TABLE OF CONTENTS 2
Contents 2
Page 2
Title of Rural Development Programme and coverage of the RDP 2
5 2
Analysis of situation 2
3.1.4 - Rural Economy and Quality of Life 2
3.1.5 - Local Action Groups (LEADER) 2
3.2 - Strategy chosen to meet strengths and weaknesses 2
3.3 - Ex-Ante Evaluation 2
1. Title 5
2. Geographical area covered by the plan 5
Table 3.1: Rural area typology and profile 8
Food – production, exports and structure 13
3.2 Strategy chosen to meet strengths and weaknesses 34
Strengths and weaknesses 34
Strengths 34
Axis 1 (Competitiveness) 34
Axis 2 (Environment) 34
Axes 3 and 4 (Quality of life/diversification) 35
Weaknesses 36
Axis 1 (Competitiveness) 36
Axis 2 (Environment) 36
Axes 3 and 4 (Quality of life/diversification) 36
Opportunities and threats 37
Opportunities 37
Axis 1 (Competitiveness) 37
Axis 2 (Environment) 37
Axes 3 and 4 (Quality of life/diversification) 37
Threats 38
Axis 1 (Competitiveness) 38
Axis 2 (Environment) 38
Axes 3 and 4 (Quality of life/diversification) 38
Less favoured areas – compensatory allowances 41
Rural enterprise 42
Training, skills acquisition and animation 43
3.3 The ex-ante evaluation 44
4. Justification of the priorities chosen having regard to the Community strategic guidelines and the national strategy plan as well as the expected impact according to the ex-ante-evaluation 50
4. 1 Justification of the priorities chosen, having regard to the Community strategic guidelines and the national strategy plan 50
Apart from the allocation of the Health Check and European Economic Recovery Plan funds Ireland is addressing the challenges relating to dairy restructuring, renewable energies and water management with the introduction of a new scheme titled “Targeted Agricultural Moderniation Scheme [TAMS] under measure 121 of Axis 1 of the RDP. 52
Main Priority: Biodiversity 52
To continue in line with the original RDP for the period 2007-2013 which already prioritises actions associated with biodiversity, water management and climate change, through its Axis 2 measures the new AEOS offers support to continue and consolidate the success of previous investments in these areas. Though the existing Rural Environmental Protection Scheme (REPS 4) was closed from July 2009 the benefits of this scheme and of the previous REPS scheme will still accrue as the contractual scheme arrangements with the existing beneficiaries, of which there are approximately 62,000, will remain in force over the coming years. 53
Priority: Water management 53
Broadband Initiative 55
Broadband Initiative under the EERP 56
4.2 Expected impacts deriving from the ex-ante evaluation with regards to the priorities chosen 56
Specific recommendations 62
Background 64
Screening of Rural Development Programme 64
Scoping of the SEA 64
Evaluation (SEA) report 64
Consultation on evaluation (SEA) report 68
Environmental Protection Agency (EPA) 68
The report examined one/two alternative scenarios. Other possible alternatives might usefully be considered. 68
The proposed monitoring programme requires detailed consideration. The inclusion of existing monitoring programmes such as national surface and groundwater programmes is recommended. There should be a clear distinction between the programme’s objectives and the environmental ones as per the SEA Directive. 68
The Water Framework Directive and associated plans and measures should be referred to in the programme. Groundwater, surface water and coastal and estuarine environments also merit mention. 68
The report refers to the requirements for environmental impact assessments for individual forestry developments. The cumulative impacts of adjoining forestry developments may not, however, be adequately addressed by those assessments. 68
In terms of the preservation of rural landscapes and traditional agricultural landscapes, there may be merit in a pilot assessment of such landscapes. 68
The evaluator’s views on some issues are open to question. In some cases, impacts might be positive or negative; flood risk is a realistic threat to low-lying agricultural land. 68
Response to strategic environmental assessment 69
On the forestry side, guidelines in relation to preservation of water quality have been drawn up, with specific requirements to be introduced for protection of the freshwater pearl mussel. Any further requirements identified as part of the implementation of the Water Framework Directive will of course be incorporated. 70
