Review of the Rural Environment Protection Scheme

 Dear Sir / Madam,

 Please find enclosed comments from An Taisce in relation to the current review of REPS. 

An Taisce would like to take this opportunity to congratulate your department on the establishment and running of the Biodiversity Unit and associated efforts towards the preparation of a biodiversity plan for DAFF.  We look forward to working with your Biodiversity Unit in the preparation of this plan.  

 We are also delighted that the actions of the National Biodiversity Plan will be implemented by the unit, including the conservation and sustainable use of biodiversity as a priority in REPS revisions.  We thus see the involvement of the environmental NGOs, and not just the farming organisations, as being integral to this process.

 REPS has huge potential to contribute greatly to the ecological health and biodiversity of our countryside.  With this fourth REPS the focus should shift increasingly from mitigating environmental impacts to proactively enhancing biodiversity and emphasising the positive role that farmers played in the past in forming the landscape and supporting biodiversity.  In this way we can move towards increasingly viable and sustainable rural economies.   

 More than 40% of threatened species in Europe are dependent on extensively used agricultural landscape systems (Ref: Protecting nature in rural areas outside Natura 2000 -The role of agriculture.  Special report of the European Environmental Bureau, 2003).  The potential of REPS in combating the decline of threatened species in Ireland needs to be actively expanded in REPS 4.

 Specific Comments in relation to the Review of the Rural Environment Protection Scheme:

1. Hedgerows

May we also take this opportunity to refer to the relevant recommendations of the Westmeath and Roscommon Hedgerow Survey Reports 2005, available to download from each County Council’s website.  The Laois and Offaly Hedgerow Survey Reports should also be available from these local authorities in the New Year. 

 The recommendations in these reports, which relate specifically to improvements in hedgerow research, management and conservation in an agricultural context, are based on detailed hedgerow data collected throughout each county, and many are specifically geared towards DAFF and REPS and are listed as such.  Of particular relevance is the recognition of ancient, species rich, townland boundary, and other ‘high value’ hedges for prioritisation in terms of appropriate management and conservation measures to maintain or improve their condition and thus their nature conservation value and long term viability. There are two main requirements for successful implementation of such measures.  The first is training of REPS planners and inspectors in recognising such hedges, and having the specific skills to prescribe and monitor the most appropriate management for each hedge.  The second is monitoring and evaluation of such practices in order to assess and record changes or improvements that result from such conservation measures.

Non-native invasive species, particularly snowberry and dogwood, which have little or no biodiversity value and are invasive and damaging to the medium term viability of hedges, should be removed from Appendix B.

    Measure 5b

An Taisce also submit that active encouragement of the provision of native hedging shrubs in nurseries is urgently required in order to dramatically increase the amount of native hawthorn quicks available for hedge planting under the scheme.  Current experience of hedge planting with non-native sourced quicks is that they have lower success rates for the establishment of a hedge.  Both genetic differences and different flowering and fruiting times also reduce the biodiversity value of such hedges.  The conservation of biodiversity is an integral objective of the REP Scheme and must not be compromised by the planting of non native hawthorn and other quicks under the scheme.

2. Trees

Planting of native broadleaf trees and Scots Pine (native species and native seed) should continue to be encouraged within REPS.  Non native trees, while sometimes favoured by landowners as a matter of personal preference, should not be eligible for REPS payments, as their value for biodiversity is generally much lower than the value of native trees. For example, Sycamore commonly poses a significant threat to the viability of native woodlands, and planting of Sycamore on farms will increase the likelihood of sycamore seeding in to native woodlands in the landscape and out-competing the regeneration native species in such woods.   All non-native tree species should thus be removed from Appendix B of the REPS Handbook.

The minimum requirement of 25% of trees to be planted in open fields must not be compromised on.

While broadleaf plantations are highly conducive to enhancing water quality, landscape, amenity, and biodiversity, pulp wood plantations are environmentally damaging and are not compatible with the objectives of REPS or the conservation of biodiversity. No unsustainable pulp wood plantations, in particular Sitka spruce plantations,  should thus be permitted within REPS farms, whether in areas included for payment or in areas not included for payment.

