8. Evaluation of Current Agricultural Schemes and Premia Payments Operating in Ireland

The scope of this study does not allow us make a detailed evaluation of all the schemes described in Chapter 2. The consultants decided to focus on a selection of schemes and payments for evaluation, based on their potential and actual influences on the natural heritage. These are included in 8.1 below.

In order to place agriculture schemes and payments in their proper context, we have included mention of other influences, including price and market supports from the CAP, market de-regulation and environmental policies, discussed in 8.2 and 8.3 below.

The consultants did not have time to examine the influence of other policy instruments such as taxation policy. However, we consider that this latter aspect needs further examination. Chapter 8 is set out as follows:

8.1 Evaluation of selected agriculture schemes and payments
8.2 Other agricultural policies which affect the natural heritage
8.3 Evaluation of environmental policies relating to agriculture

8.1 Evalutation of Selected agriculture Schemes and Payments

The literature review and case studies highlighted the very considerable negative impact of sheep payments on the ecology and landscapes of the Western Seaboard, including the western parts of Counties Mayo and Galway. It has been clear for a number of years that the Ewe Premium, supplemented latterly by the Rural World Premium, has had a major influence on the overstocking of commonages in disadvantaged areas. Sheep headage payments also encourage overstocking when combined with the Ewe Premium (see Section 8.1.2 below).

The Ewe Premium is an EU-wide system for the support of the sheepmeat sector. As such, Member States are not given much room to make adjustments which might suit their national or regional situations. Centralised planning in Brussels meant that the stocking rates were set to the lowest common denominator to apply to all Member States. Similarly, the payment limit of 500 ewes outside Less Favoured Areas (LFAs) and 1000 ewes within LFAs is an EU-wide limit which is unable to address the wide regional variation in soil, vegetation and farming systems throughout the Union.

The crudity and inflexibility of the Ewe Premium Scheme is further illustrated by the refusal by the European Commission to make amendments to the scheme. A number of countries, including Ireland, made requests for such amendments. In its recent review the EU Sheepmeat Regime, the Commission states that it does not foresee the need to make any changes to the existing basic regulation. In 1996, the Department of Agriculture requested clearance to introduce environmental cross-compliance on the Ewe Premium in order to address the serious overgrazing in western commonages encouraged by the payments. This was rejected on the basis that payments may be made under the REPS to reduce stocking and payment of the Ewe Premium would be conditional on farmers joining the REPS (see also Chapter 9).

The environmental conditions in the Ewe Premium Regulation allow Member States to refuse or reduce premium payments to farmers if the environment is being degraded. Until 1998, Ireland chose not to enforce these conditions. The economic vulnerability of hill sheep farmers and the power of the farm lobby in opposing radical changes are the main reasons why official action to curb overgrazing has been stalled for so long (see also Chapter 7, which examines the socio-economic aspects of payments).

The introduction of environmental cross-compliance in degraded commonages is described in Chapter 5.1. From 1998, sheep farmers in degraded commonages will only be eligible for Ewe Premium and sheep headage payments if they agree to enter the REPS and abide by measures designed to reduce grazing pressure under a framework plan for each commonage.

Although the primary incentive for farmers to overstock sheep originates from Brussels, the Irish government's response remained inadequate until April 1998, when above-mentioned environmental cross-compliance measure was introduced. Overgrazing has been a serious problem since the late 1980s, and it has taken about ten years for the State to bring in measures to counteract this problem. The State could have introduced a national scheme to compensate farmers for removal or reduction of sheep from degraded areas, and it was free to do this under European policy. Indeed, the Departmental policy review of 1990 (Government of Ireland, 1990) recommended adapting the Extensification Scheme for this purpose, but no action was taken at the time. The slowness of the Department of Agriculture and Food to begin to address the problem when it was first identified is part of the reason for the widespread environmental damage that has occurred in the meantime. Finally, it must be mentioned that farmers themselves bear some responsibility for this situation, and there has been a tendency for farming representatives to be reactive rather than pro-active in addressing the problem.

8.1.2. Compensatory Headage Allowances (Headage Payments)

Headage payments are a very important source of income for farmers in the lower income categories, especially in Disadvantaged Areas. Cattle farmers appeared to be the most heavily dependent, followed by sheep farmers. The vast majority of more than 100,000 farmers in the scheme receive relatively small payments (Kearney et al. 1996, see Chapter 7.1). The scheme is explicitly social in purpose, and has been partially successful in achieving its aim of maintaining rural populations in marginal farming areas. Since payments are made per animal and therefore linked to production, and are additional to Ewe Premium payments, the scheme has encouraged environmental damage in sensitive semi-natural areas. This seems to be the case mainly for hill sheep, when combined with the greater influence of the Ewe Premium.

