Inclusive of amendments of 30 September 2008, of 15 May 2009
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- 15. RECOMMENDATIONS
14. OTHER CONSIDERATIONSThere are a number of other considerations that derive from the environmental assessment of the Draft RDP. These are elaborated on below and, where appropriate, incorporated in the Recommendations section. 14.1 Energy from Agriculture, Forestry and Wind The sourcing of energy from agriculture and forestry is now of strategic importance for Ireland, in addition to having important environmental contributions to make in respect of the ‘Kyoto Agreement.’ The recently published Energy Green Paper entitled ‘Towards a Sustainable Energy Future for Ireland’ – October 2006 (Department of Communications, Marine and Natural Resources) commits to the delivery of ambitious targets for renewable energy. The Government’s 15 per cent target of 1,650MW by 2010 provides the foundation for the 30 per cent target by 2020. Bio-energy is regarded as having significant potential and the newly established Ministerial Task Force on Bio-Energy will finalise a National Bio-Energy Action Plan, assessing optimum targets for the market penetration of biomass heating, electricity and bio-fuel transport to 2020. This plan will be developed in the context of the European Commission’s Biomass Action Plan. Arising from this Plan, it is likely that a significant shift to the growing of bio-fuel tillage crops will occur. Unlike forestry where bio-fuels largely arise indirectly (from forest thinnings and downstream processing of wood) bio-fuel crops are purpose grown and are set to provide a substitute activity on tillage and grazing lands. Examples of bio-fuels include elephant grass (miscanthus) and willow. Until these bio-energy plans are more fully developed the Draft RDP cannot take appropriate account of the resultant land-use changes and the environmental consequences (likely to be primarily positive) that will inevitably flow from them. It can be expected that since the Bio-Energy Plan is a ‘Plan or Programme’ by government with self-evident significant environmental effects, it too will be subject to Strategic Environmental Assessment in due course. Also of importance, but of less significance, is the implication of the proposed magnitude of the wind-generated component of renewable energy. An expansion of the agricultural land area devoted to wind farms will likely significantly increase as suitable offshore sites are known to be limited. 14.2 Access to Lands A significant portion (approximately €6 billion under Axis 2 of the total budget of just over €7 billion) of the financial supports relate to improving the diversity of the environment, protecting biodiversity, promoting more sustainable agriculture/forestry and ultimately improving ‘Quality of Life’. Much of this expenditure is aimed at the enhancement of the countryside and the nature it supports with the stated objective, among others, of promoting its enjoyment by both visitors and locals alike. There is no reference of note in the Draft RDP to the issue of public access to these environmental assets that they, the public, have helped finance through taxation. 15. RECOMMENDATIONSThe Department of Agriculture and Food should establish and oversee a comprehensive, integrated, environmental monitoring programme. That programme should ideally be based on a sophisticated Geographical Information System (GIS). The Measures under the four Axes and the support agreement conditions arising between the ‘donor’ Department/Agency and the ‘recipient’ should be sufficiently flexible and adaptable to be capable of speedily responding to any negative environmental feedback from the monitoring programme. Due to the differing timelines of the RDP and the National Bio-Energy Action Plan the bio-fuels issue should be addressed at the Interim Review stage of the proposed RDP. The role of wind farms both as a land use and as a source of employment and local income should be evaluated for inclusion in the Draft RDP. The issue of access by the public to lands that have directly benefited from the financial supports under the relevant. Measures should be addressed in terms of ultimately improving ‘Quality of Life.’ Much of this expenditure is aimed at the enhancement of the countryside and the nature it supports with the stated objective, among others, of promoting its enjoyment by both visitors and locals alike. There is no reference of note in the Draft RDP to the issue of public access to these environmental assets that they, the public, have helped finance through taxation. 1 Irish Rural Structure - Report prepared for the NSS 2002 by NUI Maynooth and Brady Shipman Martin 2 Central Statistics Office 2006, Census of population 3 Kearney, B. 2005, Update on Rural Areas since publication of the White Paper on Rural Development 1999 4 CSO County Incomes and Regional GDP 2006 5 Morgenroth, E. (2009) “Who is Paying for Regional Balance in Ireland”, ESRI Research Bulletin 2009/1/3 7 Some farms reported 2 or more types of gainful non-agricultural activity 8 The Agri-Food sector is taken to include primary production (agriculture, fishing and forestry) together with the food and beverage, and wood processing sectors (excludes tobacco) 9 http://www.agriculture.gov.ie/media/migration/publications/2008/NetContributionofAgri-food2Funds_NewEstimate.pdf 10 Defined as Member countries in the European Union prior to the accession of ten new member countries on 1 May 2004. 11 Bord Bia 12 Ministerial Conference on the Protection of Forests in Europe 13EPA report “IRELAND’S GREENHOUSE GAS EMISSION PROJECTIONS 2008-2020” March 2009 http://www.epa.ie/downloads/pubs/air/airemissions/GHG_Emission_Proj_08_12_30032009.pdf 14 Land Invested in Nature, Natural Eco-Tillage 16 CSO Census of Population, 2002 as quoted in Review of enterprise support in rural areas, Fitzpatrick Associates, 2004 17 Higher Education Authority, College Entry in Focus, fourth survey, 1998 as quoted in Review of enterprise support in rural areas, Fitzpatrick Associates, 2004 18 Revenue Commissioners, 2003 as quoted in Review of enterprise support in rural areas, Fitzpatrick Associates, 2004 20 WDC submission to the consultation on Ireland’s National Development Plan 2007–2013, April 2006 21 The WDCs Look West initiative promotes the Western Region as a location for business and living 22 Enterprise Strategy Group (2004), Ahead of the Curve: Ireland’s Place in the Global Economy; National Economic and Social Council (2005), NESC Strategy 2006: People, Productivity and Purpose; NUI Maynooth, UCD and Teagasc (2005), Rural Ireland 2025: Foresight Perspectives 23 “Land Invested in Nature, Natural Eco-Tillage” 24Published by Department of An Taoiseach, December 2008 25 CSO, Information Society Statistics First Results 2008 26 See http://www.dcenr.gov.ie/Communications/Communications+Development/National+Broadband+Scheme.htm State Aid decision 475/2007 http://ec.europa.eu/community_law/state_aids/comp-2007/n475-07.pdf 27 As this measure is delivered by LEADER it is evaluated under Axis 4 of the programme; as such indicators under Measure 123 are additional indicators only. 28 OJ L 206, 22.7.1992, p 7. Directive as last amended by Regulation (EC) No 1882/2003 of the European Parliament and of the Council (OJ L 284, 31.10.2003, pg 1) 29 Council Directive 91/676/EEC of 12 December 1991 concerning the protection of waters against pollution caused by nitrates from agricultural sources 31 A suitable University degree in Agricultural Science is required, and planners must submit trial plans to an acceptable standard before they are approved. 32 Those farms that have not obtained a derogation from the general limit of 170 kg NORG laid down in Council Directive 91/676/EEC of 12 December 1991 concerning the protection of waters against pollution caused by nitrates from agricultural sources 33 This payment, and other payments which require action on areas of the farm up to a maximum, are not based on the maximum area itself but are averaged on a per hectare basis on the first 20 hectares of the holding 34 LINNET is an acronym for Land Invested in Nature, Natural Eco-Tillage 35 Detailed baseline inspection requirements are outlined in the Single Farm Payment Scheme Guide to Cross-compliance Requirements published by the Department of Agriculture and Food in August 2006 36 The increased rate of payment is intended to target the many Irish rivers and their tributaries which are habitats for important aquatic species, including salmonid and pearl muscle species which are coming under considerable pressure. The increased payment reflects the urgency in incentivising farmers to take up this measure. The high post and wire fencing specification that also includes access gates for machinery and stiles for fishing people is a major cost of complying with the prescribed management practices in this measure. 