Inclusive of amendments of 30 September 2008, of 15 May 2009



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11. Promotion of Equality


While not an ‘Environmental Effect’ and as such is not subject to Environmental Assessment, it is noted that the Draft RDP makes provision for the promotion of gender equality, non-discrimination and social inclusion.

12. ALTERNATIVES


SEA requires the consideration of ‘Alternatives’ to any given Plan, Programme, or elements of either, such that the Environmental Effects of implementation would be lessened or avoided.
Firstly, it should be recognised that the central elements of the Draft RDP are essentially ‘environment focused’ insofar as they seek to enhance, improve and protect the environment in its broadest sense. Many of the Measures presented in the Draft Plan, such as the Rural Environment Protection Scheme, have been in place in generally similar form for many years. Consequently the Measures proposed in the current Draft have had the benefit of feedback from these earlier applications, thereby affording the opportunity to build in appropriate improvements where deemed necessary. In the event that adverse environmental effects arise that were not anticipated at the time of formulation the proposed monitoring over the lifetime of its implementation should afford the opportunity to generate a meaningful response.
An examination of the Draft RDP suggests that collectively the Measures proposed will do much to progress rural development in both an economically sustainable and environmentally sustainable manner. The principal alternative to the Draft RDP would be not to implement the Plan, (termed the ‘Do-Nothing Scenario’), or to drop substantial elements of it. Of particular concern in the absence of the Plan would be the potential for widespread abandonment of farmland and its environs as a consequence of a further more pronounced shift to off-farm income activity in response to the decline in more traditional farm output and income. It is self-evident that the Do-Nothing Scenario would likely result in significant adverse environmental effects across the entire range of environmental parametres (biodiversity, population, climate etc).

13. MONITORING ENVIRONMENTAL EFFECTS OF PROPOSED PROGRAMME


Given the magnitude and complexity of the proposed RDP it is of the utmost importance to comprehensively and effectively monitor environmental effects of the Programme as it progresses. Appropriate monitoring arrangements therefore need to be put in place prior to commencement of implementation of the adopted RDP.
While comments on Monitoring and Indicators are presented in this Report in the assessment section for each of the proposed Axes, this key element, ‘Monitoring of Environmental Effects’ is further elaborated on below in respect of some environmental receptors.


    1. Monitoring of the Natural Environment

Biodiversity

Biodiversity data could be effectively sourced and monitored by a range of bodies including:



  • The National Biological Records Centre (to be established under the National Biodiversity Plan 2002)

  • Fish population data gathered by the various Regional Fisheries Board and those of the Department of Communications, Marine and Natural Resources

  • Local angling groups fish catch data

  • Biodiversity trends in bird life using Bird Watch Ireland survey data 1

Note 1 Bird population data is considered to be a key indicator of overall biodiversity in that bird numbers, distribution and diversity are critically dependent on both plant and invertebrate diversity being adequately maintained. These are in turn closely linked to sustainable land use.



Water Quality

Data sources could include:



  • EPA’s national water quality surveys

  • Monitoring components of mandatory river basin management plans.

Air Quality

Data sources could include:



  • EPA air quality monitoring data

  • Certain local authorities.

Climate Change

Data sources could include:



  • EPA’s CO2 management responsibilities (including under carbon trading)

  • Sustainable Energy Ireland data on renewable energy initiatives uptake.

Soil

Data Sources (and which need to be linked to water quality monitoring) could include:



  • Teagasc soil data

  • Fertiliser usage (annual fertiliser sales by type i.e. N, P, etc.)

  • Biocides (annual sales by insecticide, herbicide type and purpose/application).


13.2 Monitoring of Land Use and Integration of Environmental Quality Data

Under the Draft RDP there are numerous Measures that impact on land use, including in particular: REPS, the various afforestation Measures (broadleaf, woodland reinstatement, conifer plantations etc.), commonage, organic farming and animal breeding. It is in relation to Land Use that the greatest monitoring complexity exists. While indicators such as uptake of supports provide some measure of impacts to be effective in determining actual impacts they need to be correlated with regular geographical land use data.


To be fully usable and effective in managing the environmental impacts of the RDP, monitoring data on land use also needs to be integrated with the data gathered for biodiversity, water, air and soil. The most effective and efficient means of achieving this, and ensuring comprehensive, understandable, usable outputs, is to utilise a Geographical Information System (GIS). GIS allows detailed mapping using OS maps/satellite imagery and integration of multi-source, multi-form data. A case example would be where grant-supported forestry lands can be integrated with water quality data and the status of the required setback from watercourses established through the detailed and comprehensive aircraft/satellite imagery the system supports. Once established, GIS can provide significant data manipulation and display capabilities on a readily updatable basis. Note: The EPA recently funded a project on the development of a comprehensive ‘Data Management and Geographical Information System’ to support the implementation of the Water Framework Directive (WFD) and related ongoing research and monitoring in Ireland. The development stage that this is now at could be usefully investigated.


    1. Monitoring—Management and Responsibility

Establishing, integrating and managing a nationwide GIS-based monitoring system specifically for the RDP (possibly adapted from other ongoing national GIS work) is an important task. It is only with a comprehensive system in place that the environmental effects of the RDP can be adequately evaluated and adjusted to respond through modifications where appropriate. The establishment of an integrated monitoring system is only likely to happen where the Department of Agriculture and Food (the promoter of the RDP) assumes overall responsibility for this action.
There are numerous private-sector service companies that specialise in the field of GIS-based-data handling and while the cost can be high it is small both in the context of the RDP expenditure of over €7 billion and in the context of the significant environmental benefits to be gained.
It is at this monitoring stage that the detailed level of the implementation mechanisms, and feedback from the various Measures, can best be evaluated and addressed by corrective measures where appropriate. This includes evaluation of the relevant implementation detail of REPS and/or issues of Cultural Heritage etc., as raised by the DoEHLG, and others.
Given the extensive geographical nature and diversity of Measures proposed under the four Axes, it is inevitable that some unforeseen negative environmental effects will result. Consequently for the monitoring to be useful the Measures and the agreements arising between the ‘donor’ Department/Agency and the ‘recipient’ should be sufficiently flexible and adaptable to be capable of speedily responding to ongoing feedback from the environmental monitoring programme.


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