In relation to species selection, it is intended to maintain the target of 30 per cent broadleaf afforestation for the new programming period, with specific schemes promoting this and more favourable rates of premium applying. The native woodland resources will continue to be protected and expanded through a dedicated Native Woodland Scheme. 70
Use of fertilisers and herbicides in forestry establishment is extremely low by agricultural standards, often requiring no more than one or two applications over a full rotation of 40-100 years. A new Statutory Instrument has recently been introduced to control the use of aerial fertilisation in established forestry. 70
(B) Less favoured areas (LFAs) 72
5. Description of Axes and Measures proposed for each Axis 74
Measures proposed for each Axis 74
The position re the horizontal indicators is set out in the table below: 75
5.1 Axis 1: Improving the competitiveness of the agricultural sector 76
Summary of actions 76
Measurement 76
Coherence with first pillar 93
A. Investment in Dairy Enterprises 93
B. Investment in Sheep Enterprises 93
Measurement 101
Mountain type land 105
Actions and Amounts of Natura 2000 for AEOS 118
Controls 118
Integrated Measure 121
Options 125
Supplementary Measure 127
Minimum Tillage 127
2C Mixed Livestock Enterprises 128
5A Coppicing of Hedgerows 128
5B Laying of Hedgerows 128
5A Coppicing of Hedgerows 128
5B Laying of Hedgerows 128
Supplementary Measure Minimum Tillage 129
Agri-Environmental Payments Sub-Measure–Organic Farming 130
Must be engaged in the production of organic crops intended for human consumption and/or animal feed 130
Establishment of farm woodland 136
ACTION 9: Produce tillage crops respecting environmental principles 142
Supplementary Measure—Traditional Orchards 146
Organic Farming 152
Commonage Land outside the Natura 2000 Network 153
Natural Heritage Areas (NHAs) outside the Natura 2000 Network 154
And/or 159
And/or 159
And/or 159
One of 159
Cattle 160
Equines 160
Sheep 160
Financing 160
Agri-Environment commitments under the REPS Scheme undertaken under Council Regulation (EC) No. 1257/1999 in respect of the 2000-2006 Programming period involving payments to be made after 31 December 2006, as well as expenditure related to on-going commitments in respect of participants transforming to new commitments under REPS 4, shall be funded under the new Programme. The likely level of take up of transformation to REPS 4 is reflected in the estimated ongoing commitment of €890 million. 160
Quantified targets for EU common indicators 161
Action 1: Nutrient Management 162
Action 2: Grassland Management 162
Action 3: Protection of Watercourses 162
Action 4: Retain Wildlife Habitats 163
Action 5: Maintain Farm and Field Boundaries 163
Action 7: Establish biodiversity buffer strips around features of historical or archaeological interest 163
Action 8: Visual Appearance of Farm and Farmyard 164
Action 9: Tillage 164
Conservation of Animal Genetic Resources 164
Riparian Zones 164
LINNET 165
Low Input Tillage Crops 165
Minimum Tillage 165
Traditional Farm Enterprises 165
Traditional Grazers 165
Mixed Grazing 165
Clover sward 165
Conservation of Wild Bird Habitat 165
Heritage Buildings 165
Organic Farming 165
Baseline 166
Baseline 167
Integrated Measure 169
Scoring System 172
Core Actions: New Grass Habitats 174
Cross checks to IACS databases 174
Core Actions: 176
Labour and machine hire 177
Follow an annual wall maintenance programme for the farm. Livestock must be present on the farm and commonage lands are not eligible. 177
National 178
National 179
Green Cover Establishment from a sown crop. 179
National 179
Actions: Establish non-commercial orchard with traditional top fruit varieties selected from a published list on vigorous rootstocks by means of planting, fencing and annual maintenance. 192
Summary of actions 194
Measurement 194
Rationale for intervention 195
Rationale for intervention 198
Rationale for intervention 201
Result 219
Training and Information Measure for Economic Actors Operating in the Fields Covered by Axis 3 220
Legal basis 220
Article 52 (c) of Reg. (EC) N 1698/2005 220
Point 5.3.3.3 of Annex II of regulation (EC) N 1974/2006 220
Measure Code: 331 220
Category 222
Category 225
Implementing Local Development Strategies 226
Legal basis 226
