The European Commission’s initial observations on Ireland’s draft CAP strategic plan have been critical of the proposed plan’s scope in addressing environmental issues.

Brussels is requesting that many of the environmental targets contained in the plan are revised to reflect a higher level of ambition.

The ability of the proposed measures to meet their stated goals was also the focus of many Commission comments on the draft plan, which included “doubts” as to whether the plan “goes far enough”.

It was suggested in the Commission’s observation that some eco scheme options and Agri-Environment Climate Measure (AECM) requirements could be “automatically met” by farmers in some regions, with little or no departure needed from their current farming practices.

Schemes

The Commission expressed “concern” on the administration of a single payment rate across all eco scheme options, saying that this framework may limit the uptake of the more demanding or costly options within the scheme, such as tree planting.

Observations were also made that there is scope within the proposed eco scheme to further extensify livestock production beyond 1.5LU/ha, lower nutrient usage on farms and attach more conditions to their utilisation of the multi-species swards option.

Explanation

Further explanation has been sought on the expected efficacy of the Suckler Carbon Efficiency Programme, with the Commission stating that this scheme was “very much” relied upon to deliver greenhouse gas emissions reductions.

Details on how exactly the proposed AECM requires farmers to go beyond the mandatory requirements of the new CAP are needed by the Commission, as is clarification around the areas in which farmers are eligible for entry into the agri-environmental scheme’s higher-payment co-operative stream.

The mandatory requirements on the management of farmed peatlands was raised in the Commission’s observation, with the Department asked to clarify what management standards farmers on peat soils will be required to maintain, outside of voluntary conditions agreed to by farmers in schemes.

Plant-based

Ireland has also been invited to better explain how the CAP plan will facilitate a dietary shift towards plant-based proteins.

“While the CAP strategic plan acknowledges the need to increase awareness of healthy diets, interventions proposed seem to be limited.

“The Commission therefore invites Ireland to better explain how the shift towards healthy, more plant-based and sustainable diets will be achieved,” it said.