Dear Minister,
On behalf of the Northern Ireland agri-food industry, we are writing to formally respond to your recent announcement of a second phase consultation on the proposed Nutrients Action Programme (NAP) 2026–2029, and the establishment of a stakeholder “task and finish” group.
We cautiously welcome your decision to engage further with industry stakeholders to develop NAP policies and to invite further consultation following the procedural flaws identified in the current process.
Sectoral commitment and importance of farm-level policy
The agri-food sector is fully committed to improving water quality and the sustainability of the environment within which it operates, working in partnership with your Department to support and shape further progress. However, it must be recognised that for over two decades, farmers have complied with detailed regulations around nutrient storage, application and record keeping. Many have also made substantial investments in infrastructure and management systems.
Any developed policies must be genuinely workable at farm level, taking into account the realities of farming calendars, capital investment requirements, planning and permitting constraints, supply chain dependencies and the need for policy stability to support long-term investment. This is critical in supporting farmers to implement solutions within the day-to-day operation of their businesses. Solutions which enable them to meet climate and environmental obligations as noted in the Programme for Government, while also sustaining economic viability and innovation. Policy must not place unfair regulatory burdens on the industry or undermine confidence in the very transition it seeks to promote.
Due to the agri-food industry’s commitment to improving water quality and the importance of suitable farm-level policy, we will be responding to the current NAP consultation and will also be encouraging farmers and others to respond. Their professionalism and expertise is essential in creating a NAP that works with farmers.
Engagement with stakeholder group
It is equally important that industry is involved in the proposed stakeholder task and finish group, and we formally confirm our participation. We welcome your commitment that this group will be asked to explore and develop alternative solutions beyond those already suggested.
The formation of the stakeholder group is a necessary step in correcting the deficiencies in the current consultation and in building a collaborative path forward. The process must empower this group to identify and propose credible, evidence-based measures which can deliver environmental improvements while maintaining the economic and operational sustainability of farm businesses.
We emphasise the importance of clear, transparent governance. The task and finish group must operate under clearly defined and agreed terms of reference established at the outset. These should cover its scope, decision-making process and evidence-gathering framework, and confirm that the group is not constrained to simply refining the existing consultation proposals, but is empowered to consider new and alternative solutions.
The group must be properly resourced and given adequate time to carry out its work, properly supported by an independent chair with a strong understanding of agriculture and the rural economy. The chair must be capable of facilitating meaningful engagement and leading the group to develop realistic and fair proposals. We also seek clarity on how the external facilitator will be appointed and confirmation that all relevant industry organisations will be invited to participate fully in the group.
Given the significant economic and planning implications of any future proposals, we strongly recommend that officials from the Department for the Economy and the Department for Infrastructure are involved in this process.
Economic assessment and further public consultation
We note that a draft economic impact assessment will be prepared during the stakeholder group process. It is essential that the group is able to contribute substantively to this work, drawing on its expertise and insight. The assessment must be robust and its conclusions must properly inform the next stage of policy development.
We also welcome your commitment that a further public consultation will take place after the stakeholder group has concluded its work and submitted proposals for Ministerial consideration.
Conclusion
The Northern Ireland agri-food sector is one of our most strategically important industries, contributing nearly £9.4bn in output and supporting over 113,000 jobs. The stakes in this process are high, not only for environmental protection but also for the resilience of the rural economy.
Farmers are understandably anxious about the impact of the current proposals, and the wider policy landscape around ammonia, climate action, bovine TB, and sustainable agriculture must be considered in tandem.
We trust that you will reflect carefully on the concerns raised in this letter and take the necessary steps to restore confidence in this process and to ensure that meaningful solutions can be developed in partnership with the industry.
We look forward to your response.