As referred to in Article 62(1)(a) with a view to achieving the objectives of one or more of the three other axes defined in sections 1, 2 and 3 (Article 63(a) of Reg. (EC) N 1698/2005) 226
Measure Code: 41 (inclusive of Measures 411 and 413) 226
Legal basis 233
Article 59 (Article 63(c) of Reg. (EC) N 1698/2005) 233
Measure Code: 431 233
Potential Effects 234
SUBSTITUTION OF FOSSIL FUELS, CARBON SEQUESTRATION, REDUCTION OF NITROUS OXIDE (N2O) 234
New Challenge: Water Quality 239
6,7 and 8 Financing Plan 241
Total 241
Total 242
Total 242
Phase 4 February—March 2011 258
Political Parties 262
Other Government Departments 263
Response 263
Environmental Bodies 265
Forestry Groups 266
Public Bodies (incl. Regional Assemblies/Authorities and Western Development Commission) 267
Social Inclusion Groups 267
Community Environmental Groups 268
Rural Economy Groups 268
Enterprise support activity must not duplicate initiatives by other public agencies, and appropriate sectoral agreements must be in place at local level. Emphasis will be placed on developing on-farm diversification initiatives and enhancing the economic contribution of local natural resources. 268
Other Interested Parties 268
Promotion of equality 275
Non-discrimination 275
Size Structure and Productivity of the Food, Drink and Tobacco (FDT) and Total Manufacturing Sectors, 2003 281
Appendix 3 313
(REPS and Organic Farming) 313
Basis of REPS Costing for Grassland Farmers 313
Follow an appropriate waste management, liming and fertiliser plan prepared for the total area of the farm. 313
a) Fertiliser limits apply to crops. 313
a) Follow an appropriate waste management, liming and fertiliser plan prepared for the total area of the farm. 321
b) Fertiliser limits for crops set at 70per cent of crop requirements; or 6per cent of arable area to be farmed under conditions of LINNET supplementary measure but without additional payment, subject to crop requirements not being exceeded on the rest of the holding. 321
Basis of Costing for NHAs not designated under Natura 2000 – excluding commonage 339
Appendix 3A 340
Establishment and maintenance of habitats 341
Establishment and maintenance of habitats continued 341
New grassland habitat 341
New grassland habitats 341
3. Tree Planting & Management 342
a) Total cost per tree: 342
National 344
Traditional Orchards: 344
9. 345
Total Cost 345
NEW CHALLENGE: WATER QUALITY 346
National 346
Riparian boundary strips contribute to water quality. Farmer incurs capital costs and maintenance costs and income foregone in terms of agricultural production. 346
NEW CHALLENGE: CLIMATE CHANGE 347
National 347
The creation of arable margins contributes to carbon sequestration by grassing of arable land. 347
Green Cover Establishment from a sown crop. 347
National 348
Litter Pollution Act, 1997 354
Statutory Provision 355
Implementing Body 355
Penalties 355
Part III.12. D 365
Supplementary Information Sheet on Aid to Compensate for Handicaps in Certain Areas 365
1. questions relevant for all notifications of aid to compensate for handicaps in certain areas 365
2 Other Information 369
1.1.2 If no, please note that Part IV.C.3 of the Agricultural Guidelines does not allow for aid to compensate for costs other than those related to the disadvantages related to the implementation of Directives 79/409/EEC, 92/43/EEC and 2000/60/EC. 370
2.1 Are costs incurred and income foregone resulting from disadvantages in the areas concerned related to the implementation of Directives 79/409/EEC, 92/43/EEC and 2000/60/EC? 370
Supplementary Information Sheet on Agri-environmental and animal welfare aid 374
Aid for Agri-environmental commitments 376
(point IV.C.2 of the guidelines) 376
1. objective of the measure 376
2. Eligibility criteria 377
2.1 Will the aid be exclusively granted to farmers and/or other land managers (Article 39(2) of Regulation (EC) No 1698/2005) who give agri-environmental commitments for a period between five and seven years? 377
2.2 Will a shorter or a longer period be necessary for all or particular types of commitments? 377
3. Aid amount 378
3.1 Please specify the maximum amount of aid to be granted based on the area of the holding to which agri-environmental commitments apply: 378
3.2 Is the support measure granted annually? 378
3.3 Is the amount of annual support calculated on the basis of:
- income foregone,
- additional costs resulting from the commitment given, and
- the need to provide compensation for transaction costs 379
