In May 2016, the Commission launched the Environmental Implementation Review (EIR), an analysis over a period of two years aimed at improving the implementation of existing EU environmental policy and legislation. As a first step, the Commission drafted reports on the 28 member states, in order to identify environmental challenges and opportunities. The aim in producing these reports has been to bring about communication over common environmental challenges within the EU and also the best ways to address major issues in implementation. These reports were published in February this year, accompanying the EU Commission’s Communication, ‘The EU Environmental Implementation Review 2016: Common challenges and how to combine efforts to deliver better results’.

Main challenges for Ireland

The main challenges that have been highlighted with regard to implementation are:

• The need to complete the Natura 2000 designation process, with clearly defined conservation objectives, for terrestrial and marine sites.
• Protecting the raised and blanket bogs remains a significant challenge.
• Maintaining the important investments required for water services, given the urgent need to invest in water infrastructure.

According to the report, Ireland could perform better on issues where a sound knowledge base and good practices already exist by:

• "Making better use of the significant potential in nature for tourism by better managing and protecting natural sites.”

The report also identified two main “Points of excellence” where Ireland has taken innovative approaches which could be mirrored by other member states;

• To comply with a ruling by the Court of Justice, Ireland implemented a major reform of its waste sector, closed illegal landfills and financed costly clean-up and remediation works.
• Ireland has taken a proactive approach towards managing complaints in the environmental sector, in cooperation with the Commission.”

Towards a circular economy

The report highlights the importance of the adoption of a National Strategy on Resource Efficiency in 2014. This refers to the EPA strategy, ‘Towards a resource efficient Ireland’, which aims to achieve the vision of ‘Living better, using less’.

According to the report, “Ireland is committed to achieving EU targets on reducing greenhouse gas emissions, increasing energy efficiency and renewable energy, increasing reuse, recovery and recycling of waste, improving water quality, and conservation."

The report also finds that major issues remain in relation to waste management, such as;

• the lack of households covered by door-to-door separate collection of waste and;
• the lack of financial incentives to encourage increased recycling and prevention of waste as opposed to relying on residual waste treatment.

Nature and biodiversity

The report acknowledges Ireland failure to complete the designation and set out clear conservation objectives and measures for Natura 2000 sites. Another obligation that must be fulfilled is the allocation of sufficient resources for implementation in order to achieve favourable conservation status across protected species and habitats under the Habitats and Birds Directives.

• The report gives the conservation status of SACs and SPAs as of data from 2013; with only 9% of the habitats’ status favourable, 50% unfavourable– inadequate and 41% unfavourable – bad.
• With regard to species, 52% had favourable assessments in 2013, 20% at unfavourable-inadequate and 10% unfavourable-bad status.

It notes the main pressures to habitats as unsuitable grazing levels (both under and over-grazing), pollution of freshwaters, drainage and cutting of peatlands and wetlands, invasive species and recreational pressures, including some building works. One major obstacle to achieving the objectives of the Nature Directives is identified as the lack of adequate ‘financial and human resources to support appropriate land management and conservation measures’.

While praising some examples of land management, such as in the Burren, the report highlights the lack of site specific conservation and management plans for Natura 2000 sites. It recommends better administrative capacity building, to also allow for stronger stakeholder engagement and notes that insufficient communication and awareness regarding Natura 2000 has also led to misunderstanding and mistrust. The Eurobarometer report for 2015 found that only 5% of people knew what Natura 2000 was.

The largest source of complaint to the Commission has been compliance with the Nature Directives, with the greatest concern relating to raised and blanket bogs. The report notes that despite a ban on turf-cutting in protected SAC raised bogs, illegal activities continue. Furthermore, the necessary steps to restore raised bogs have yet to be fully taken. It emphasises the need for a number of issues to be addressed;

• management of blanket bog and ‘assessing and ensuring the compatibility of turf cutting’ in these areas
• finalise the draft National Peatlands strategy and National Raised Bog SAC Management Plan
• the decline of waders, particularly the Curlew within and outside Natura sites
• reconciling the protection of the Hen Harrier with forestry and wind farm development,
• avoiding the cutting of hedgerows as well as burning in the uplands during the nesting season of birds.

