I.	We suggest that decoupling all CAP compensatory payments partially or wholly from production should become a general principle. However, a move to area-based payments should not be regarded as a panacea.
II.	The best way of ensuring that payments do not encourage environmental damage is by giving positive incentives to farmers to manage their land in line with environmental objectives and phasing out incentives that encourage damage.

I.	We support the environmental cross-compliance now required for Ewe Premium and Compensatory Headage in degraded commonages.
II.	The proposed environmental cross-compliance measures for degraded commonages should be extended to include those unimproved coastal grasslands (sand dune systems and machairs) currently threatened by overgrazing.
III.	The Irish government should insist on the amendment of the Ewe Premium so as to provide for compensation to farmers for de-stocking in degraded areas. Ultimately, it makes no sense to have two competing schemes: the Ewe Premium, which is linked to production, and the REPS, designed to counteract another CAP scheme.

I.	Environmental standards should be introduced for tillage farmers through the introduction of a mandatory code of good environmental practice. This form of cross-compliance, in return for cereal aid payments, could apply to retention of existing hedgerows and habitat areas, nutrient management plans and management of set-aside areas for the benefit of wildlife.
II	. Existing unimproved grassland and other areas of conservation value should be excluded from eligibility for cereal aid payments.
III.	Our proposed new Farm Habitat Management Scheme could reward non-REPS arable farmers for environmental work which costs the farmers money (see Section 10.8). This scheme would offer linear and area payments for limiting pesticide and fertiliser use, hedgerow and habitat management and creation and the creation of buffer zones or wildlife corridors adjacent to hedges, habitats and watercourses.
IV.	The Department of Agriculture and Food should fund research into methods of implementing these recommendations by establishing pilot schemes, and tapping into the large amount of research which has already been undertaken in the United Kingdom and other European countries.

I.	REPS planners should be required to identify the habitat value of all areas on the farm. For example, in the ESAs in Northern Ireland, grasslands are classified according to the cover of perennial rye grass in the fields and each grassland type is marked on the map. If planners had to account for the wildlife value of each area, then the current weaknesses in habitat identification could be rectified.
II.	REPS planners should be required to mark all habitats on a field-by-field basis on the farm map. The current status of the habitat should be described along with the appropriate management practices. This should be entered on a computerised database, as in Northern Ireland.
III.	Nominated environmentalists should have a greater involvement in the REPS planning process.
IV.	REPS plans should have a larger section for habitat management.
V.	Ecological experts should be employed by the Department of Agriculture and Food to monitor the environmental quality of REPS planning and offer advice to REPS planners.
VI.	Ecological monitoring of a representative number of REPS farms should be undertaken to assess the effectiveness of the scheme. There should be regular evaluation to ensure that any weaknesses are identified and addressed. This is particularly important for the new REPS. A suggested approach is outlined in Chapter 6.3, which should give the Department of Agriculture and Food a good basis from which to prepare its monitoring and evaluation methods.
VII.	The new round of REPS must begin with a baseline study of each farm, on a field-by-field basis, to be undertaken when each farm first enters the scheme. This will enable an assessment of the progress made in environmental management through the course of the scheme.
VIII.	The provisions made in the Agri-Environmental Regulation (2078/92) for the support of ‘the cultivation and propagation of useful plants adapted to local conditions and threatened by genetic erosion’ should be incorporated into the next round of REPS in order to encourage cultivation of threatened native crop varieties or landraces.
IX.	We recommend that the new REPS places greater emphasis on environmental enhancement, in order to increase biodiversity, and not just maintenance of existing habitats and features. The creation of new habitats should also be provided for in each REPS plan.
X.	The focus of the new REPS on less intensive, small and medium farmers should remain. We believe that the new REPS would be undermined if the entry conditions were relaxed for more intensive farmers.
XI.	We support the role of REPS as an income supplement, but it should be primarily an agri-environmental scheme, with environmental objectives first and foremost.

I.	Habitat surveys undertaken by qualified ecologists should be a requirement for land released from a REPS plan to forestry under the Afforestation and Premium Scheme.
II.	We refer the Heritage Council to its recent report on the impact of current forestry policy on aspects of Ireland's heritage for further recommendations on the Afforestation and Premium Scheme.