3.5 Are the payments made per unit of production? 379
Management & Control Structure 381
Certifying Body 381
Finance Division DAFF 381
Glossary of Abbreviations 382
I EX-ANTE EVALUATION OF THE RURAL DEVELOPMENT PLAN 403
BACKGROUND AND INTRODUCTION 403
1.1 Purpose and Scope of Ex-Ante Evaluation 403
1.2 Council Regulation 1698/2005 and changes from previous Regulations 403
1.3 The regulatory framework for ex ante-evaluation 404
1.4 Structure of Ex-Ante Evaluation Report 404
1.5 Sources of Information 405
2.1 Structure of the Plan and compliance with EC Regulation EC 406
2.1.1 Evaluators’ comments on structure and content of plan 407
2.1.2 Summary of Plan 408
2.1.3 Problems RDP is expected to address 409
2.1.4 SWOT Analysis 410
Problems not addressed by the implementation of the Programme 413
OBJECTIVES OF PLAN 413
Overall policy objectives and expected impacts 413
Policy objectives and expected impacts – Axis 1 414
Policy objectives and expected impacts – Axis 2 414
Coherence of Programme objectives with NDP 415
4. Proposed Measures 416
4.1 Summary of Measures and their relationship to overall objectives 416
4.2 Lessons Learned and taken into account in designing the draft programme 417
4.3 Measures Axis 1 – Competitiveness 418
4.3.1 Introduction 418
4.3.2 Early Retirement Scheme and Installation Aid Measures 418
Current Situation 418
Actions Proposed 423
4.3.3 Farm Improvement Measures 426
4.3.4 Afforestation Axis 1 Measures 430
Problems to be Addressed 431
4.4 Measures Axis 2 435
4.4.1 Introduction 435
Sub-Total Axis 2 436
4.4.2 Less Favoured Areas – Compensatory Amounts 436
4.4.3 Agri-Environment (REPS) and Natura 2000 442
4.4.5 Animal Welfare, Recording and Breeding Scheme for Suckler Herds 456
4.5 Axes 3 and 4: Rural Quality of Life and LEADER Implementation 457
4.5.1Introduction 457
4.5.2 Axis 3 Measures 458
5. Added value of Community involvement 465
6. Monitoring and evaluation systems 465
7. Strategic Environmental Assessment 466
7.1 Definition and Scope of Strategic Environmental Assessment 466
7.2 Outline description of the Measures proposed 466
7.3 Baseline Environmental Information 466
7.4 Anticipated Environmental Effects arising from Axis 1 Measures 467
7.5 Anticipated Environmental Effects arising from Axis 2 Measures 467
7.6. Anticipated Environmental Effects arising from Axes 3 and 4 Measures 469
7.7 Alternatives to the Programme 469
7.8 Monitoring Environmental Effects of Proposed Programme 469
1. INTRODUCTION 479
2. EXECUTIVE SUMMARY 481
3. Summary of the draft rural development programme 486
4. ENVIRONMENTAL PROTECTION OBJECTIVES 489
5. BASELINE ENVIRONMENTAL INFORMATION 490
6. DESCRIPTION OF AXES AND MEASURES PROPOSED FOR EACH AXIS 496
7. IDENTIFYING ENVIRONMENTAL EFFECTS 498
8. AXIS 1: IMPROVING THE COMPETITIVENESS OF THE AGRICULTURAL AND FORESTRY SECTOR 499
Summary of Axis 1 Measures 499
Comments on the Matrix—Agricultural and Forestry Training 500
9. AXIS 2: IMPROVING THE ENVIRONMENT AND THE COUNTRYSIDE 512
9.3.4 Mitigation Measures for Significant Adverse Effects 520
To provide a sustainable basis for development of the rural economy 523
11. Promotion of Equality 535
12. ALTERNATIVES 535
13. MONITORING ENVIRONMENTAL EFFECTS OF PROPOSED PROGRAMME 536
14. OTHER CONSIDERATIONS 538
15. RECOMMENDATIONS 539
The ex-ante evaluation of the national Rural Development Plan (RDP) for the programming period 2007—2013 is based on and elaborates on the Ireland Rural Development National Strategy Plan (2007—2013) and Council Regulation 1698/2005 (the ‘Regulation’) on support for rural development by the European Agricultural Fund for Rural Development (EAFRD). The draft plan has now been subjected to an ex-ante evaluation and strategic environmental assessment covering:
The draft plan conforms to the requirements of EC Council Regulation 1698/2005 and meets the priorities defined under ‘The Community Strategic Guidelines for Rural Development Policy’. It also reflects the priorities defined under the National Strategy Plan for Rural Development and government priorities for the development of agriculture and food as well as protection of the rural environment. It is consistent with other relevant strategy documents such as the DAF’s document, AgriVision 2015 and the White Paper on Rural Development. The draft plan examines the current issues and problems facing agriculture and the rural economy (Chapter 3) as part of a lead in to a SWOT analysis.