The headage payments scheme has been criticised in several recent policy assessments (see Chapter 7) for being poorly targeted and encouraging overstocking. The ESRI Mid-Term Review (ESRI, 1997) suggests that payments should ideally be replaced by a scheme more related to environmental objectives or at least de-coupled from stock numbers, while the Kearney Report recommended that environmental cross-compliance be introduced. We are in agreement that cross-compliance and de-coupling should be introduced, but we wish to emphasise the importance of supporting farm incomes in Disadvantaged Areas, and this is borne out by the study described in Chapter 7. Our view is that the total package of income support (such as a modified headage payments scheme or equivalent, and social welfare payments) to less well-off farmers should be maintained. Whatever the eventual form of this total package of support, it should include sustainable agricultural management as a primary objective. Many of the more marginal farms also coincide with areas of natural heritage value. Supporting these farms with environmental conditions as a primary requirement could help to alleviate the pressure on wildlife habitats and help to maintain farm incomes.

In the EU’s proposed Rural Development Regulation (European Commission, 1998), headage payments will be paid on a per hectare basis on the condition that they are environmentally compatible. This proposal has yet to be agreed by the EU Council of Ministers and is likely to meet with resistance. If agreed, this new measure, alongside the cross-compliance measures in degraded commonages, could contribute to reducing the incentive to overstock. However, the experience of agriculture schemes to date indicates that area-based payments must still be explicitly linked to environmental objectives if they are to be of benefit in conserving habitats and species.

8.1.3. Beef Payments (Suckler Cow, Special Beef and Extensification Premiums)

These payments were increased since the CAP reforms of 1992 to compensate farmers for falls in market support, and unlike headage payments, they are not biased towards lower income farmers. Currently, they have no environmental conditions attached. Payments are based on the forage area of each farm and subject to a relatively generous stocking limit, and are directly linked to animal numbers. The eligible forage area is the utilised agricultural area, and excludes non-agricultural land such as woodland, hedges, ditches, etc. The larger the forage area, the greater the number of stock for which payments may be claimed, since payments cannot be made if stocking levels exceed 2 LUs in the case of Suckler Cow and Special Beef Premiums.

The Extensification Scheme would appear at first sight to make a useful potential contribution to the environment. As a generalisation, low stocking densities have been shown to benefit wildlife and maintain traditional agricultural landscapes. However, there are no environmental conditions attached to the Extensification Premium. Its primary objective is to discourage an increase in production by maintaining relatively low intensity cattle farming. In order to obtain the Extensification Premium, stocking densities must be below 1.4 LUs. We conclude that the Extensification Premium has and little or no positive environmental benefit in its current form.

The combined effects of the current compensatory payments may provide an incentive to farmers to expand their utilised agricultural area to avail of the payments, at the expense of non-agricultural land such as scrub, wetland, etc. There are some indications that this may be the case in the Burren, where a considerable amount of land reclamation has taken place in recent years. However, eligibility for compensatory payments may be only one of a number of incentives for reclamation (see Chapter 5.2). There is evidence from other EU countries that the current Extensification Scheme has not been effective in supporting the least intensive producers, who are also likely to be managing land of the highest nature value. The Agenda 2000 proposals, if agreed, will allow area-based payments to be made under the Extensification Scheme and the eligibility rules will be tightened up (European Commission, 1998). This may result in more positive environmental benefits.

Agenda 2000 also provides for an increase in the Suckler Cow and Special Beef premiums (European Commission, 1998). It is therefore particularly important that environmental conditionality is built into the all the new payments. This is discussed further in Chapter 9.

8.1.4. Arable Aid Scheme

As with the beef compensatory payments, the arable payments are designed to control cereal production and compensate farmers for reduction in cereal prices of 30% following the CAP reforms. The scheme is an especially important source of income for specialist cereal growers and represented 83% of output value in 1997 (DoA, 1998). Although farmers can choose not to enter the scheme, in practice, it would not be economically worthwhile because of the reduced cereal prices.

Payments are conditional on eligible land, which means that the area under cereals on each farm effectively cannot be increased beyond the 'base area'. Payments are also conditional on set aside. In EU policy terms, the current set aside scheme is strictly a means of controlling output, and the attached environmental conditions are inadequate. In practice, the management of set aside observed in the case studies is not beneficial for wildlife, and the poorest land on the farm is usually allocated for set aside. This could be permanent pasture, which is then re-seeded, managed by topping and followed by taking a crop of silage in September. On the farms visited, there were few areas of any conservation value (see Chapter 5.4). Most wildlife habitats have been removed during the 1970s and 1980s, funded by the Farm Modernisation Scheme and the Farm Improvement Programme in the past.

Since 1996, transfer of eligibility rules allow farmers to plough up and re-sow areas previously ineligible under the Arable Aid Scheme. Our observations indicate that the land with the highest conservation value (such as low intensity pasture) is the first to be converted to intensive cereal production.

Although cereal farming occupies only 308,800 ha, of which 33,000 ha are at present in set-aside, most of this land is farmed intensively, and most is situated in the south and east of the country, which has the lowest biodiversity. It would clearly be of value to introduce some environmental incentives which could be incorporated into intensive arable farming.

The farmers interviewed had no interest in the REPS; and habitat re-creation would have to be completely funded by grant aid before they would become interested. If this attitude is typical, the prospects for introducing any form of nature conservation in intensive tillage farms would be extremely limited unless there were adequate, well-targeted incentives.

