Contact: Ms Leni Hurley
INTRODUCTION
Since Ireland joined the EU, Irish agriculture has been dictated by the Common Agricultural Policy. This has involved the transfer of large sums of EU taxpayers money into a system of farming which has grown increasingly intensive, and which has led to severe environmental degradation across the EU. Intensive agricultural enterprises contribute to eutrophication of surface and ground-waters, bacteriological contamination of drinking water supplies, soil erosion, global warming, acidification and loss of habitat. The combined effect of these processes is the loss of biodiversity, including genetic diversity in the rural area. The loss of biodiversity and genetic diversity at farm level is neither recognised nor tackled in this country, though it is of major concerned in the EU and beyond.
The CAP reform package of 1999 has led to a relatively favourable outcome for Irish farmers. Department of Agriculture figures state that in the period 2000-2006, the final agreement will deliver a substantial total gain of £395 million in farm income. The national gain over the period will be even greater, £666 million, because of the additional benefits to consumers and others from lower product prices.
However, these figures exclude the costs of the research and development and the implementation of measures to counteract the environmental degradation that results from the farming sector. These costs (as well as the farm supports themselves) are born by the consumer, in the form of taxes. The widely held view that the polluter must be responsible for the environmental degradation s/he causes does not seem to apply to the farming community. The EU, Government Department such as the Department for the Environment and the EPA, and Local Authorities are the main forces behind the research and implementation, however minimal, of environmental standards in agriculture. The very fact that every Irish (and EU) citizen pays both for farm income support and for the pollution engendered by the farming sector, gives consumer-, animal welfare- and environmental groups, as well as private citizens a right to an input in the decision-making process.
It must also be born in mind that, if it was left to the Irish Government and farming community, no environmental measures would be taken at all. Every single environmental initiative affecting Irish agriculture originates 'from above', from the joint decision-making process in the EU. (Note that it does not originate from within the Common Agricultural Policy either, although the Rural Development policy and the agri-environment Regulation are now part of the CAP!)
Under the latest CAP reform, three-quarter of the taxpayer's money continues to go into farm support payments which continue to add to environmental degradation. When one considers that about 50% of all European land is used by farming, and over 75% in Ireland, one can see that farming has a tremendous impact on the landscape. In Ireland, the noises coming from the agriculture sector tend to be: "Sheep Farmers Let Down", "Pig Farmers on the Brink". We never hear: "The Environment Destroyed" or "Animals Mistreated". We are not concerned enough in this country. This is not the case across the EU. In Austria organic farming and integrated farming are encouraged by important financial aid. Likewise, extensive exploitation of mountain meadows and the conservation of landscapes and threatened species are supported by subsidies to farmers. Outside the EU, the Swiss have chosen a different route also. Let's take a look at the Swiss example.
CHANGES IN SWISS AGRICULTURAL POLICY
PUBLIC OPINION MADE THE CHANGE
Agricultural policy in Switzerland has undergone radical changes in the past five years. Before 1993 Swiss farmers were supported by maintaining artificially high prices for agricultural products. This policy meant that high yields per hectare were rewarded as well as environmentally destructive production methods. Swiss environmental organizations actively protested against this policy. In 1993 the Swiss government started to restructure the agricultural policy towards more ecological sustainability. The Swiss system of direct democracy is responsible for the radical changes. The Swiss population had to vote twice for an amendment of the constitution that concerned the future of agricultural policy. The basis for the two referenda that were held in 1995 and 1996 was a proposal for a constitutional amendment for which 100,000 signatures were collected. The initiative for this amendment was taken by a broad coalition of environmental, animal and consumer protection groups, as well as organic farming organizations. With an overwhelming majority of over 70% the Swiss population voted for the constitutional amendment. With their vote they clearly expressed that farmers could no longer be supported with tax money at the expense of the environment. Instead, public funds have to be channeled to the development of organic farming, measures that protect species diversity and animal friendly farming systems. Where and how food is produced must be labeled. The Swiss people want to know what it is that they eat.
FARMERS RECEIVE PAYMENTS ONLY UNDER STRICT ECOLOGICAL CONDITIONS
As soon as the constitution was changed the Swiss government introduced cross compliance. Direct payments to farmers is given only under strict environmental conditions. Swiss farmers have to prove that they do not pollute the environment beyond the minimum norms set by the government. The norms are called "ecological standards of performance". If farmers pollute in excess of the standard, direct payments are reduced or cut off entirely. In 1998 over 80% of the farms were able to comply with the ecological standard, and the number is increasing. The Federal Office for Agriculture expects that within three years over 95% of the farms will comply.
THE ECOLOGICAL STANDARD OF PERFORMANCE
Farmers are required to keep records of their environmental performance in order to prove that they comply with the ecological standard of performance. The records of each farm are controlled by a cantonal control agency ones a year. Farmers have to:
For each crop the maximum allotment of the total arable land per farm is determined. Thereby mono cultures of corn and grain are not permitted.
Moreover, the Federal Council developed incentives to encourage farmers to undertake ecological measures that go further than the ecological standard of performance. For example, farmers producing organically or who are in conversion to organic agriculture receive higher subsidies per hectare. Farmers maintaining unfertilized meadows, hedgerows or orchards are compensated for the income loss.
