Specific Details
Common Agricultural Plan (CAP) Strategic Plan Evaluation Plan
Intended results
To recommend that evaluation efforts are afforded to the degree to which administrative simplification has been achieved under the CSP, both from perspectives of beneficiaries and administrating authorities. Feedback to date has been that the current Common Agricultural Plan(CAP) is anything but simplified.
The proposed delay in farm payments for beneficiaries in 2023 as a result of the new system is a reflection of same and completely unacceptable, particularly in this financially challenging year, and must be resisted.
To highlight the importance of how evaluation efforts are conducted, covering not only the CSP and individual interventions therein, but also the national and EU policy instruments contributing to these goals, where aligning success or otherwise in the Common Strategic Plan (CSP) interventions toward broader economic/social and environmental ambitions.
To recommend that evaluation of the Suckler Carbon Efficiency Plan (SCEP) within the CSP evaluation plan is not limited to its contribution to net emission reduction, when the scheme also supports other broader objectives (e.g. animal welfare; economic and social sustainability in rural Ireland etc.). These broader objectives must also be factored into the success or otherwise of the Suckler Carbon Efficiency Programme (SCEP) scheme.
To stress that maximum flexibility must be afforded within evaluations undertaken, with swift corrective action taken where necessary to support adaptation for the benefit of the farmer within the current period.
To insist that maximum advanced payments must also be afforded within individual scheme measures, to limit the financial burden encountered by farmers in terms of their implementation.
To emphasise that farmers must not be unduly disadvantaged, penalised or prone to increased on-farm inspections as a result of data collection or monitoring mechanisms/requirements.
To insist that the privacy and data protection rights of the farmer are secure and protected at all times. The sharing or transfer of data from one data source to another, even within individual entities, is not permitted without the prior consent of the farmer.
To recommend that the level of ongoing monitoring of on-farm activities must be proportionate and similar to that afforded to other employment cohorts. Overall, the monitoring / inspection regime should seek to be more proactive toward achieving compliance, rather than merely tracking performance and applying penalties. Herein, the recommendations in the Agricultural Appeals Office review must be implemented without delay, and an Independent Chairman, with farmer representation appointed.
• Monitoring mechanisms (e.g. Fertiliser Register) need to be practical, with realistic timelines and expectations set. Undue or mandatory obligations on the part of the farmer to comply with monitoring activities in all situations will not be acceptable. Participation must be voluntary with adequate reward / compensation provided.
To recommend that within the context of promoting increased operating certainty and our environmental ambitions, unless to the advantage of the farmer, individual terms/qualifications of agri-environment schemes must hold true for at least the term of the new Common Agricultural Programme (CAP). There can be no downward revision or pro-rata reduction in either payment or maximum eligible area within individual measures of future iterations of the Agri-Climate Rural Environment Scheme (ACRES).
To emphasise that, in evaluations regarding the ‘impact of changes to direct payments on farm income', it is important that a range of outcomes is provided rather than purely an average / aggregate perspective, as relying on aggregate data only can conceal the true impact experienced. Similarly, the degree of change must also be quantified and presented.
To highlight the importance of using Scope 1 IE data coefficients where available, rather than using international coefficients in evaluating the impact of the Common Strategic Plan (CSP) interventions on GHG and ammonia emissions using coefficients. These may not be representative of Ireland's unique grass-based production system.
In addition, it is important to recognise that the emissions reduction benefit of CSP interventions may not be immediately obvious. A time lag often exists between intervention, execution, and emission reduction benefit.
The projected impact of the Common Strategic Plan (CSP) interventions must be provided rather than purely annual year on year variation of individual interventions, with comparisons vs Baseline, EU counterparts and annual variations also beneficial.
To highlight that it is essential existing data collection mechanisms (e.g. Agri-Climate Rural Environment Scheme (ACRES) results-based scoring) are maximised before the creation of new costly mechanisms, with regard to the proposal for ‘Monitoring and Evaluating Biodiversity (Habitats)' .
To seek clarification pertaining to R.33 ‘Improving Natura 2000 management'. A full review of the internal operating dynamic surrounding designations, compensation and applications for the Agricultural and Rural Convention (ARC) programme is required. The existing is not fit for purpose.
It is imperative that Government ensure, that maximum flexibilities apply at a local level and that actions are applied on a voluntarily basis only, but there must be an adequate financial package provided, independent of Common Agricultural Policy (CAP) funds,to compensate farmers for their endeavour and any lost income and/or asset value arising. With regard to the latter, false promises were made in the past to farmers operating in designated areas.
This must be rectified in the first instance, and the same mistake avoided at all costs. IFA will not agree with land being designated or re-wetted without prior agreement with farmers and full compensation must be provided for any reduction in farming activity or associated impairment of land values.
To highlight the importance of wider reflections being incorporated also. For example, with the Agri-Climate Rural Environment Scheme (ACRES), only thirty thousand applicants were identified as the participating Tranche 1 target, despite general acknowledgement that a significantly higher volume of farmers would be interested in participating in the Agri-Climate Rural Environment (ACRES) scheme, having been participants of previous agri-environment schemes.
In other words, infrastructural limitations and complexity of new results-based approach, in the case of the Agri-Climate Rural Environment (ACRES) Scheme, have to date shown to be constraining factor rather than farmer demand / inaction.
To highlight the importance of segregating agricultural related influence from other sources, and recognise too that not all Common Strategic Plan (CSP) interventions will exhibit direct benefit to improved water quality immediately. Similarly, it is important to recognise and account for the fact that other external factors (e.g. prevailing weather conditions) can have a significant influence on water quality.
Simply layering agricultural land use data onto the Irish Environmental Protection Agency's (EPA) water quality maps to determine the impact the Common Strategic Plan (CSP) interventions are having on water quality as outlined is overly simplistic and will yield erroneous results. Multi-year assessments, taking above consideration into account is required. Short-term trends are less reliable as seasonal influences and weather events can override the benefit of additional protective measures.
To question if similar profiling is planned for Best Agricultural Technique (BAT) on conventional farm operations (e.g. Low Emission Slurry Spreading (LESS); protected urea etc etc)? the same as Organic farming as per Spending Review 2023 ‘Profiling the beneficiaries of the Organic Farming Scheme 2023-2027'.
To question how many evaluations are planned for each / all objectives during the relevant period according to the draft evaluation plan that states ‘As per Commission Implementing Regulation (EU) 2022/1475, each Member State is required to evaluate each specific objective and cross-cutting objective at least once during the programming period'.
To question if there is there a hierarchy re individual groups/Committees and ultimate derived monitoring/evaluation outcomes?
To question if there is a mediation / appeals process where consensus cannot be reached either within or across units?
Charlie McConalogue
Minister (Department of Agriculture, Food and the Marine)
Paul Savage
Assistant Secretary (Department of Agriculture, Food and the Marine)