The modified set aside measures proposed under Agenda 2000 would allow Member States to introduce five year set aside schemes so that environmental benefits could be enhanced. The compulsory element in set aside would be retained but the usual rate would set at 0% and small cereal farmers would remain exempt from the scheme (European Commission, 1998).

8.1.5. Rural Environment Protection Scheme (REPS)

The consultants take the view that the REPS is a very important scheme which has considerable potential to make a positive impact on the Irish rural environment. How the REPS operates in practice is therefore of vital importance. In this section, we have therefore decided to discuss the REPS in more detail than the other schemes and payments.

The Department of Agriculture and Food has a target participation of about one-third of all Irish farmers (approx. 40,000). The REPS is targeted on low intensity farming, including organic farming, which occurs throughout the country, but more often exists in the Disadvantaged Areas. Chapter 2.2.2 describes the scheme, its approach and conditions, and the uptake of the various supplementary measures. This study and others have noted that it is very difficult to give an accurate indication of the performance of the scheme in conserving wildlife and reducing pollution, since the baseline information is poor and no assessment programme has yet been put in place. The Department of Agriculture and Food collects comprehensive statistics on the number of participants, the area in hectares under each measure, and the payments made. However, these data do not reveal the performance of the scheme in meeting its environmental objectives. In the absence of monitoring data, we have to rely on anecdotal evidence from those who are actively involved with farmers in drawing up plans and promoting the scheme. In citing this anecdotal evidence, the consultants are aware that there are no concrete data to back it up. However, we feel that because certain aspects of the REPS are discussed among planners, the farming press and participants, these deserve mention, and could provide important lessons which could lead to improvements in the future.

Significance of REPS for farm incomes

At a REPS Conference in Johnstown Castle in October 1996, Tony Pettit, Teagasc Cattle Specialist, outlined the significance of the REPS for farm incomes. The income of cattle and sheep farms is well below other farming systems on comparably-sized farms. Based on the Teagasc National Farm Survey of 1995, the average income levels per acre for all farm sizes in 1995 were: dairying, £250; tillage, £150; and cattle, £97. Direct payments accounted for 80-95% of overall income on cattle farms compared to 9% on specialised dairy farms. Drystock farmers make up the majority farm enterprise of those farmers entering REPS.

The high uptake of the REPS by drystock farmers is as a result of the current low beef prices. This means that low input systems which are compatible with the REPS or the Extensification Scheme offer greater returns for many drystock farmers. It appears that many farmers have been able to join the scheme without having to decrease their stocking levels. Indeed, there has been scope, on the advice of Teagasc and private consultants, to join the REPS and intensify production up to REPS thresholds, and this is noted by the consultants as a cause for concern. Nutrient management planning has made significant cost savings for farmers and the evidence from the consultants’ observations suggests that this has probably decreased nutrient run-off to watercourses.

For many dairy farmers, the current profit levels from intensive production and CAP price support mean that joining the REPS would result in reduced profits. Those tillage farmers involved in intensive winter cereal production are also achieving high production levels. This level of production combined with cereal aid payments means the REPS is not an attractive proposition, mainly due to the cut off level for payments at 40 ha.

In contrast the payment levels for existing organic farms and horticultural enterprises in REPS and for conversion to organic farming are attractive and have lead to a major increase in the number of farms and the hectarage under organic management.

The consultants welcome the recent improved treatment of REPS payments under the 1998 Social Welfare Bill which provides for an extension of the current exemption of the first £2,000 of REPS payments for means-testing purposes (Unemployment Assistance, Pre-Retirement Allowance, Old Age Non-Contributory pension) to the new scheme of compensation for compliance with SAC conditions. However, we remain concerned about the imbalance in the treatment of afforestation and REPS payments in the taxation system with REPS payments being taxable and forestry payments being tax-free.

Standards of REPS farm planners

There has been criticism of the poor habitat identification and lack of ecological skills among REPS planners. Over 70% of REPS planners are agricultural graduates. Some of these agricultural graduates have completed further courses in environmental management. The Department of Agriculture and Food has now introduced a more rigorous course for approval of planners; trainee planners now have to attend an intensive three day training programme and must complete three plans to the satisfaction of the Department before they receive approval. However, in general, short environmental courses are unlikely to completely reverse years of training and experience in intensifying production. In the experience of the consultants, some planners are reluctant to recommend retaining certain habitats to avoid constraining farmers from reclaiming or afforesting these areas in the future. Some planners also appear to miss habitats due to poor habitat identification skills.

A critique of the standard of REPS planners in the farming press was presented by Joe Hall (Countryside Management Expert, Teagasc). He noted that: ‘Some (planners) have an innate interest in the rural environment and submit excellent plans, some show willing and retrain in the agri-environmental field and others try to harness REPS to their production ethos without due regard to its environmental remit. How many farms have been “straightened out” prior to a REPS application? Are the planners involved lacking in environmental awareness or complacent?’ (Irish Farmers' Journal, 5 July, 1997, Page 37).

In a report on the EU wide assessment of schemes operating under the Agri-Environmental Regulation 2078/92, BirdWatch Ireland noted the lack of professional ecological experience within the Department of Agriculture and Food, and also noted that some ecologists had complained that their services are used only to a very limited extent, if at all.

Because of commercial pressures, planners seek to attract the maximum number of clients into the REPS. Farmers tend to choose planners who make plans with the least constraints, within the REPS rules. There is plenty of scope within the REPS for achieving minimum or maximum benefits for the environment. Environmental management may impose extra constraints and costs, and these can be minimised by the planner. Since the majority of planners are agricultural graduates, they have been trained to maximise production and profit for farmers. The REPS is often seen as just another income scheme for farmers and not as a change of direction in agriculture policy. Although some planners have undergone limited environmental training, this is unlikely to provide all the necessary nature conservation skills.

The Department of Agriculture and Food requires that all plans drawn up in relation to SAC/NHA areas are signed by an environmentalist (Department of Agriculture, REPS Circular No. 9/98). In Teagasc, this role often falls on those members of staff who have completed a diploma course in environmental management. With private planning agencies the environmentalists carry out this role. However, we understand that many of these environmentalists never walk the farms in question. They sign the plans, which are usually prepared by an agriculturalist, based on the guidelines provided by the Dúchas staff. However, since management plans are unavailable for most SAC/NHA sites, they rely on the notifiable actions list for the site. This does not insure that all of the required management is carried out by the farmer. The farmer does not usually meet with the environmentalists. This means that there is little opportunity for the farmer to become more aware of the environmental value of the site.

In contrast, the Department of Agriculture in Northern Ireland (DANI) employs mainly environmental graduates with a farming background. There seems to be a doubt among agriculturalists that environmentalists would have a good enough grasp of farming in order to advise farmers. However, many of the advisers on agri-environment schemes in Northern Ireland are environmental graduates, some with a farming background (DANI, pers. comm.).

Farmers' attitudes towards the REPS

A striking example of the direction some farmers are being advised to take was given in the Irish Farmers' Journal in 1996. An article 'Transforming a Westmeath farm', describes the development of ‘JJ's 90 difficult acres’. ‘His 147 map acres, that were once mostly cutaway turf bog, are now adjusted to 118 by Christy Jones of Teagasc’. Hour after hour on the Hymac eventually got the drains in and brought about an acceptable seed bed. He started with 10 acres in 1992, 20 acres in 1993, 28 in 1994 and 10 in 1995. The reclamation continues amidst a plethora of development around the farmyard which has given him a modern efficient dairy farm. Grants are promised under the Control of Farmyard Pollution Scheme for building work. This year JJ has joined REPS. With nitrogen use at about 110 units per acre, the REPS targets should be easily met. Like most young developing farmers, JJ's big handicap is now the shortage of milk quota.’ (21 October, 1996, p.31). It is not possible to state how many farms have been re-structured prior to applying for the REPS, and in practice this information would be difficult to obtain. Anecdotal evidence from some planners suggests that other such examples exist. The Department of Agriculture and Food has stated in a personal communication that it is not aware of re-structuring of farms prior to entry into the REPS and that the above example is likely to be the exception rather than the rule. However, the consultants feel that this issue should be given greater attention. In the opinion of several Wildlife Rangers interviewed for this study, the re-structuring of farms prior to entering REPS was a significant problem.

A survey of 200 REPS farmers by Teagasc in 1995 revealed some interesting views about the scheme. The average farm size was just over 30 hectares, most were in drystock farming and a large minority were part time farmers. Most farmers viewed extra income as the main benefit, followed by improving the appearance of the farm. A significant proportion regarded pollution control as the main benefit. However, the image of farm produce and the benefits for wildlife were not considered important. Most farmers felt that the capital cost of pollution control was the major negative aspect, along with limitations on expansion. Most farmers interviewed felt that the REPS training course was valuable. Forty per cent of farmers who joined the course wanted more outdoor practical sessions and 45% wanted refresher courses. The training course is arguably one of the most important parts of the scheme, since real change occurs when farmers' attitudes change towards conservation (Source: REPS conference, Johnstown Castle, Co. Wexford, October 1996).

University College Galway Survey of Farmers and the Environment (1997)

A recent study has presented a snapshot of attitudes to the environment following a survey of thirty-two REPS participants and eighty-one non-participants in Galway in 1997 (Tina Aughney, pers. comm.). The response to three of the questions posed is given in the Table 8.1.

It would appear from the survey that REPS farmers have no greater awareness of environmental issues than non-REPS farmers. This is worrying, as one of the aims of the scheme must be to raise awareness of these issues among farmers. The main reasons cited for joining the REPS scheme are to tidy up the farm and receive extra income. One of the main objectives of REPS, to protect wildlife habitats and endangered species of flora and fauna, was given a low priority among those farmers interviewed. If the REPS is viewed as just another income provider then it may have failed to meet its long term objectives.

It was widely thought that the scheme has had a positive effect on the consciousness of farmers towards the environment. However, the results of a recent UCG survey of farmers indicates that there is little or no greater environmental awareness among REPS participants. This REPS approach is new to many farmers, who have been educated in the production ethos and who have received advice and support to increase production from the state bodies and the farming press over a generation. It will take time for the concept of sustainability to be accepted by farmers.