3. High nature value farmland

Areas of agricultural land with high nature values are increasingly being abandoned in Ireland.   REPS should develop innovative strategies to target such landholdings and enhance Rural Development support for farmers with such landholdings if we are to curb such losses.  Such measures will need to be sensitively and inclusively developed as a matter of priority, being vital to halting the loss of biodiversity in Ireland, as we have committed to under the UN Convention on Biological Diversity.  Such strategies and measures are also important if Ireland is to justify the maintenance of farm incentive schemes in light of increasing opposition. 

4. Access

While access to arable or grassland fields should remain subject to landowner invitee restriction, and consideration must be given to impacts on privacy of houses or farming activity, there is a need to provide suitably safe access to uplands, coastal areas, archaeological monuments, and ‘Greenways’ and other walking and cycling routes, in the interest of the common good.  The incorporation of such access routes must be given serious consideration under REPS.

5. EDUCATION

Current educational standards for both REPS planners and participants is lacking in relation to hedgerow management and conservation, wildlife and biodiversity.  All planners and participants need to have a general understanding of the systems approach to the environment and of ecosystem functioning in order to fulfil meaningful environmental and biodiversity standards.  Funding and suitable expertise will be required to develop these educational aspects of the scheme.

6. MONITORING AND EVALUATION

Please find attached the final and updated report “Monitoring and Evaluation of the Rural Environment Protection Scheme”, as submission to this review of the REPS. The report, compiled by An Taisce and completed in     looks at the effectiveness of the monitoring and evaluation measures of REPS for wildlife and heritage protection.  Part 3 of the report contains conclusions and recommendations.

To quote from our report “Impacts on habitats, flora and fauna and landscapes as a result of the scheme are not monitored or recorded and cannot be assessed.  Therefore the overall aims and objectives, for which the scheme has been designed, have little information against which to be assessed.  This is a poor basis on which to continue and leaves the scheme open to criticism about its ‘value for money’.  In order to ensure the long-term survival of the scheme, An Taisce suggests that proper monitoring and evaluation must be put in place in order to buffer the scheme against any budgetary cuts in the future.  Value for money can and should be shown for heritage as an income support”.

Recommendations for improving monitoring and evaluation of the Rural Environment Protection Scheme.

3.2.1    Collection of data

Many environmental companies are working to improve systems for environmental monitoring and evaluation, whether by using spatial data management tools or environmental risk analysis computer programmes. However baseline data must be collected first for input into these programmes. 

1.                  At the outset, a full ecological survey should be undertaken by qualified ecologists at application stage for inclusion in REPS agri-environment plan.  70% of farmers questioned as part of this project support this.

2.                  A summary datasheet of this survey should be devised for entry into a national REPS database (currently under construction by Department of Agriculture) or revisions made to 5V Form for its inclusion.

3.                  These inclusions should include record of all habitats and their extent present on the farm and their ecological status, archaeological features, stonewalls etc,.

4.                  Management prescription if required for each habitat should be included.

5.                  Soil analysis report submitted with application should be entered in database, in a format that would be compatible with a national soils database under consideration by EPA as part of their Soil Protection Strategy for Ireland.

6.                  Data that must be retained for inspection by each farmer under Measure 11 on an annual basis, should be summarised by the planner on a specially designed form for inclusion with form 1C, which must be submitted in order to receive annual payments.

7.                  Information gained from compliance checks should be collated for analysis.

8.                  Duchas monitoring of Natura 2000 sites on REPS farms should be more specific and an obligation to maintain inspection records should exist.  These should specifically relate to ecological status of site and management plan.

9.                  Monitoring of specific indicator species should be undertaken as part of national ecological surveys.  It should be recorded if land is managed under REPS plan.