Yours sincerely,
- William Irvine, UFU President
- Norman Robson, NI Pork and Bacon Forum
- Eva Ross, Head of Commercial Partnerships, Yara
- Daryl Mclaughlin, NI Meat Exporters Association
- James Lowe, NI Agricultural Producers Association
- Jonathan Dunn, Chairperson, Ulster Arable Society
- Trevor Lockhart, Group Chief Executive, Fane Valley Co-Operative Society Ltd
- Edward Adamson, NI Chairperson, National Sheep Association
- Damian McCloskey, Chairperson, The Agricultural Consultants Association (ACA (NI))
- David Rankin, ACA (NI) Representative, The Agricultural Consultants Association (ACA (NI))
- Ian Stevenson, Chief Executive Officer, the Dairy Council for Northern Ireland
- Colin Kelly, Group Chief Executive Officer, Lakeland Dairies
- Nick Whelan, Group Chief Executive, Dale Farm Ltd
- Paul Vernon, Chief Executive, Leprino
- Brian Hanafin, Head of Milk Pool & Technical Development, Tirlán
- Justin Coleman, Poultry Business Unit Director, Pilgrims Europe
- Tony Demaine, Site director, Cranswick Country Foods (Ballymena)
- Vincent Grant, Director, William Grant and Company LTD
- Christopher Frizzell, Director, Pig Procurement & Finishing operations, Sofina Foods Europe
- Kenneth Irwin, Managing Director, AN Irwin Feeds Ltd
- Michael Redmond, Director, Ballinaskeagh Grains Ltd
- David O’Connor, Trade Manager for Ireland, Cefetra Ltd
- James Chesnutt, Managing Director, Chestnutt Animal Feeds
- Tony McEntee, CEO, Devenish Nutrition
- David Aiken, Director, F S Herron Ltd
- Garth Boyd, Managing Director, Fane Valley Feeds
- Gareth Anderson, Director, FarmGate Nutrition
- Joe Gilkinson, Managing Director, Gortavoy Feeds and Farm Supplies Ltd
- Tony McIvor, Sales Manager, Goulding NI
- Gordon Donaldson, CEO, John Thompson & Sons Ltd
- Colin Purdy, Managing Director, Mason’s Animal Feeds
- John Moore, Managing Director, Moore’s Animal Feeds Ltd
- Gill Gallagher, CEO, Northern Ireland Grain Trade Association Ltd
- James Ambrose, Area Manager, Phileo UK and Ireland
- Michael McAree, Director, Precision Liquids Ltd
- Tim Trail, Managing Director, Strabane Mills Ltd
- Graham Booth, Owner, T. J. Booth & Sons Ltd
- Ian Hutchinson, Managing Director, Thomas Hutchinson & Sons Ltd
- Aidan Fisher, Country Manager, Trouw Nutrition Ireland
- Kieran Shields, Managing Director, Tullyherron Farm Feeds Ltd
- Clarence Calderwood, Managing Director, United Feeds Ltd
- Niall O’Donnell, Managing Director, United Molasses (Ireland) Ltd
- Charlie McAllister, CEO, Barnett-Hall
- Charles Crawford, Ready Eggs & Skea Eggs
- Foyle Food Group
- Dunbia
- ABP Food Group
- WD Meats
- C&J Meats
- Hewitt Meats
- Bawn Bua Foods
- Kirsten Dunbar, President, NIVA
- Mel Spahn, President, AVSPNI
- Sarah Clarke, Technical Manager, Robert Clarke (Keady) Ltd
- Michael Bell, NI Food and Drink Association
- Conal Donnelly, CEO, Countryside Services Ltd
- David Linton, Barenbrug, UK agriculture commercial manager
- Gareth McDonald, Co-founder and CEO Farmdrive
- Allister Erskine, Aurio Co Op
- Susan Wilson, Director, Aphaeas Agriculture Limited
- Timothy Savage, Central Chemical Supplies Ltd.
- Kenny Hanna, Rural Chaplain
- Ronan McKee, Directors at FMK Architecture Ltd
- Jason Fleck, Directors at FMK Architecture Ltd
- Larry Burke, CEO, Ai Services NI
- Kenneth, Valerie, James, Amy and David Flanagan, Drumnahoney Farm