We believe that the REPS has contributed significantly to supporting the incomes of farmers in the sectors most badly affected by changing agricultural policy and depressed markets. The whole-farm management approach of the REPS is on paper one of the most advanced agri-environmental schemes in the EU, and Ireland is the first country to introduce environmental cross-compliance into a CAP compensatory payment scheme. Its chief problem is 'quality control'. If the standard of REPS planning and inspection of plans is improved by employing more ecological expertise to complement the existing agricultural skills, the REPS could achieve very good results for protection of the natural heritage. The Department of Agriculture and Food is conscious of the need for monitoring and evaluation so that the scheme may be improved. Since the existing scheme will conclude in 1999, it should plan to address these important concerns for the planned new scheme beginning in 2000.

8.1.6. Early Retirement from Farming Scheme (ERS)

The scheme is described in Chapter 2.2.1. Our brief evaluation is limited to the personal experiences of several of the consultants and the remarks of interviewees, since the case studies did not reveal any examples of farms that were transferred under the scheme and because field studies could not be undertaken.

On paper, the ERS is a mainly a developmental scheme. The Department of Agriculture, when interviewed in connection with this study, stated that its main aim was to encourage elderly farmers to provide an opportunity for young farmers to practice farming. The objectives are to ‘redress two of the main structural defects in Irish farming, viz. farm sizes and the age profile of farmers’ and ‘the emphasis is on using the land released to increase and re-structure other holdings to make them viable’. The scheme appears to be attractive to farmers: by the end of 1996, over 5,000 farmers had been approved for payments and 169,000 ha were released to young farmers (see Chapter 2.2.1).

The EU environmental conditions state that ‘released land transferred to farming transferees must be farmed ... in harmony with the requirements of environmental protection’, and ‘released land transferred to non-farming transferees must be used in a manner compatible with the protection or improvement of the quality of the environment and of the countryside.’ The Irish scheme requires participating farmers to ‘farm in harmony with the requirements of EU and National legislation on environmental protection’, but this is not defined further.

In the experience of the consultants, elderly farmers tend to be less development-minded and sometimes have more sympathy with the natural environment than younger, development-conscious farmers (for example, see Section 8.5.3 above). For this reason, habitats that have remained intact for generations may be removed once the farm is transferred. This is quite understandable, and is similar to the changes that take place on non-farm properties in town and country transferred from older to younger occupants. However, it must be mentioned that this changeover does have potential negative environmental effects.

The environmental conditions in the Irish ERS state that farmers must comply with EU and national environmental legislation. However, the only countrywide wildlife legislation is the Wildlife Act, 1976, which is recognised to be inadequate in protecting species and habitats outside State ownership (see Chapter 1.3). The only other protective legislation applies to designated Special Protection Areas and Special Areas of Conservation, which cover less than 10% of the country. The Department of Agriculture and Food did not indicate that monitoring of the ERS included an environmental assessment.

The ERS conditions also state that where no suitable farming transferee can be found, owners are allowed to re-assign land for non-agricultural uses, forestry or ecological reserve creation. We are unsure if there is information on how much such re-assigned land exists and how it has been used, but this could merit some further investigation.

8.1.7. Control of Farmyard Pollution Scheme (CFP)

We include a brief evaluation of this scheme because, although it has been discontinued, the Government has indicated in early 1998 that it may be introduced in the future. Furthermore, the CFP is the only capital grant scheme with a specific environmental emphasis and had an important linkage with the REPS. The scheme is described in Chapter 2.3.2. The objectives are to reduce water pollution, enhance Ireland's 'green image' and provide better working conditions on farms.

The CFP was evaluated as part of the Mid-Term Review of the Structural Funds (Fitzpatrick and Associates, 1997). The report found that the scheme was not sufficiently well-linked to the objective of controlling farm pollution. It recommended that any future scheme should be far more wide ranging than improvements to animal housing and waste storage facilities, in order to achieve overall anti-pollution objectives. The report also suggested that the CFP should have been better targeted towards the farms with the highest pollution risk.

While the criticism in the Fitzpatrick Report is understandable, there was a reason for focus of the scheme on lower income farmers. In the REPS, there is a requirement that farmers must have effluent storage in their farmyards under control at all times. In order to achieve this, farmers availed of capital grants under the CFP. This brought a day-to-day management element into the control of farmyard pollution which was previously missing. Before the REPS was introduced (in 1994), the CFP merely provided capital grants for upgrading effluent storage on farms, but there was no follow-up in terms of monitoring the management of those upgraded farmyards. Since the REPS encompasses whole-farm management, the Department of Agriculture considered that it was important to encourage as many farmers into the REPS as possible, and this could only be achieved if their farm waste management was up to the standards specified in the REPS.

