I attended the recent IFA meeting in Upperchurch, Co Tipperary about the compulsory use of the trailing shoe and other approved low-emission slurry spreading (LESS) technologies in hilly areas.

Depending on who you talked to, there were anywhere up to 350 people in attendance. It’s hard to say if this was accurate. But the hall was certainly packed to the rafters, and a considerable number of the attendees came from far beyond Tipperary.

The IFA has clearly hit on an emotional issue. They’ve focused on the adverse health and safety aspects of using the trailing shoe in upland areas.

I understand from contractors that up to now, the trailing shoe is used on relatively flat land and the splash plate is used on higher ground. On really high ground, no slurry or chemical fertiliser is applied.

Trailing shoe

None of the contributors from the “top table” or “the floor” were critical of the trailing shoe where it could be used safely. This was a very positive message. LESS is clearly viewed in general now as a cost-effective mitigation technology, alongside other measures, such as the use of protected urea.

Two issues struck me about the situation as I reflected on the meeting. The first concerns the suddenness with which the core issue emerged on the agenda. When I chaired the Dairy Vision Group for instance, not once was the issue raised by the farm organisations.

Farmers achieved a major victory in respect of the climate change negotiations in effectively halving the required reduction in emissions to 2030 relative to what all other sectors have to face.

But that success was in part achieved by concessions in other areas such as the provisions involving the use of LESS.

As is nearly always the case, concessions only come to light when their implementation is imminent. In these circumstances, the issue is treated as a stand-alone matter and the bigger picture tends to get missed.

The second, and more important matter, is that the issue raised by the use of the trailing shoe highlights the utter inefficiency of a regulatory approach to tackling climate change. Economists loathe regulation relative to the pricing-of-pollution approach.

A regulation imposes a straitjacket approach to compliance that can result in unintended and often undesirable outcomes. It also focuses on what a farmer does rather than what he or she achieves in terms of mitigation. All of us should be focused on how we can reduce our climate change footprint.

Cost-effective methods

Of course, we have to use all methods that are available in the most cost-effective way. So if a farmer knows what his baseline level of greenhouse gases is, and is given a required reduction in that baseline, economists would say that he should be allowed to achieve that target in whatever way he or she sees fit.

They will be judged solely on how they succeed, not on whether they used one particular technology over another.

In this framework, a farmer in a hilly area might decide to use the splash plate to apply slurry but then use less chemical fertiliser to compensate. But consider a different scenario.

If the farmer is forced to use a combination of technologies that could, on the one hand, endanger his own health and safety but, on the other, create additional emissions, most reasonable people would see this as absurd. And yet as long as we adhere to a regulatory approach, this kind of situation is likely to prevail.

Tackling sustainability on farms from a climate change, biodiversity, or, water quality perspective has to allow the farmer to exercise flexibility.

Each farm is unique in terms of its scale, soil type, typography etc, and the farmer is in the best position to decide what will work best in their own situation to address the achievement of sustainability.

There is much in the argument that flexibility should extend to the curtailment of agricultural emissions that embraces net emissions, and land use change, including the production of renewables.

The establishment of rigid targets for these different activities confounds flexibility and is anathema to the way that most farmers think about the running of their farms.

Regulatory approach

It is likely that the continuation of a regulatory approach will give rise to other issues, like the one highlighted at the Upperchurch meeting.

The alternative approach where farmers would be assessed in terms of their emissions relative to a baseline would probably be administratively difficult and costly to implement, especially in the set-up phase.

But it is likely to emerge as the preferred approach in time and it is being considered in New Zealand. In the meantime, we will have to deal with forcing the adoption of some mitigation technologies that will make little sense in some circumstances.