Marine environment

With regard to implementing the Marine Strategy Framework Directive, many of Ireland’s environmental descriptors (explaining what the environment will look like when Good Environmental Status has been achieved), still need to be more clearly defined, more specific and measurable. The report recommends improving these, addressing knowledge gaps, better assessment and reporting of main pressures and impacts to marine areas as well as better monitoring of programmes and methods for marine protection.
Water quality and management With regard to water quality, Ireland has a number of failings, particularly regarding surface waters;

• 56 % are affected by diffuse sources of pollution,
• 49 % by point sources of pollution,
• 24 % by river management,
• 9 % by abstraction,
• 8 % by flow regulation and morphological changes.

While the level of nitrates from agricultural sources decreased from 2008 to 2011, agriculture is still identified as ‘a significant pressure’. The ‘challenge’ posed by further agricultural intensification, (set out in FoodHarvest 2020), particularly in relation to 50% increase in milk yields is also acknowledged. Drinking water quality is identified generally as meeting high standards within the Drinking Water Directive, and 73.7% of bathing waters said to be of excellent quality. However, it also draws attention to problems, such as the presence of trialomethanes in water supply areas and implementation issues in relation to urban waste water, noting that in 47 of 170 agglomerations of wastewater, secondary treatment is not ensured, resulting in direct discharge of untreated wastewater.

Environmental taxation

The report commends Ireland’s introduction of ‘Green Tenders’, an Action Plan on Green Public Procurement, introduced by the department of the Environment, Community and Local Government in 2012.
The Commission had previously recommended the introduction of taxation on CO2 content of energy products for non- ETS sectors and efforts to strengthen local government financing through property tax and waste water charges. This report noted that these steps were taking place, noting that revenue from environmental taxes was 2.43% of GDP, just under the EU28 average, but that it also accounted for 8.17% of total revenues from taxes and social-security contributions (compared with EU28 average 6.35%). The report notes the potential negative environmental impacts of the current reduction of motor tax on commercial vehicles. It also highlighted that peat for electricity is exempt from carbon tax while still being subsidised, also pointing out that
“Reduced value-added tax rates on energy products (at 13.5%) also conflict with overall energy and climate policy objectives as the decree the incentive to reduce energy consumption or improve energy efficiency.”

Air pollution

Air quality is noted as generally good, but with exceptions and with estimated health related external costs of air pollution above €2 billion per year, (2010). This also translates in direct economic costs to “382 thousand workdays lost each year due to sickness related to air pollution”. “With associated costs for employers of EUR 65 million/year (income adjusted, 2010), for healthcare of above EUR 5 million/year (income adjusted, 2010), and for agriculture (crop losses) of EUR 30 million/year (2010)”.

Effective governance and knowledge

According to the 2013 European Quality of Government Index, Ireland ranks 10th out of the 28 Member States. The report mentions Ireland’s more recent efforts to reduce infringements of environmental law, implement court judgements and to improve “coordination and consistency amongst its local authorities and other compliance assurance authorities”, but also points out Ireland’s shortcomings in relation to the INSPIRE Directive in terms of disseminating environmental information to the public.

Room to improve? The Report in Context

The report has shown that while Ireland has in some areas demonstrated 'Points of Excellence', there are areas which there is vast room for improvement. For example, Ireland is commended on its commitment to "achieving EU targets on reducing greenhouse gas emissions, increasing energy efficiency and renewable energy, increasing reuse, recovery and recycling of waste, improving water quality, and conservation." However, this is not reflected in the reality on the ground, considering that we are due to miss our 2020 carbon emissions reduction targets and in light of the recently published Draft National Mitigation Plan (NMP), which is in the view of An Taisce, unambitious and 'too little too late'. [Read the press release for An Taisce's views on the Draft Plan - http://www.antaisce.org/articles/too-little-far-too-late-national-mitigation-plan-an-unmitigated-failure].

For policies and laws drawn up with the best intentions for improving the state of our environment are only as effective so far as they are implemented. Significant changes have been identified, but more needs to be done to keep environmental protection and sustainability moving in the right direction.

For more in-depth information, take a look at;

Detailed country report on Ireland – http://ec.europa.eu/environment/eir/pdf/report_ie_en.pdf;

Report factsheet – http://ec.europa.eu/environment/eir/pdf/factsheet_ie_en.pdf