Based on the SWOT analysis a range of measures, are proposed under each Axis that address identified problems. The objectives, rationale and actions under each measure are elaborated as is the proposed financial allocation. The overall structure and content of the plan follows closely the provisions of the Regulation and reflects the requirement of the Regulation that development policy should accompany and complement the market and income support policies of the common agricultural policy and that rural development policy should also take into account the general objectives for economic and social cohesion policy set out in the Treaty and contribute to their achievement while integrating other major policy priorities as spelled out in the conclusion of the Lisbon and Goteborg European Councils for competitiveness and sustainable development.
1.3 Problem Identification
The draft plan provides significant background analysis of the socio-economic environment underpinning the plan and this informs the subsequent problem identification. The problems which need to be addressed can be summed up in terms of the three axes in the RDP: there is a threat to the competitiveness of Irish agriculture from a number of sources, there needs to be incentives to preserve and enhance the rural environment and countryside, and supports are needed to create employment and generate economic and social activities and infrastructure in rural areas.
The competitive problems arise from, on the one hand the reduction in market aids and supports and the more open EU market for agriculture. On the other hand, demand for land for non-agricultural purposes and alternative employment is raising the cost of the principal inputs for commercial agriculture. These problems are superimposed on fragmented farm structures and a generally ageing agricultural work force.
The decline in price supports for agriculture and the introduction of decoupled payments will tend to reduce agricultural activity and the consequent agricultural load on the environment. Unless action is taken, this may tend to the abandonment of land, which generates other environmental problems. Meanwhile, there will be a core of active farms, which generate emissions, and the Nitrates Directive will raise the standards, which farms have to comply with.
In relation to rural society in general, many areas suffer from a poor demographic structure and from inadequate infrastructure, social facilities and employment opportunities. Many of these problems are not addressed by the ‘mainstream’ policies of national and local government entities.
1.4 Objectives
Axis 1
The first Axis of the RDP is aimed at improving the competitiveness of farm and forest enterprises through support for restructuring and innovation. This axis includes support for training, installation aid, early retirement, food quality and downstream food and forestry activities. Measures under this axis have the objective of promoting structural changes at farm level as well as investment in key sectors. This is supported by training measures that are seen as essential in meeting the challenges of an increasing competitive environment. Combined, the measures under Axis 1 respond to identified issues that impact on the competitiveness of the agriculture and food sectors and aim to progress restructuring and investment for the challenging era ahead.
The broad objectives of Axis 3 are to improve the quality of life in rural areas and encourage diversification of economic activity in rural areas including diversification into non-agricultural activities. The measures under Axis 3 encompass a range of initiatives that are designed to promote economic activity in rural areas and also stimulate broader community initiatives aimed at improving the overall quality of life for rural dwellers. The measures will be implemented using the LEADER approach that emphasises a ‘bottom up’ approach and area-based local development strategies.
The draft RDP proposes expenditure of €7.055 billion over a 7-year period of which €2.339 billion will be from the EAFRD and €4.716 billion from the National Exchequer. In line with the requirements of Council Regulation 1698/2005 the plan is structured around 3 core objectives of improving competitiveness, improving the environment and improving the quality of life in rural areas. This is reflected in the plan with measures allocated among 3 axes corresponding to the above objectives. The axes and financial allocations are as follows:
Competitiveness envisages total expenditure of €665 million of which €234 million will be from the EAFRD. Under this Axis issues relating to the competitiveness of the agriculture and food industry are addressed particularly structural problems. The proposed measures are in the main a continuation of measures included in the RDP but with some changes in approach and design. Most of the funding is allocated to the Early Retirement Scheme (€418) and a complementary scheme of Young Farmer Installation Aid (€63). In total the 2 measures account for 72per cent of total planned expenditure under the axis. Other measures planned under this axis are farm improvement – designed to promote investment in modern facilities in key sectors and support to the forestry sector.
Improving the environment envisages expenditure of €5,965 million of which €1,871 will be from the EAFRD. Measures under this Axis focus on ways of improving the environment but with farmers and farms at the core. The measures proposed are measures included in the current RDP but with modifications and improvements based on the up to-date problem analysis. The main measure proposed is the continuation of the REPS/Natura 2000 measure for which €2,982 has been allocated representing 50 per cent of expenditure under the axis. The next most important measure in terms of expenditure levels is the Compensatory Allowance measure with planned expenditure of €1,799 million or 30 per cent of expenditure under the axis. The remaining measures cover forestry initiatives with a predominantly environmental focus and for which €934 million is allocated and animal welfare with an allocation of €250 million.