37 There has been increasing pressure on populations of farmland bird species due to reduced food supply over the winter months. The number of farmland birds continues to fall and the increased payment reflects the urgency in incentivising farmers to take up this measure. The maintenance of the cereal brassicas crop mixes for the five year duration of the REPS contract is a significant cost of complying with the prescribed management practices in this measure. 38 Inclusive of area under M216 39 National Farm Survey 40 European Communities (Good Agricultural Practice for Protection of Waters) Regulations 2006 (S.I. No. 378 of 2006) 41 This area is captured under Measure 214. 42 Reductions in gross nutrient balance are targeted and will result from the interception of nutrients by means of the buffer zones created and the prevention of bovine access to watercourses under this measure. It is not possible to put a precise figure on the reduction in gross nutrient balance as monitoring to the exclusion of all other factors is not possible or available at farm level. 43 All Axis 3 measures delivered by LEADER are evaluated under Axis 4 of the programme; as such indicators under Axis 3 are additional indicators only. 44 All Axis 3 measures delivered by LEADER are evaluated under Axis 4 of the programme; as such indicators under Axis 3 are additional indicators only. 45 All Axis 3 measures delivered by LEADER are evaluated under Axis 4 of the programme; as such indicators under Axis 3 are additional indicators only. 46 All Axis 3 measures delivered by LEADER are evaluated under Axis 4 of the programme; as such indicators under Axis 3 are additional indicators only. 47 See http://www.dcenr.gov.ie/Communications/Communications+Development/National+Broadband+Scheme.htm State Aid decision 475/2007 http://ec.europa.eu/community_law/state_aids/comp-2007/n475-07.pdf 48 All Axis 3 measures delivered by LEADER are evaluated under Axis 4 of the programme; as such indicators under Axis 3 are additional indicators only. 49 All Axis 3 measures delivered by LEADER are evaluated under Axis 4 of the programme; as such indicators under Axis 3 are additional indicators only. 50 All Axis 3 measures delivered by LEADER are evaluated under Axis 4 of the programme; as such indicators under Axis 3 are additional indicators only. 51 All Axis 3 measures delivered by LEADER are evaluated under Axis 4 of the programme; as such indicators under Axis 3 are additional indicators only. 52 This methodology will only be used to deliver measure 123: support for enterprises involved in the processing and/or marketing of Annex 1 products. 53 CSO Regional Population Projections 2011-2026 54 Source: Review of enterprise support in rural areas, Fitzpatrick Associates, 2004 55 Cross-compliance outlined in this column is a summarised version. For a comprehensive description of cross-compliance, refer to the Single Farm Payment guide to Cross-compliance and the single payment scheme: DAF publications. 56 Local Government (Water Pollution) Act, 1977 and Amendment Act, 1990; Waste Management Act, 1996; Fisheries (Consolidation) Act, 1959; Local Government (Planning and Development) Acts, 1963 to 1998; Air Pollution Act, 1987; Environmental Protection Agency Act, 1992 and the European Communities (Environmental Impact Assessment) Regulations, 1989. 57 The overall costing for the first 20ha shall include an additional payment of €30/ha (including 20% incentive) based on a farmer selecting a range of optional measures as set out in Appendix 1. 58 By selecting 2 of the options listed (from the categories as set out in Appendix 1) it will be possible to reach the proposed €177.50/ha on the first 20 ha of a holding. There is no incentive element in the costing of the options. 59 Payment for non-target land will be on a per-hectare basis and will be payable on up to a maximum of 55 hectares. Participants farming more than 55 hectares must include all the land in their agri-environmental plan and farm it in accordance with the REP Scheme conditions. 60 GAEC outlined in this column is a summarised version. For a comprehensive description of GAEC, reference should be made to Annex 2 of the Plan. 61 Participants can receive payment on one Supplementary Measure only. 62 Payment is based on a livestock unit basis rather than on a per hectare basis. 