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The environmental bodies broadly supported the environmental elements of the programme but raised a number of additional issues that they felt could be dealt with in the programme. The specific concerns raised by environmental bodies in respect of forestry are dealt with in the Strategic Environmental Assessment.
The other issues raised by the environmental bodies are set out below:
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While broadly supporting the need for strong and sustainable rural development, more emphasis needs to be placed on protecting, maintaining and enhancing the conservation of key rural sites for sensitive flora and fauna.
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Little consideration has been given in the programme to the identification and protection of high nature value (HNV) farmland, which is recognised within the EU as a key habitat.
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A biodiversity monitoring programme, including a farmland bird population indicator, should be established as part of the programme.
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Resources in the REPs should be allocated to proper ecological supports including ecological training for those involved in REPs.
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The REPs 4 is welcome. It is the simplicity of the scheme, which appeals to farmers, and this ensures a large uptake by farmers, resulting in positive impacts on biodiversity in the Irish countryside.
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Water quality issues, which are being addressed in the development plans for River Basin Districts, should also be reflected in the programme.
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A scheme that supports a return to domestic garden fruit and vegetable production, should be included in the programme.
Response -
The primary mechanism for conservation of key sites for sensitive flora and fauna is the system of designation administered by the National Parks and Wildlife Service of the Department of the Environment, Heritage and Local Government. Participants in any of the measures in the programme will – as before – be required to follow the appropriate NPWS prescriptions for such sites where these are available.
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Farmers participating in REPS must meet high standards of environmental management on their lands, regardless of whether they are in a HNV area. The identification of HNV farmland is not itself a matter for the programme. However, if such lands are designated by a competent authority and protection measures are prescribed, then those measures would have to be complied with by participants in the measures in the programme.
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BirdWatch Ireland already conducts a monitoring programme on farmland birds and this indicator is listed in the programme. National biodiversity monitoring is not a matter for the RDP.
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REPS has always included provisions for training to help the participant understand and meet his or her agri-environmental commitments under the scheme. REPS 4 training will be devised to match the requirements of the final scheme.
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The voluntary schemes in the programme include elements designed to augment and complement national efforts on water quality such as implementation of the WFD and the designation of habitats, but the programme is not the primary instrument for addressing water quality issues.
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REPS 4 proposes to continue support for traditional orchards.
Forestry Groups
The general issues raised by the forestry groups include the following:
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The level of funding proposed for forestry is inadequate and will not cover planting targets.
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The planting target is 50 per cent of the planting target set by the Government’s national forestry strategy (20,000 hectares). The planting targets are therefore not in line with the current Government forestry policy.
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The consequences for the processing sector of the reduced planting target have not been taken into account. The annual figure of 20,000 hectares was identified in the national strategy as being the minimum to create an economical critical mass for the processing sector.
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The funding for forestry is no longer co-financed by the EU, unlike previous the programming periods. This will leave the annual funding for forestry open to the political decisions made as part of the national estimates process.
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While the programme does recognise the role played by forestry in climate change through carbon sequestration, a mechanism to compensate farmers for their carbon sequestration is required.
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The level of funding provided for the forestry development and competitiveness measures is inadequate.
Response
The level of funding for forestry under the National Development Plan 2007–2013 includes a number of proposed new measures to make investment in forestry more attractive than ever. Ultimately, the schemes are demand-led but the intention is to stimulate that demand. The question of the ownership of sequestered carbon remains an issue for future debate.
Public Bodies (incl. Regional Assemblies/Authorities and Western Development Commission)
The need for complementarity between this programme and the new National Development Plan 2007–2013 was a common theme. Other general issues included:
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The need to ensure complementarity with the National Spatial Strategy and EU structural funds, particularly the avoidance of overlap with measures contained in the Operational Programmes of the Regional Assemblies
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Further broadening of measures particularly aimed at rural tourism, micro- enterprise, and conservation and upgrading of rural heritage
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Development of rural infrastructure concerning road, rail and air transport facilities in rural areas
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Use of appropriate performance indicators and establishment of a representative monitoring committee and network.
Response
The programme is structured to complement and add value to the wider range of measures focused on rural areas that are contained in the new National Development Plan 2007–2013, particularly under the strategic priority heading ‘The National Development Plan and Rural Communities’.
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