The European Commission’s observation letter to Ireland evaluating our Common Agricultural Policy (CAP) Strategic Plan questions the level of climate and environmental “ambition” in the plan.
The word “ambition” is used several times in the letter by the commission, in relation various CAP measures proposed by Ireland.
The commission does say that the strategic plan has the “potential” for contributing effectively to environmental objectives, if certain points were improved.
For instance, the commission believes there are “gaps” between the emissions reduction Irish agriculture will require under our Climate Action Plan (22% to 30% by 2030) and the emissions reduction that the strategic plan will be able to contribute to.
For that reason, Ireland is being asked to explain how other measures would “fill those gaps”.
The commission also says that the plan does not address the need to improve sequestration from forest and woodland, and it seeks assurances that other instruments outside the strategic plan will achieve this.
As reported by Agriland earlier this week, the commission had a number of criticisms to make of the Pillar I eco-scheme, saying it could be improved in relation to extensifying livestock rearing, cutting nutrient use, and improving soil quality.
On the Pillar II Suckler Carbon Efficiency Programme, Ireland is being asked to further clarify how the supports to farmers will actually lead to the necessary net emission reduction.
In terms of the targeted land for carbon storage in soils, the plan seems to contain a contradiction between 8.88% and 9.32%, which the commission wishes to see clarified. In either case, however, the observation letter said that this figure seems low, given that Ireland has the highest percentage of permanent grassland in the EU, as well has having substantial peatlands.
Ireland’s targets under result indicators in relation to protecting soils, air quality, water quality, nutrient management and reducing pesticides also seem low from the commission’s point of view.
As Ireland’s plan outlines a “major role” for the Nitrates Action Programme in achieving some of the CAP objectives – particularly in reducing organic nitrogen output from dairy cows – Ireland is being asked to go into more detail on that.
We are also being asked to provide further information on the consistency of the CAP plan with the Water Framework Directive – including how many water bodies Ireland wishes to exempt from the requirement of reaching “good status”.
On biodiversity, the commission called into question Ireland’s target of 30% by 2030 for agricultural habitats to show improvement, saying this is not ambitious enough.
Ireland is also being called on to consider further action on freshwater habitats, heathlands, mires and bogs, particularly those outside Natura 2000 areas.
The commission notes that Ireland’s CAP Strategic Plan does not address the need of maximising the contribution of forestry to biodiversity, as there are other instruments outside the plan for this. For that reason, the commission seeks “reasoned assurances” from Ireland that these other instruments will meet this requirement.