A survey of 92 randomly selected CFP participants in 21 Irish counties in August/September 1996 demonstrated that 77% of all slurry produced was spread before the time of the visit in August/September. Nineteen per cent planned to spread slurry after September 30. About 80% of the participants were complying with the REPS standards for pollution control, while 30% were actually participating in the REPS. This finding contrasts with the finding of the case study of dairy farming in Kilkenny, where farm waste management was found to be unsatisfactory (see Chapter 5.3).

A study of the causes of pollution in Lough Conn (McGarrigle et al., 1993) found that although £5 million had been spent on winter housing for cattle, this did not appear to have helped alleviate water pollution. Large amounts of slurry had accumulated in slatted sheds and the stored slurry was subsequently spread on land in the autumn, coinciding with heavy rainfall which washes into streams and rivers. Many farmers were reported to have waited for rain so as to wash the slurry in, rather than spreading it when dry weather is forecast.

This illustrates a more general problem with schemes operating in Ireland. Follow-up and monitoring of the consequences of schemes is generally inadequate. In this case, grants were given to farmers under the CFP and the FIP to upgrade farmyards and increase storage capacity so as to reduce the risk of run-off from farmyards. It is generally considered that the CFP did reduce the risk of serious pollution arising from farmyards, and this is confirmed by an interview with the North-Western Regional Fisheries Board. Another indicator that the CFP has reduced serious pollution incidents from farmyards is the gradual fall in recorded fish kills since the CFP came into operation in 1989.

This is only part of the story, however. The Control of Farmyard Pollution Scheme (and the Farm Improvement Programme which preceded it) were capital schemes which did not address the need for adequate land area, soils, and good slurry management practices. In one sense, the CFP has been an aid to intensification and to exacerbation of the water pollution problem, since more cattle can be housed in winter compared with traditional out-wintering with associated low stocking rates. Increased winter feed production (usually silage) also requires more intensive fertiliser application. Large quantities of slurry have to be disposed on an inadequate area of land, and often in weather conditions which are unsuitable. Slurry tanks which are designed for a particular volume of waste may have to emptied in unsuitable weather conditions to avoid overflows. Our information suggests that this is a regular occurrence.

The above may tend to contradict the assertions of some in the agricultural sector who claim that slurry management is under control. Our contention is that many farmers are not adhering to codes of good practice for farm waste management. Unless a future capital grant scheme for upgrading farmyards is strongly linked with stocking rates, availability of land, adherence to codes of good practice, and curbs on accepting slurry from intensive pig units, the situation of water pollution in Ireland is likely to deteriorate still further.

We do not wish the above criticisms to give the impression that there are no positive aspects of the CFP. The scheme has certainly helped to increase the storage capacity of many farmyards, and thereby reduced the risk of slurry tanks overflowing, which has led to so many fish-kills in the past. But a capital grant scheme such as the CFP is only part of a package of measures which are needed to reduce agricultural pollution. The CFP was a stand-alone scheme unrelated to stocking rates, fertiliser application rates, codes of slurry management and soil nutrient status, and this was its Achilles heel. Future capital grants for pollution control will have to be strongly linked with nutrient management planning for entire farms and tied in with stocking densities which reflect the carrying capacity of the soil to accept farm wastes. With this in mind, the link that had been established between the CFP (before its suspension) and the REPS was a move in the right direction.

8.1.8. Other Schemes and Payments

In this section, we make a brief evaluation of other schemes and payments which may have an influence on the management of the natural heritage.

Afforestation and Premium Scheme

The Afforestation and Premium Scheme was the subject of a review of Irish forestry policy commissioned by the Heritage Council in 1997. To avoid overlap, forestry did not form part of this study. However, a number of key points need to made in relation to the interaction of forestry with agriculture:

Agenda 2000 proposals for forestry

In the Agenda 2000 proposals, forestry is to be included as part of an overall rural development policy. The proposed new EU regulation on support for rural development (European Commission, 1998) mentions sustainability in relation to forestry for the first time. The forestry proposals are similar to the existing EU forestry regulation, No. 2080/92. Both the old and the new draft regulations state that in the case of ‘fast growing species cultivated for the short term’, support will only be given if ‘the planting is adapted to local conditions compatible with the environment.’ We are of the opinion that, in general, industrial plantations of fast growing, exotic conifers on agricultural land in Ireland are neither sustainable nor adapted to local conditions compatible with the environment. However, the definition of a fast-growing species grown for the short term is not elaborated upon, since the Commission has not provided a list of such species.

LEADER and INTERREG

These schemes are so-called 'Community Initiatives' and are directed at rural development rather than focusing specifically on agriculture. Our assessment is that they have a marginal impact on the natural heritage in comparison with CAP compensatory payments and CAP schemes under the 'Accompanying Measures'. There has been at least one case where a LEADER-funded project has impacted negatively on the natural environment, but this was a commercial turf extraction project, and not an agricultural project. We are not aware of agricultural projects under the current INTERREG scheme which have had damaging environmental effects.

Erne Catchment Nutrient Management Scheme

This cross border scheme was introduced as part of EU Special Support Programme for Peace and Reconciliation. Free advice by consultants on nutrient management planning in the Erne catchment is offered to farmers. The scheme was targeted on the Erne catchment because of a deterioration of water quality associated with excessive nutrient inputs from agriculture.