10.              The National Biological Records Centre as proposed by the Heritage Centre and included as an action in the National Biodiversity Plan should include in its remit the collection of data from REPS farms.

The collectable data should be examined from the perspective of evaluating the effectiveness of REPS for wildlife and heritage protection and databases should be established in conjunction with the Data Entry Bureau.  All implicated partners and datasets should be involved in these discussions, e.g. planners, EPA and Duchas.

The collection of this data should not place any additional administrative work on the farmer, but should be weaved into the applications and forms to be submitted by the planner at the appropriate stages.

3.2.2    Improvements to REPS forms

5V Form Evaluation Sheet for REPS

An Taisce believe that if the evaluation sheet was more specific it could provide a beneficial source of baseline data.  Landscape and biodiversity and supplementary measures are not included in the form.  There is a section for watercourses length, habitat type and archaeological features.  Hedgerow length is included.  However it is be recommended that the form be made more specific for example, to include:

• Habitat: Include Habitat Area (Ha) for each Habitat Type recorded.

• Include Supplementary measures such as Set Aside Area, Organic Area and Rare Breed types and area covered (Ha) by these measures. 

• Landscape: Type should be listed.

• Biodiversity: Flora and Fauna: Type/abundance

Quarries/Farm building that contains animal species (bat/barn owl)

• Archaeological Features: Name the type of feature, codes and SMR reference number. 

The 5V Form is “required to provide data to the EU on the performance of the Scheme". It should also include the above so that biodiversity and natural heritage are sufficiently represented in the assessment of its performance.

Record Sheets and Agri-Environment Plan

The Agri-Environmental Record Sheets are retained by the farmer to be inspected by the REPS planners.  The REPS planner countersigns any application for subsequent payments.  An Taisce would recommend that the information held should be more standardised so it becomes more database compatible. 

• Record sheet 5: with particular reference to measure four, five, six should be adjusted and made more compatible to database format so that the information contained can be inputted into a computerised system. 

• Record sheet 5 and 6: Measures two, three, four, five, six, seven and eight and nine should have the assistance of REPS planner for completion if required.  A detailed account of actions undertaken could be given and collected. 

• Record sheet 6: Other environmentally sensitive work carried out.  Farmers who carry out such work should be recognised and additional funding given so that going beyond requirements is more attractive than the minimal requirement. This would place further emphasis on the scheme's aims to benefit the rural environment.

• Record Sheet 7:  Measure A and Supplementary Measure 4 Long Term Set Aside.  Data needs to be collected in a format that is compatible with computerised database so that it is easily accessible and may be cross referenced with other sources and plans.  Progress from details given may be acquired from the data. 

• With regard to Measure 4, 5, 6 and 7 of the Agri-Environment Plan, they need to be in a format that the data could be captured easily and successfully.  At present the measure 4 specifies how habitats will be retained.  There is no mention of enhancement or habitat restoration unless a REPS planner recommends it in additional comments.  This section should be more focused as it is supposed to fulfil one of the REPS main objectives. 

3.2.3    Measure 11 and environmental indicators

The Environment Protection Agency (EPA)[1] is developing key environmental indicators for Ireland and has used the “uptake of REPS” as a response indicator to environmental problems associated with agriculture.

The EPA uses the DPSIR framework for the identification and classification of environmental indicators.  Indicators can be classified as drive force, pressure, state, and impact and response types.  This framework is based on the concept of cause and effect and reflects the interaction between the socio-economic and environmental systems.[2]

The EPA provide a map of the uptake of REPS by county area as illustration of this response indicator and state that 27% of the utilisable agricultural area is being farmed under REPS guidelines. 

Suggestions for use of the measure 11 records as environmental indicators

·        Monthly livestock inventory (Pressure indicator)

National livestock numbers are used by the EPA to indicate a pressure on the environment in terms of green house gas emissions, agricultural waste generation, acidifications, eutrophication and overgrazing.  Specific livestock numbers from REPS farms could be used in the same way.

