Ireland’s proposed eco-scheme under Pillar I of the next Common Agricultural Policy (CAP) from 2023 will need improving, the European Commission says in its observation letter.
Ireland submitted its CAP Strategic Plan for 2023 to 2027 in late December and, at the end of the last month, the commission sent back its observations, in which it assesses whether or not the plan measures up to EU regulations and aims, particularly where the environment is concerned.
And according to the observation letter seen by Agriland, the Department of Agriculture, Food and the Marine will have to make some changes.
This is true of some parts of the strategic plan and not others, where the commission is more positive.
However, one area where the commission’s criticism is notable is on the eco-scheme, which is a new addition to the next CAP and is funded through 25% of a member state’s Pillar I budget – previously reserved mainly for direct and ‘Greening’ payments.
The commission says it has concerns on the overall design of the eco-scheme proposal, as well as on the scope of some of its options.
The single rate of payment for farmers – which the strategic plan puts at €77/ha based on an average uptake – is an issue for the commission as the likely large difference in the cost or income loss for farmers of the scheme options might lead to low compensation for some farmers, or possibly too high for others.
This can discourage farmers’ uptake of the most demanding options such as planting trees or hedgerows, or maintenance of landscape features and non-productive areas, the commission argues.
The commission recommends keeping a “reasonable link” between the unit amounts and the calculation of costs incurred and income foregone, to ensure that the more demanding options in Ireland’s eco-scheme are not side-lined by the less demanding ones.
Ireland is also requested to explain how it intends to ensure an adequate uptake for the practices with a higher environmental effect.
According to the commission, there is no incentive for farmers to subscribe to options that can have a higher environmental benefit.
The commission also takes issue with how the €77/ha payment rate was arrived at, saying that the link between the level of payment and the level of uptake was not clear.
According to the commission, the level of payment needs to take into account the level of sustainability and “ambition” of each eco-scheme option, based on “objective and transparent criteria”; and that the linking of payment rates to uptake is not in line with EU regulations.
The observation letter contends that some options would have only a modest benefit to the environment and that the eco-scheme as a whole would not result in a substantial change of farming practices and an improvement of Irish farming’s environmental footprint.
The commission calls on Ireland to “strive for an eco-scheme that ensures a balanced approach between simplicity and appropriate environmental ambition”.
In drafting the CAP Strategic Plan, Ireland chose to use three ‘result indicators’ for the eco-scheme from a list of indicators provided in EU regulations. However, the commission questions Ireland’s use of these three specific indicators in relation to the eco-scheme.
These results indicators outlined in the plan are:
- Amount of land related to improved nutrient management;
- Amount of land related to sustainable use of pesticides;
- Amount of land related to supporting biodiversity conservation or restoration.
The commission believes that the choice of these three indicators will not fully capture the contribution of the options involved to the objectives required by the EU.
Ireland is being asked to review the list of available result indicators and set more specific indicators for each option, as the observation letter argues that there are other indicators that are more appropriate for some of the scheme options.
Furthermore, the commission says that the indicator relating to pesticides is not covered by any of the options in Ireland’s eco-scheme plan (except possible indirectly through the use of GPS-controlled equipment).
As well as that, the observation letter states that all eco-schemes must provide a contribution to result indicators on income support; redistribution to smaller farms; and enhancing support for farms in areas with specific needs.
While these indicators do not reflect environmental benefits, the commission notes that they provide information on key objectives related to direct payments.
So, work to be done for the department…