4th Nitrates Action Plan - Strategic Environmental Assessment

An Taisce's Submission to the Draft 4th Nitrates Action Programme. 28th November 2017

Evaluation of RPS Environmental Report on thet Strategic Environmental Assessment Report (SEA) of the 4th. Draft Nitrates Action Programme 2018-2021

November 2017

1. WHY A LEGALLY COMPLIANT SEA WITH ONGOING MONITORING AND APPROPRIATE REMEDIAL ACTION IS REQUIRED

The compliance of the Draft 4th. Nitrates Action Programme SEA Environmental Report with the legal requirements of the SEA Directive 2001/42/EC needs to be assessed and validated.

The SEA Environmental Report needs to asses and mitigate the impact on all of the considerations listed in the SEA Directive namely: “Biodiversity, flora and fauna population human health, soil, water landscape air climatic factors, material assets and cultural architectural and archaeological heritage” as well as “interrelationships”.

The 4th. Nitrates Action Programme needs to comply with Annex (1) (g) of the Directive to identify:

the measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plan or programme;

The adoption of plan is only part of the SEA process which then requires under Article 10 ongoing implementation action to:

"monitor the significant environmental effects of the implementation” of the plan “in order, inter alia, to identify at an early stage unforeseen adverse effects, and to be able to undertake appropriate remedial action”

Failure to carry out an effective SEA and put adequate monitoring and remedial action in place would expose Ireland to legal action at national and EU level.

The proposed programme also needs to address the interrelationship of bovine agricultural expansion with nitrous oxide as well as methane emissions, as well as climate vulnerability and fodder supply, having regard to the provisions of Section 15 of the Climate Action and Low Carbon Development Act 2015

Full submission: