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

Other Government Departments

Response

• 
  While the programme recognises the need to introduce voluntary measures designed to improve water quality in a number of areas: specifically, certain salmon rivers and pearl mussel habitats, and the catchments of certain western lakes, the DCMNR sees scope for more detailed plans for rivers and lakes to be included.
  

• 
  There is no reference in the Biodiversity sections of the programme to the need to protect aquatic habitats, particularly salmon habitats, or the benefits that the riparian corridor can provide as a habitat for flora and fauna.
  

• 
  The issue of water quality in general is addressed via the measures put in place to implement the Water Framework Directive as well as by national legislation such as the Phosphorus Regulations and the Nitrates Regulations. The voluntary schemes in this programme include elements designed to complement and augment these efforts, but are not themselves the primary instrument for improving water quality. The dedicated Supplementary Measure for Riparian Zones is being extended in REPS to help the preservation of the freshwater pearl mussel, and the Supplementary Measure for certain lake catchments (complemented by actions under Axis 3) is innovative. These and other aspects of the programme can be reconsidered at the mid-term evaluation stage, particularly in the light of developments in the implementation of the Water Framework Directive.
  
• 
  The importance of aquatic habitats is fully accepted. The individual elements of the programme, particularly those in the agri-environment measures, provide a high level of supplementary protection for habitats such as ponds, rivers and lakes where they exist on a participating farm. These actions are, however, complementary to national efforts (by statutory means and otherwise) to improve water quality, such as the implementation of the Water Framework Directive.
  

• 
  The commitment to the promotion of gender equality contained in the programme, particularly under the LEADER approach and training measure under Axis 3 is welcomed. It is, however, suggested that in the absence of dedicated gender equality personnel and resources, the promotion of equality throughout the programme measures may be uneven.
  
• 
  The clearly stated commitment in the programme to ensuring that the provisions of the Equal Status Acts 2000 and 2004 are met is viewed very positively.
  

• 
  As approximately 90 per cent of land is in male ownership, the submission envisages that the extent of such ownership will be continued through the proposed concentration of expenditure at on-farm level. One suggested option is to retain a dedicated expenditure under Axes 1 and 2 for training measures for women.
  
• 
  Failure to promote the concept of farming partnerships is seen as a lost opportunity to foster equality.
  
• 
  Monitoring and evaluation data should be gender disaggregated across the programme to facilitate measurement of on-going programme impact on gender equality.
  

Equality of opportunity is a core requirement of the programme, as emphasised in chapter 15. Assurance of continued equality will be maintained through the appropriate composition of the monitoring committee and disaggregation of performance evaluation data into gender components where possible.

• 
  The increased funding allocations and payment rates in the various measures were welcomed.
  
• 
  There should be a further enhancement of schemes to encourage the production of renewable energy crops.
  
• 
  An animal welfare scheme for dairy herds, which would improve competitiveness by improving the productivity of the herd, should be introduced in the Programme. Similar suggestions were made in relation to sheep and deer.
  

Response