27 May 2025

Dear Minister Muir,

As you are aware, the Northern Ireland (NI) agri-food sector have significant concerns regarding the measures proposed within the consultation on the Nutrients Action Programme 2026-2029.

We are particularly concerned about how the science is being used, the complete lack of economic impact analysis and inconsistencies between certain measures within this consultation document and other policies which make it difficult for stakeholders to comment on these proposals. While we welcome the recently announced extension to the consultation period, this is not adequate given the scale of potential impact and the significant concerns we have with the consultation document alone. For these reasons we are asking you to suspend the current consultation process.

We would ask that senior officials directly engage with industry leaders and other relevant stakeholders, working together to develop a set of proposals with incremental steps that will find a balance between improving the environment and maintaining a viable agricultural industry in NI.

The NI agri-food sector is a key contributor to economic output, employment and the rural economy. The gross output of agriculture in 2023 was £2.87bn, while the gross output of food and drinks processing was £6.5bn.

The ripple effect is even greater when the indirect contribution of a wide variety of ancillary sectors is taken into account such as construction and logistics.

The impacts of these proposals will be far reaching for the rural economy and indeed all of NI and it is therefore untenable that a proper impact assessment has not been carried out.

It is important to confirm that the industry is committed to addressing water quality issues in NI and therefore wants to be part of the solution to this ongoing problem.

For around 20 years farmers across NI have been required to comply with rules and regulations around nutrient application, storage and record keeping, and many have invested significantly to improve environmental compliance on their farm. Supply chain businesses have also been investing in, and working with their farming partners, to drive knowledge and efficiency in nutrient management and water quality improvement.

We are collectively committed to continuing this progress and working in partnership with DAERA to address this issue while supporting farmers.

However, farmers and industry are incredibly frustrated at the lack of progress that has been made by other sectors to address water quality concerns and this needs to be immediately rectified to ensure better buy-in from the agricultural sector.

In past reviews stakeholders would have met on a regular basis with officials to discuss the science, implementation and costs of proposals to find a practical way forward and it is unfortunate that this did not happen on this occasion

Many of us were present at Balmoral Show and were inundated by farmers who are extremely anxious about the proposals and the impact they will have on their farm businesses and the wider supply chain. This stress is unacceptable and could have been avoided.

The NAP review doesn’t just sit in isolation and any measures that are proposed to update for 2026-2029 need to be considered within the evolving policy landscape regarding ammonia, climate action, bovine TB and the sustainable agriculture programme.

We trust that you will consider the above and look forward to hearing from you.

Yours faithfully

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 and 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 and Finishing operations, Sofina Foods Europe

Foyle Food Group

Dunbia

ABP Food Group

WD Meats

C&J Meats

Hewitt Meats

Bawn Bua Foods

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

Sarah Clarke, technical manager, Robert Clarke (Keady) Ltd

Kirsten Dunbar, president NI Veterinary Association

Mel Spahn, president of the Association of Veterinary Surgeons Practising in NI

Aislínn Campbell, Alltech Regional Manager Northern Ireland, Alltech Ireland

Note: This list is not exhaustive and other companies may not have been able to respond in the timeframe provided