An Taisce has questioned the “robustness” of environmental assessments accompanying the Agri-Food Strategy, and their compliance with EU law.
The environmental-awareness organisation expressed concern in its submission to the public consultation on the environmental assessment of the Draft Agri-Food Strategy to 2030.
In relation to this submission, it said it had “serious concerns regarding the standard of assessment for both the Strategic Environmental Assessment and the Appropriate Assessment”.
Included in its submission, An Taisce queried the scientific evidence necessary to show that there would be no ill effect on Natura 2000 sites as a result of the strategy.
“It is our considered opinion that the Natura Impact Statement (NIS), as presented, fails to provide the scientific evidence and level of certainty which is necessary for the decision maker to conclude beyond reasonable doubt that the plan or project will have no adverse impact on Natura 2000 sites,” it said.
It added that the mitigation measures are “vague, non-binding and do not present detailed analysis of how they will counteract the ongoing declines for Irish natura sites as a result of agricultural practice, as acknowledged by the National Parks and Wildlife Services (NPWS) and the introduction of this NIS”.
What is Natura 2000?
Stretching over 18% of the EU’s land area and more than 8% of its marine territory, Natura 2000 is the largest coordinated network of protected areas in the world. It offers a haven to Europe’s most valuable and threatened species and habitats. Source: European Commission.
An Taisce said there is a “reliance on existing measures, which have been shown to be ineffective for the protection of Natura 2000 sites from agriculture”.
It added that there is also a dependence on plans and strategies that are, as yet, unproven in relation to their efficacy.
“We would reiterate that the NIS specifically outlined that the actions within the Agri-Food Strategy are critical in determining the future direction of these impact pathways, and that the Agri-Food Strategy addresses all these issues in some detail and provides appropriate mechanisms for reducing and counteracting impact pathways.
“We would highlight that is clearly not the case, and no such evidence is provided in the NIS document before us.
“As such, the potential impact has been identified, the importance of mitigation measures has been underlined, but no sufficient mitigation measures have been provided. Therefore, we submit that this is a clear failure within the NIS document.
“We are of the view that the Department of Agriculture, Food and the Marine cannot sign off on the Agri-Food 2030 from a legal perspective, as the NIS does not provide the necessary legal certainty as required by Article 6(3) of the Habitats Directive.
“To do so would be in contravention of the Habitats Directive, and subject to legal challenge on those grounds.”