To date, the scheme is more successful in Northern Ireland, with 690 plans completed, than in the Republic, with only 30 completed plans. The Department of Agriculture in Northern Ireland (DANI) has carried out a pollution risk assessment of up to 2,000 farms each year, which enabled DANI to target the most intensive farmers in the catchment. This information enabled the consultants to focus on the farms with greatest pollution risk.

One reason given for the poor participation rate in the Republic was the existence of the REPS; however, the farmers to which the Erne scheme applies are too intensive to join the REPS. In addition, in the Republic there is no system of pollution risk assessment and the consultants were left to target the farmers themselves. It appears that the active involvement of DANI was part of the reason for success north of the border. This brings into question the performance of the Department of Agriculture and Food, since there appears to be no other good reason why there should be such a low participation rate south of the border.

8.2. Other Agricultural Policies which Affect the Natural Heritage

Since this study is concerned with agriculture schemes and payments, we do not intend to make a detailed evaluation of other agricultural policies, but merely to allow them to be placed in the context of agricultural policy in general. We noted that agricultural schemes and payments are not the only influence on the way that agricultural land is managed. Direct payments are of most relevance to small and medium farmers and less intensive farmers in the sheep and beef sectors, and to cereal farmers. In contrast, direct payments play a very small role in the dairy sector, which is illustrated in the dairy case study (Chapter 5.5). Dairy farmers rely on price support, and the sector is controlled by production quotas and a super levy system. (The situation of dairy farmers may change when the dairy cow premium is introduced under Agenda 2000). The pig and poultry sectors are not eligible for direct payments or price support under the CAP, and are essentially deregulated. The dairy, pig and poultry sectors represent the most intensive livestock enterprises in Ireland, and this is reflected in the policy of the Environmental Protection Agency (EPA): large pig, poultry and dairy enterprises will eventually be subject to Integrated Pollution Control Licencing (IPCL) because of their high pollution risk.

Influence of market supports and de-regulation of markets

Some European policy analysts have concluded that high artificial prices under the CAP encouraged farmers to expand and intensify, thus leading to environmental damage. While this may have been the case in the earlier decades of the CAP, there are indications that low prices may also encourage farmers to intensify, in order to make the best of narrow profit margins. The Agenda 2000 proposals include the eventual phasing out of dairy quotas in 2006, which is likely to result in a fall in the price of milk. One reaction of the sector to this prospect was illustrated in the Farmers' Journal, 7 February 1998. Senior advisor Stanley Lyttle of the DANI Development Division in Fermanagh/West Tyrone was quoted as stating that ‘the first priority is to increase farm output - more quota and cows. Land is not limiting’. If this trend is followed, the implications for the environment are not favourable. Phasing out of dairy quotas would appear likely to make it more difficult to reduce the impact of intensive farming on the natural environment.

The extreme intensification and concentration in the pig and poultry sectors illustrates the reaction of those sectors to the forces of the deregulated market. From an environmental viewpoint, enterprises which generate huge quantities of farm waste pose a considerable pollution risk, particularly since there often an insufficient area to spread slurry safely. Since there are no quotas on production, the pig sector can expand to meet market needs, and Government policy is to encourage this expansion, which is promoted by Teagasc. Planning regulations and IPCL are the only controls over the expansion of the industry. Most applications for pig installations are granted by local authorities and An Bord Pleanála, even though there are clear problems posed by large volumes of slurry that must be disposed in areas already suffering from over-fertilised soils. The problems posed by the pig and poultry industry in Cavan and Monaghan respectively are illustrated in the case study (see Chapter 5.3), and provide an example of the impacts of deregulated farming in Ireland. There is ample evidence from Ireland and abroad that deregulation forces smaller, so-called less efficient farmers to quit farming, while those enterprises that survive tend to become larger and more specialised as a response to market pressures. The consequences are almost always negative for rural society and the environment.

Irish agricultural policies

The last comprehensive review of Irish agricultural policy was produced by the Department of Agriculture in 1990 (Government of Ireland, 1990). In the main, Irish policy has faithfully followed EU agricultural policy in recent years, with the Department of Agriculture and Food acting as the agent of the European Commission. Since the policy of successive Irish governments has been to support the further integration of the country within the EU, it is not surprising that Irish agricultural policy is, to all intents and purposes, EU agricultural policy. The CAP compensatory payments are administered centrally by Brussels and up until now, could not be adjusted to suit national circumstances, while framework regulations allow some adjustment to national circumstances in the case of the Accompanying Measures and EU structural funded Schemes. This situation may change if the Agenda 2000 proposals are agreed: there should then be a greater degree of flexibility to adapt EU schemes to the Irish situation (see Chapter 9).