Improving the quality of life in rural measures includes a range of measures that are aimed at having a more sustainable rural economy with an improved quality of life. The measures build on similar type measures implemented under the LEADER programme in previous programmes and have a total allocation of €425 million of which €234 million is from the EAFRD. While the measures here are primarily aimed at improving the quality of life in rural areas they also support and complement the objectives of Axis 1 and Axis 2.
The issue of competitiveness is well analysed in the plan but the link between the proposed measures and the identified problems could be strengthened. 72 per cent of expenditure is allocated to the problem of age structure and farm size but it is unclear from the analysis if this is the main competitive issue facing agriculture and food. While the IAS is likely to achieve results in terms of attracting young farmers, the continuation of the ERS is problematic and the low uptake in the current scheme is of concern. While the measure is well intended it may be that uptake is opportunistic depending on the individual circumstances of farmers who may have been considering exiting.
The farm improvement measure is generally good and should achieve results, though there may be an issue with deadweight in some areas. Consideration could be given to increasing the allocation to organic farming. In relation to forestry the measures proposed are directed at encouraging actions which are important for ensuring that the potential of forestry are in line with the overall objectives of the Draft RDP and complementary to the forestry measures in Axis 2. However, the issue of whether the low rates of plantation now being recorded are capable of supporting a competitive industry needs further exploration.
Axis 2
With 80 per cent of expenditure under Axis 2 the RDP is primarily a plan to address environmental priorities, especially as some of the measures under Axis 1 and Axis 3 are also environmental in nature. While the measures under Axis 2 are directed towards the environment they also contribute significantly to farm incomes and thus to the maintenance of a farming community. The CAs are a valuable contribution to farm incomes in the Less Favoured Areas (LFAs) and as such help attain important Community and national objectives for rural development including population stabilisation and maintenance of farm land in good environmental condition. However, the reaction of farmers to decoupling needs to be monitored carefully and on farms where activity declines to minimal levels, the scheme may prove to be redundant. As it is the scheme is complementary to the Single Farm Payment (SFP) and consistent with most other policy initiatives such as REPS. It is not consistent with the ERS or with the Forestry Programme, although the adverse impact in both cases is likely to be small.
The proposed REPS measure builds on the success and experience of previous REPS measures but is not just a simple follow on from the previous programme. It will be implemented against a background of a totally changed CAP Pillar 1 and a new farming regime. Lessons learned from the previous measures have been taken into account in the design of the current measure and the current design is considered to be attractive both in terms of its flexibility and monetary reward.
The national forest programme is consistent with objectives of the EU in relation to forestry and supports national rural development policy in providing alternative income and employment in rural areas. Forestry also provides important carbon sequestration and alternative energy potential and, when carefully managed, can generate important amenity and biodiversity values. The forestry measures will promote the size of the national forest, which is low by European standards, and will address some deficiencies of Irish forests and enhance some opportunities through targeted interventions. The forestry schemes are complex and expensive but there is no alternative to heavy subsidisation, backed up by careful supervision as envisaged in the draft RDP. The major difficulty with the programme at the moment is the low rate of take-up, which may be aided by the forthcoming increase in the premiums, and some deficiency in the management of the existing forest estate. Any additional resources for forestry that might become available should be focused on measures designed to enhance the commercial value of the forests, such as reconstitution and the measures in Axis 1.
The combined measures under Axis 3 represent an attempt to deliver a significant community based rural development programme using the LEADER approach. Unlike the other two axes, which are mainly comprised of existing and well proven measures, Axis 3 is quite innovative and challenging.
The general definition of Axis 3 including the problem identification would benefit from further analysis and a clearer outlining of the problem being addressed and overall objectives. Also the issues and measures covered under Axes 3 and 4 cover only a part of overall public support for development in rural areas and indeed part of the needs. In the context of a new National Development Plan 2007—2013 it would be very desirable to see a document, that incorporated all the proposals affecting rural development together, and evaluated together.
The specific proposals under Axes 3 and 4 are generally good but we feel the links between analysis, problem identification and proposed measures to respond to problems could be made clearer.
While the proposed implementation arrangements are generally satisfactory and do not require changes there are significant concerns with the identification and selection of indicators. It would seem that this area of the plan is largely incomplete and that a systematic approach to defining useful indicators and agreeing how such indicators can be compiled is required. Particularly, in relation to assessing impact the use of special surveys may need to be considered.