63 The increased rate of payment is intended to target the many Irish rivers and their tributaries which are habitats for important aquatic species, including salmonid and pearl muscle species which are coming under considerable pressure. The increased payment reflects the urgency in incentivising farmers to take up this measure. The high post and wire fencing specification that also includes access gates for machinery and stiles for fishing people is a major cost of complying with the prescribed management practices in this measure. 64 There has been increasing pressure on populations of farmland bird species due to reduced food supply over the winter months. The number of farmland birds continues to fall and the increased payment reflects the urgency in incentivising farmers to take up this measure. The maintenance of the cereal brassicas crop mixes for the five year duration of the REPS contract is a significant cost of complying with the prescribed management practices in this measure. 66 €106 up to 55ha; €15 for each additional hectare 67 € per hectare unless otherwise specified 68 Non productive investment under measure 216; total cost is annual payment x5 69 Proposed Payment is €314 70 Proposed Payment is €314 71 Proposed payment is €314 72Council Regulation (EC) No 1698/2005 of 20 September 2005 on support for rural development by the European Agricultural Fund for Rural Development (EAFRD) (OJ L 277, 21.10.2005, p. 1). 73Council Regulation (EEC) No 2019/93 of 19 July 1993 introducing specific measures for the smaller Aegean islands concerning certain agricultural products (OJ L 184, 27.7.1993, p. 1). 74Council Directive 91/676/EEC of 12 December 1991 concerning the protection of waters against pollution caused by nitrates from agricultural sources (OJ L 375, 31.12.1991, p. 1). 75 Council Regulation (EC) No 1257/1999 of 17 May 1999 on support for rural development from the European Agricultural Guidance and Guarantee Fund (EAGGF) and amending and repealing certain Regulations; OJ L 160, 26.6.1999, p. 80–102 76 Council Regulation No 1782/2003 establishing common rules for direct support schemes under the common agricultural policy and establishing certain support scheme for farmers (OJ L 270, 21.10.2003, p. 1). 77 Council Regulation (EC) No 1698/2005 of 20 September 2005 on support for rural development by the European Agricultural Fund for Rural Development (EAFRD); OJ L 277, 21.10.2005, p. 1–40. 78 Directive 2000/60/EC of the European Parliament and of the Council of 23 October 2000 establishing a framework for Community action in the field of water policy (OJ L 327,22.12.200. p.1). 79 OJ C 319, 27.12.2006, p.1. 80 Council Directive 79/409/EEC of 2 April 1979 on the conservation of wild birds (OJ L 103, 25.4.1979 p.1). 81 Council Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and flora (OJ) L 206, 22.7.1992, p.7). 82² Council Regulation (EC) No 1698/2005 on support for rural development by the European Agricultural Fund for Rural Development (EAFRD), OJ L 277, 21.10.2005, p. 1 83 Council Regulation 1782/2003 establishing common rules for direct support schemes under the common agricultural policy and establishing certain support schemes for farmers, OJ L 270, 21.10.2003, p. 1 84 European Commission. Ex Ante Evaluation Guidelines, DOC 25 Guidance note D V2.doc. European Commission 85 Expenditure Review of the Early Retirement Scheme 2000 – Department of Agriculture and Food Johnstown Castle 2004 86 Rural Ireland 2025—Foresight Perspectives – joint publication NUI Maynooth/University College Dublin and Teagasc 2005 87 OJ L 206, 22.7.1992, pg 7. Directive as last amended by Regulation (EC) No 1882/2003 of the European Parliament and of the Council (OJ L 284, 31.10.2003, pg 1) 88 OJ L 206, 22.7.1992, pg 7. Directive as last amended by Regulation (EC) No 1882/2003 of the European Parliament and of the Council (OJ L 284, 31.10.2003, pg 1) 89 Financial Impact of Rural Environment Protection Scheme Liam Connolly, Teagasc November 2005 90 Source: National Farm Survey, Teagasc, 2004 Directory: media -> migration media -> The milk carton kids media -> Events Date and Location media -> The Gilded Age: The First Generation of Historians by H. 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