The Department of Agriculture, Food and the Marine is currently reviewing its Common Agricultural Policy (CAP) Strategic Plan, after some areas of the initial draft received criticism from the European Commission.

However, it would appear Ireland was not alone in submitting a plan that the commission took some issue with.

A new document from the commission summarises some of the main issues it noted in the different strategic plans it received, and several of the deficiencies noted in Ireland’s proposal seem to have been replicated by other member states.

On economic sustainability and “a fairer CAP”, the commission said that member states in general needed to clarify and better justify certain decisions regarding redistribution of CAP funds.

“The sole fact that one of more interventions is used does not allow us to conclude that a sufficient redistributive effect is achieved,” the summary document says.

Many member states were also asked to clarify certain decisions around coupled income support and sectoral interventions, with the commission saying that “a lack of coherence and consistency is observed between the objectives and the design of the planned interventions”.

Furthermore, some member states did not make it clear how these income support interventions would be consistent with the Water Framework Directive.

In light of the Russian invasion of Ukraine, the commission is asking member states to consider interventions that will help reduce the dependence on fossil fuels and other externally sourced inputs.

The commission’s summary says that many member state proposals to strengthen farmers’ position in the food chain have “limited scope”. The commission suggests enhancing interventions for the formation of producer organisations and farmer participation in them.

Several member states are also asked to differentiate between on-farm non-productive and productive investments to better contribute to economic or environmental objectives towards farm modernisation.

A number of member states were asked to clarify how they intend to define features of an eligible hectare.

In relation to environmental matters, a number of member states were asked to make more of an effort on organic farming.

In general, countries were asked to amend their standards under the good agricultural environmental conditions (GAECs) so they are in line with the official EU standards, and to make these more “environmentally ambitious”.

On the eco-scheme – which must be funded through at least 25% of each country’s Pillar I budget – some member states were asked to ensure that they comply with the minimum funding requirement.

Member states have been generally asked to propose higher targets for environmental measures (with, in some cases, higher funding), and to ensure relevant links between interventions and result indicators where these links “do not seem correct”.