I.	We recommend that a new scheme, similar to the Countryside Stewardship Scheme operating in Britain, should be introduced to provide an incentive for habitat management on those farms which are unsuited to participation in the REPS, or where farmers do not wish to join the REPS. These could include those more intensive farms which nevertheless may retain habitats of interest or which have scope for habitat creation and restoration.
II.	The new scheme should provide incentives not just for maintenance but also for restoration, and creation of new habitats.
III.	A habitat survey of each county would be needed to identify habitats which could benefit from the scheme. In any case, such a survey is likely to be necessary in order to implement the National Biodiversity Plan (in preparation as of May 1998).
IV.	The habitat survey should include areas which are not currently designated as NHAs or SACs in order to avoid duplication with areas already surveyed. Such a survey is likely to take a number of years, and could be undertaken on a phased basis. When each farm applies to join the scheme, a habitat survey should be carried out, and only those farms with the most to offer in terms of habitats and potential for habitat restoration and creation. This would enable the scheme to commence without having to wait the until the entire survey had been completed.
V.	The habitat survey would provide baseline ecological data through which the scheme could be monitored. Nutrient Management Planning (NMP) and adherence to a Code of Good Agricultural Practice on the whole farm would be required.
VI.	Environmental experts must play a central role in the operation of such a scheme to ensure appropriate environmental management is followed.
VII.	The scheme could be part-funded by the EU Structural Funds and national funds, in the same way as the Control of Farmyard Pollution Scheme and the Farm Improvement Programme.

I.	Nutrient Management Planning (NMP) should be a requirement for all farms. At present, NMP is only required in the REPS. Since REPS farms are by definition less intensive, there is no reason why NMP should not also apply to intensive farms which are likely to have a higher risk of pollution. Properly applied, NMP is not onerous on farmers, and can assist in saving on input costs.
II.	The Department of Environment and Local Government should issue planning guidelines for intensive agricultural enterprises. At present, we are of the opinion that planning applications and EISs do not receive proper scrutiny in the matter of slurry disposal on a catchment basis.
III.	The Government target for expansion of the pig industry appears to be unsustainable. Pig numbers should be capped, and preferably reduced, in catchments already suffering from eutrophication. A similar approach should be made for the mushroom and poultry sector in affected water catchments.
IV.	Expansion of intensive agricultural enterprises (pigs, poultry and mushrooms) must be restricted in sensitive areas and confined only to areas where the threat of nutrient enrichment of waters can be avoided. In terms of safeguarding and improving water quality, we do not believe that there is any further room for expansion of these sectors in Ireland without centralised waste processing, better physical planning by local authorities, EPA enforcement of IPCL, and mandatory nutrient management planning.
V.	A centralised waste processing facility, which was already proposed for Monaghan (see Chapter 5.3), should now be put in place in Cavan and Monaghan to avoid further environmental damage.
VI.	Pollution risk assessments should be carried out for all intensive farms, including the larger dairy farms, as in Northern Ireland. The brief should be prepared not only by the Department of Agriculture and Food, but also by the EPA and the Fisheries Boards.
VII.	A catchment management planning approach, such as in Lough Ree and Lough Derg, should become accepted practice throughout the country. This is the only practical way of balancing all of the pressures on water resources in each catchment, and may well become mandatory under the proposed EU Water Framework Directive.
VIII.	If the Control of Farmyard Pollution Scheme is to be re-introduced, it must be strongly linked with Nutrient Management Planning and whole farm management. There must be some means of curbing further increases in stocking after capital works are completed, unless the farmyard facilities are again upgraded to match extra livestock numbers.

I.	Co-operation between government departments as well as an open information policy are of utmost importance in ensuring the success of agri-environmental schemes in the Burren.
II.	A menu-type approach to the supplementary measures of the REPS may ensure a wider range of objectives to be achieved.
III.	In order to achieve the set environmental objectives, particularly with regard to habitat protection both inside and outside Natural Heritage Areas, the co-operation of agriculturalists and environmentalists in the drawing up of agri-environmental plans should be enforced.
IV.	The decoupling of compensatory payments from production could have a positive influence on the environmental quality in the region.

I.

Environmental conditionality should be built in to all the agriculture and rural development schemes and payments proposed in Agenda 2000. This could take the form of a basic code of good environmental practice, involving protection of wildlife habitats, nutrient management and protection of heritage features. If farmers are required to meet more demanding environmental requirements, these can be addressed by the REPS, the SAC scheme and/or our proposed Farm Habitat Management Scheme. We recommend that all state and voluntary bodies with environmental responsibilities should be invited to make submissions to the Minister for Agriculture and Food regarding the Irish government's negotiating position on Agenda 2000.

II.

There should be scope for the government to direct the new rural development package proposed in Agenda 2000 towards environmentally beneficial plans and projects. Submissions should be sought from state and voluntary bodies on plans and projects which can help to conserve biodiversity, advance sustainable agriculture (including organic farming) and sustain rural incomes and lifestyles