic and so far reaching as to be impossible to quantify.
4. Risks and Uncertainties
The distortion of trade which would result from some regions regulating against the use of GM would jeopardise the future of EU livestock farming, drive up prices and cause chaos in terms of logistics and labelling of product throughout the whole EU agrifood sector. Food shortages and imports of livestock products from third countries (where they would have been fed on GM materials) are inevitable.
5. Substitutes for GM feed
Intensive livestock production throughout the world depends on soybean as the principal protein source. There is no alternative which can supply the volume and quality of protein and any restriction to accessibility of soya will limit livestock production and raise costs.
Yours Sincerely,
- Category: Consultations
The Northern Ireland Grain Trade Association is pleased to have the opportunity to comment on the DARD Draft Budget 2015/16.
The rural economy needs a vibrant farm sector to keep prosperity and employment in the countryside and we believe the potential for growth in the agrifood industry is the major opportunity for the economy in Northern Ireland.
We had hoped that the budget proposed by DARD would recognise this opportunity and direct all available resources to the support of competitive and profitable food production . We note with concern the absence of an immediate response to the urgent needs of the industry for funding initiatives to progress the Going for Growth Strategy which is so important to the development of agriculture in Northern Ireland.
This can only result in a serious loss of momentum which will undermine the good work which has been carried out to date. It is disappointing to see scarce resources used for projects which do not bring any benefit to the industry.
We have indicated our opposition to the move of the DARD Headquarters to Ballykelly in earlier communications and it is disappointing to see that this project remains a priority. I trust these comments are useful and hope that they can be given serious consideration.
Robin Irvine NIGTA
- Category: Consultations
The Northern Ireland Grain Trade Association is pleased to have the opportunity to comment on the Feed Law Enforcement Guidance Document Review.
We are happy with the general principle of earned recognition as it gives tangible benefit to businesses which achieve consistently high standards of management controls and feed safety as demonstrated by their compliance with the relevant industry assurance schemes.
With the possibility of charges for enforcement activity in the future our members will be very conscious that every inspection visit or sample taken could have a cost. Lighter touch regulation will be welcome particularly where existing controls and available information is recognised and the focus is on risks which are not already well covered.
Accredited assurance schemes developed by the industry and audited by independent 3rd party bodies are now in place throughout the food chain and have played a vital role in raising standards of safety and risk management. The schemes developed by the Agricultural Industries Confederation (AIC) are in widespread use - in the feed sector these include UFAS, FEMAS, and TASCC which have become the accepted standards for the industry.
In Northern Ireland the recent launch of the Food Fortress program has been well received by the trade and this now comprises 45 feed businesses covering 99.9% of compound feeds produced in the province. This brings an extra level of surveillance with a strategic sampling program covering the principle risks across the range of feeds every month of the year. We feel that this program should earn an additional level of recognition for its members as it adds a significant bank of test results which are shared with regulators on a regular basis. This information can be used to inform the risk assessments carried out by DARD/FSA and allow them to focus their attention on risks or businesses not covered by the Food Fortress.
The proposed testing frequency for different activities seems reasonable for businesses within an accredited scheme which is subject to annual audit. We would have concerns that there is very little difference in frequency of inspections between these operations and non scheme businesses - ie there is not a sufficient level of credit allowed for scheme membership. Non scheme businesses, not subject to the discipline of an annual audit would present a much higher risk and this is not reflected in the proposed testing regime.
We would also wish to see a higher level of control around the area of co products and surplus foods entering the food chain. The management of these materials from food producer through to storage on farm should be given a high priority particularly if there is no appropriate quality scheme in place.
The principle of unannounced inspections may also cause some difficulty in that it is important that the appropriate personnel are on hand to meet the inspector and deal with queries and questions which may arise during the visit.
I trust these comments are useful and we look forward to working with FSA on the detail of the proposals.
Robin Irvine
NIGTA
- Category: Consultations
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.
- Category: Consultations
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