It is fair to say that agri-environmental initiatives applied in Ireland have come almost exclusively from Brussels. If the REPS was optional for Member States and no matching funding had been provided, it is highly unlikely that the scheme would have been put in place, at least on the present scale. Similarly, in terms of environmental legislation, the Government has belatedly introduced the Natural Habitats Regulations, 1997 only because it was legally required to so as part of its commitment to implement the EU Habitats Directive. The same is true for the implementation of most other environmental legislation. Meanwhile, the Government has delayed enacting the amendments to the Wildlife Act, 1976 for many years, and this could be attributed to the lack of pressure both from the Irish public and from Brussels, since it is a national matter and not subject to EU directives or regulations. The Government could have taken action to curb overgrazing in commonages by introducing national measures instead of waiting at least eight years until EU environmental legislation compelled it to do so and when EU funding finally became available.

We perceive several obstacles to progress in policy making for the harmonisation of agriculture with Ireland's heritage:

8.3. Evaluation of Environmental Policies Relating to Agriculture

How much influence does environmental legislation have on the way that agricultural land is managed? Until the introduction of the Natural Habitats Regulations in 1997, environmental legislation had very little influence over the management of the rural environment. Since 1997, farmers in areas identified as Special Areas of Conservation (SACs) are required to manage their land in a way that conserves its biodiversity. Farmers are offered the option of joining the REPS and receiving a special top-up payment in addition to the basic scheme, or, if they can prove economic loss arising from restrictions on their business, they can avail of a special compensation scheme administered by the Department of Arts, Heritage, Gaeltacht and the Islands. The introduction of the cross-compliance measure for degraded commonages in 1998 (see Chapter 5.1) was stimulated by the need to protect SACs which are being damaged or threatened by overgrazing. Management plans for SACs are being formulated by Dúchas. The total area covered by SACs is estimated as 550,000 ha, a large proportion of which is owned and managed by farmers. For the first time, farmers within SACs have had legal restrictions imposed on them for the management of their land. It can be concluded that the introduction of the Natural Habitats Regulations has had a considerable impact on the farming community in these areas because of these restrictions. It remains to be seen how this implementation of this legislation on the ground will affect habitats.

The loss of landrace varieties of cereal crops as well as the serious decline in Ireland's arable weed flora which appear to be a result of the abandonment of traditional cultivation and rotational cropping have been noted in Chapter 4.2. No particular support scheme can be held responsible for the abandonment of traditional cultivation / rotational cropping. This development is part of the general trend towards intensification and specialisation. Two factors would seem to curtail the maintenance or re-introduction of this type of land use:

The Nitrates Directive has so far not had a significant impact on intensive farmers. However, the Code of Practice for Nitrates could result in the preclusion of farmers who use more than 250 kg/ha of organic nitrogen from receiving additional slurry and manures from pig and poultry enterprises. The implementation of the Nitrates Directive is under critical review from the European Commission. An outline of the implementation of the Directive to date is given in Appendix V.

Planning legislation has had some effects on the pigs and poultry sector, in which large enterprises require planning permission and Environmental Impact Assessment (EIA). Spokespeople for the pig sector are regularly quoted in the farming press as stating that the establishment of new units is made more difficult because of the restrictions imposed by planning legislation. Planning permission and EIA became legal requirements in 1990 (see Chapter 1.3). However, it is rare that planning applications are refused, and conditions for slurry management are rarely properly enforced. In many cases where objections and appeals were made, the poor quality of EISs for pig units has been frequently criticised. Teagasc has conducted a majority of EISs for pig developments, as well as promoting the expansion of the pigs sector. As the case study of intensive agriculture in Cavan and Monaghan illustrates (see Chapter 5.3), regulation of slurry management is, in practice, seriously inadequate. If local authority and An Bord Pleanála planning policies are tightened up, planning legislation could begin to have a significant effect on the expansion of the pigs sector. Since Integrated Pollution Control Licensing (IPCL) was introduced very recently for intensive agricultural enterprises, it is not certain how this will affect these sectors, but this will depend on the EPA's enforcement. We believe that enforcement of slurry management on farms is labour-intensive, time-consuming and difficult to enforce. We conclude that planning legislation has had had some impact on the intensive agricultural sector, but does not seem to have curbed its expansion. We also believe that planning legislation is an inexact tool for controlling farm waste management. It is not yet clear if Integrated Pollution Control Licencing will have an impact on waste management by pig and poultry enterprises, since the process has begun very recently.

8.4. Summary

References

DoA (Department of Agriculture) 1997. Annual Report, 1997. Department of Agriculture and Food, Dublin. Web address: http://www.irlgov.ie/daff/Review97.doc
European Commission (1998) Agenda 2000: The Future of European Agriculture. Directorate-General of Agriculture (DG VI), Brussels. Web address: http://europa.eu.int/en/comm/dg06/
Fitzpatrick and Associates, Economic Consultants (1997). Operational Programme for Agriculture, Rural Development and Forestry (OPARDF) 1994-1999. Mid-Term Review Report, January 1997. Department of Agriculture and Food, Dublin.
Government of Ireland (1990) Agriculture and Food Policy Review. Stationery Office, Dublin.
Government of Ireland (1997). Sustainable Development: A Strategy for Ireland. Department of the Environment, Dublin.
McGarrigle, M., Champ, W., Norton, R., Larkin, P., and Moore, M (1993). The Trophic Status of Lough Conn. Mayo Co. Council, Castlebar, Co. Mayo.