·        Details on the import/export of organic wastes (Pressure indicator)

An indication of the amount of organic waste being produced and its movement could be used as a pressure indicator.  It may also assist in the identification of vulnerable catchments which may be at increased risk from organic pollution during particular times of the year.  The percentage of reduced inputs of organic waste may indicate indirect impacts on soil, flora and fauna and watercourses. 

·        Particulars of all chemical fertilisers brought onto the farm (Pressure Indicator)

The EPA use fertiliser sales as a pressure indicator, relating their over-use to one of the main causes of the levels of slight and moderate pollution observed in river water quality over the last 36 years.   As well as indicating the extent of this pressure for REPS farms, it could be utilised for comparative purposes with non-REPS farms.

·        Particulars of the works, stipulated in the farm plans that have been carried out (Response indicator)

This set of records is very plan specific but would nonetheless provide important information on the overall success of REPS, whether it be increasing facilities for storage of farm wastes or retaining stonewalls and hedgerows.  It could be a useful indicator for areas of farmland under agreement for target wildlife species. 

·        Winter housing dates of livestock (Pressure indicator) 

The winter housing of livestock may be used as an indicator of weather trends and perhaps help identify resultant regional farming practises.  An increased time spent in winter housing means that animal waste storage facilities must be available for longer and that more capacity is required.  It may also indicate the pressure for land spreading and consequent water quality risk.

·        Land applications of stored animal and other wastes and chemical fertilisers (Pressure indicator)

The amount of stored animals, wastes and chemical fertilisers are all indicators of the pressure exerted on the land and the environment.  Wastes and fertilisers have contributed to deteriorating water quality in rivers, lakes and groundwater.  Information on quantities applied and to which land parcels could be a very important indicator of the pressure exerted by agricultural 'wastes' and fertilisers.  The spreading of stored animal wastes in accordance with REPS guidelines could be used as a response indicator. 

·        Records of any other environmentally sensitive work over and above the scheme requirements carried out.  (Response indicator)

These include additional planting of hedgerows and the non-use of harmful chemical fertilisers.  This information would be site specific and could perhaps be used as a response indicator for farmers participating in REPS and the percentage of farms participating in the elements of the scheme.

3.3  Overall recommendations for a framework for monitoring and evaluation of REPS

[updated December 2005]

1. Establishment of evaluation unit within Department of Agriculture, to pursue improved monitoring, collection, collation and analysis of data.

2. The department should appoint a designated officer with responsibility for monitoring the collection of data necessary to compile the indicators for the mid-term evaluation of REPS.

3. Improvements should be made to forms and datasheets as suggested in section 3.2.2, to ensure a comprehensive dataset.

4. Collection of data for monitoring and evaluation of the impacts of REPS for wildlife and soils should be a priority as per suggestions in section 3.2.1.

5. Collection of baseline data should be a priority, particularly information on soils, habitats as per suggestions in section 3.2.1.

6. More emphasis on the integration of ecological considerations into REPS planner training.

7. Requirement for farmer to participate in more than one training course during lifetime of REPS contract.

8. All REPS plans should be prepared with assistance of ecologist.  Approved ecologist list should be drawn up by Department of Agriculture following consultation with Duchas.

9. Availability of REPS plans to other agencies.  There is no reason why third party information cannot be excluded to allow access to this information.

10. Establishment of a fully staffed biodiversity unit within Department of Agriculture[this has been done]

11. Begin preparation of sectoral plan on biodiversity at earliest possible date.

12. The [contribution of REPS monitoring data to the] National Biological Records Centre [currently being established (winter 2005)] would ensure a centralised information archive for all of these records into the future.

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We would appreciate being kept informed of developments with the REPS review and wish to continue to be involved as a stakeholder in the review process. 

 We wish you every success with the review of the REPS, and hope that our input at this time is useful.  Please do not hesitate to contact us for clarification on any of the topics included in this submission.

Yours sincerely,                                  

Anja Murray

Natural Environment Officer

An Taisce.