Consultation on evaluation (SEA) report

Response to strategic environmental assessment

As legally required the definitive response will be set out once the programme is adopted. The following, although necessarily provisional, provides a clear indication as to that response and as to the manner in which the SEA has been taken into account in preparing the programme:

• 
  On consideration of possible alternative approaches, it is accepted that the environmental report limited itself to one/two scenarios. However, two important and related factors have to be borne in mind. Firstly, the regulation provides a set menu of possible support measures under each of its objectives. Secondly, this programme provides for 80 per cent of total co-funded expenditure under the ‘environmental’ objective – the maximum allowable. The combined effect is to reduce the scope for alternatives.
  
• 
  While the restrictions reduce the potential for alternatives at a macro level, it is appreciated that they do not preclude consideration of possible alternatives at measure level to maximise potential benefit. Based on discussions with the EPA and other suggestions, certain measures have been adapted to this end. In the case of agri-environment, the measures proposed under REPS, Natura 2000 and Organic Farming will continue to develop a set of pro-active elements to restore and enhance the environment and biodiversity and to accommodate developments in agricultural policy and emerging environmental issues.
  
• 
  A number of issues relating specifically to forestry were raised as part of the SEA consultation process, i.e. water-quality, species selection, use of fertilisers and herbicides, reforestation and soils definitions. All applications are subject either to full EIA screening (if below 50ha) or full EIA (if above 50ha or if demanded). It is also worth remembering that the size of individual plantations is now quite small – less than 10ha on average. Statutory consultation with prescribed bodies is also part of the approval process, with full public consultation in many instances. In addition, the new GIS map-base will be extensively used not just to evaluate proposals against a range of opportunities and constraints, but also to guide the preparation and submission of such applications in the first place. The GIS system will assist in targeting investment in areas of high scenic sensitivity and converting established forests to fit better within the landscape.
  

• 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.

• 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.

• 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.

• 
  Reforestation is not grant-aided and forms no part of the programme. Conditions applying to reforestation are stipulated in accordance with the Forestry Acts (which are currently under review).
  
• 
  In relation to soils definitions, the question here is how to define a ‘peat’ soil. The approach used in Irish forestry is well established internationally and, at the Commission’s request, a new paragraph has been inserted into the RDP explaining the situation in more detail.
  
• 
  Initial discussions have taken place with Bord na Móna in terms of a holistic response to the future management of cut-away bogs, in which careful planting of woodlands will play an important role. The potential for easing flood-risk in this fashion (such as into the Shannon) will also be explored. At a ‘local’ level, riparian planting will be encouraged under the new Agro-Forestry scheme and this can have a significant and positive effect on localised flooding and soil-erosion.
  
• 
  The need for an effective and flexible monitoring system is recognised. Given the programme’s emphasis on environmental measures, its objectives and those of the SEA Directive are to a very significant extent compatible. In monitoring progress, use will be made of existing data sources. These will also be utilised to discern possible unforeseen effects and the need for appropriate response. Assessment of ‘environmental’ progress will be an inherent feature of annual reports etc. on the programme. In terms of broader level monitoring, the National Forest Inventory has just completed fieldwork that will provide excellent baseline information not just in terms of productivity, but also in terms of forest health and ecology. In addition to its relevance to the current programme, the monitoring system will also inform any successive programme.
  

• 
  REPS and the Natura measures will involve the collection of environmental data about each holding which will form the basis for detailed individual farm plans. This collection of data will feed into an ongoing analysis of the effects of the measures.
  
• 
  The plans and measures adopted under the Water Framework Directive will be taken into consideration as the programme progresses. A new Supplementary Measure in REPS is designed to address water quality issues, in particular lake catchments. Since farming is only one of the factors affecting water quality in these areas, the REPS Supplementary Measure will be complemented by actions under Axis 3.
  
• 
  Following the 2004 report by the Flood Policy Review Group, the Office of Public Works (OPW) was appointed as the lead agency to implement flooding policy in Ireland. The OPW is currently developing a strategy to manage flood risk, in conjunction with other relevant state agencies. The strategy is likely to involve non-structural measures such as storage and better flood forecasting and warning, but will also include structural works, particularly where flooding is already a problem. Developments here will be closely monitored and where necessary reflected in the programme measures.
  

• 
  Almost 60,000 farmers, farming 2m hectares in the scheme, farm to individual farm plans prepared by a professional
  
• 
  4,000km of new hedgerow contracted for establishment
  
• 
  2,700km of hedgerow contracted for rejuvenation
  
• 
  13,700ha contracted for new on farm habitat creation
  
• 
  17,000 farmers opted to provide nature corridors by increasing all field margins from 1.5m to 2.5m
  
• 
  7,000ha contracted for the establishment of traditional hay meadow
  
• 
  12,000ha contracted for the establishment of species-rich grassland.
  

The 1999 evaluation was carried out by Fitzpatrick and Co. and concluded that the scheme, as designed, has many attributes. It applies a set of standard environmental requirements to be met by participating farms, which together make substantive inroads towards achieving optimal environmental sustainability on farming units. A range of areas is covered, ensuring real improvements on participant farms, although the nature of improvements, correctly, depends on the nature of individual farms. The scheme furthermore ensures that these advancements may be guaranteed for a period into the future.

• 
  Soil quality has been protected through nutrient management planning and grassland management.
  
• 
  Chemical contamination of soils has been prevented or reduced through the limitations on nutrient input implemented by nutrient management plans.
  
• 
  The biodiversity measure has been successful in protecting habitats that may have been otherwise lost.
  
• 
  Hedgerow quality has attributed to avian diversity on farmland in general.
  
• 
  The visual appearance of farms is much improved. Maintenance of stonewalls and retention of hedgerows has a positive impact on the landscape.
  
• 
  Research done by Teagasc found that more archaeological features have been maintained on farms because of REPS. Prior to this, some of these were destroyed due to land improvement associated with more intensive farming.
  

The report concluded that REPS has a positive effect on the landscape by improved visual appearance, better management of designated areas of high nature value, and appreciation of historical and cultural values.

• 
  Improvement of wildlife habitats, hedgerows, farmyard tidiness and cultural heritage
  
• 
  Improvements to biodiversity-enhanced recreational opportunities, rural development and contributions to farmers’ incomes and the broader rural economy.
  

The report further concludes that the total benefits provided by the REPS are likely to exceed the costs associated with it and on this basis the scheme would seem to be justified.