EFFECTIVE POLICY
The process of policy reforms is not yet finished. New policy measures need to be improved in a number of areas. However, preliminary results show that the new policies are on the right track because pressure on the environment has been reduced substantially. Pesticide application has decreased by 23% since the period of 1989-91. The use of phosphates decreased from 83 to 73 kg per hectare. The purchase of phosphorous fertilizers decreased by over 60%. The total use of chemical fertilizers is below that of the period 1946-1950. In 1998 the number of organic farms increased to 5000 which is about 8% of all farms, compared to less than 2% in 1993. The increase in organic area was followed by an increasing demand for organic products. With federal support consumer prices of organic products were reduced, and all the large retail-chains have introduced organic products in the stores.
Despite the reduction of pesticides there have been no reductions in the average yield per surface. This raises the question why farmers have been losing money with the excessive use of inputs. Beat Jans, Pro Natura, Switzerland
FEARS FOR LOSS OF MARKETS - MISGUIDED.
The Swiss example shows that respecting the environment can go hand-in-hand with commercial success. It appears that EU fears concerning loss of markets and competitiveness continually dilute and belittle the very grave consequences of the European Community model of intensive farming. We know that the intensive livestock and tillage sectors are largely responsible for environmental degradation. We are also becoming aware that the perceived 'green image' of Ireland no longer stands up to consumer scrutiny. In fact, the overwhelming consumer trend in Europe is towards organic produce. People are rightly concerned about their own health, and about the welfare of farm animals. People question the use of pesticides and herbicides. They question intensive farming practices, particularly in the pig and poultry sectors. Meanwhile, the export of live trade is of increasing concern to citizens around the world, not just in the EU. Claims by the farming community, such as the outrageous claims made by the Agri Awareness Centre in its public information leaflet: "EU direct Payments", about the intrinsically environment - and animal friendly farming systems in Ireland sound very hollow indeed. These may be aspirations, they are not the reality on the ground.
ENVIRONMENTAL ISSUES
SUSTAINABLE DEVELOPMENT - A STRATEGY
FOR IRELAND, GOVERNMENT OF IRELAND, 1997.
In it's Action Programme towards Sustainable Agriculture, the government acknowledges that agricultural activity must be undertaken in an environmentally sustainable manner, if it is to be economically viable in the long-term. It notes that:
"The Department of Agriculture and Food will produce comprehensive guidance and advice on agricultural practices for the purpose of protecting all environmental media - the ecosystems they support, and promoting sustainable agriculture."
However, how can the Department deliver on such promises, particularly in the area of biodiversity and habitat protection, but also in the physical protection of ecosystems, when it lacks the necessary ecological expertise? All Department officials are agriculturalists.
And where is the input from this Department, when in a major new study on the impact of farming practices on the environment, the EU commission finds that overcrowding is a major problem on Irish pig farms and that the large number of pigs per hectare may have a high impact on the environment. "Air and soil especially need constant protection against the negative influences of intensification." The report finds that, in 1995, cow manure was responsible for placing over 100 kg of nitrogen in each ha of Irish soil, the third highest rate in the EU.
Unless the Department establishes a unit of expertise, including ecological and nature conservation expertise, in its headquarters, it is unlikely that leadership of the kind indicated in the Government's Action Programme towards Sustainable Agriculture can be expected from the Department of Agriculture, Food and Rural Development.
LOSS OF HABITAT AND BIODIVERSITY.
Across Europe there is growing concern about the loss of habitat and biodiversity. This must be of interest to the tourist and amenity sector. Visitors and walkers are becoming increasingly discerning. They want to see a diversity of ground cover, insects, butterflies and birds, rather than denuded hillsides carpeted with sheep dung and hung with the occasional dead sheep (a sure sign of large flocks funded by the EU and not regularly checked by the farmer) netted in wire fencing, or the abundance of nitrogen-loving nettles bordering fields and streams.
ABSENCE OF ECOLOGICAL LITERACY & UNDERSTANDING.
The problem in Ireland really is one of a lack of ecological literacy. Third level degree graduates in Environmental Resource Management appear to lack the basic ABC of ecology. How can people be expected to 'manage' environmental resources, when they do not understand how these resources function? School-children are not taught the basic ecological processes of life. These processes have been made systematically child-friendly by the Institute for Earth Education in primary schools programmes such as Sunship Earth and Earthkeepers. In Sunship Earth, children use a mnemonic device: EC-DC-IC-A to memorise the ecological principles of Energy Flow, Cycling (of the building materials of life in water, air and soil), Diversity, Community, Interrelationships, Change and Adaptation. A Field Ecology diploma course in UCC is the only course in Ireland where such knowledge is specifically elaborated. Ecology looks at the interaction between the non-living, physical and the living, biotic aspects of ecosystems and communities of life. The science of ecology teaches us, for example, that populations of species isolated in small areas (say an NHAs) surrounded by cultivated land are not viable. We then begin to understand why buffer zones and green corridors are needed. Ecological infrastructures, including buffer zones and ecological corridors, are being incorporated in some member states, but not in Ireland. Meanwhile, ecology remains a hazy subject, and words like 'sustainability' and 'biodiversity' misunderstood, even though they are bandied about with great fervour.
Thus it may do well to quote from the horse's mouth, that is, from the Council of Europe's booklet: Questions and Answers: Agriculture & Biodiversity, and from Ritt Bjerregaard, the EU's Commissioner for the Environment (Newsletter, March 1999, Brussels).
AGRICULTURE & BIODIVERSITY - QUESTIONS AND ANSWERS, COUNCIL OF EUROPE:
Many reasons underpin biodiversity conservation in farming activities.
Biodiversity represents a gene4 bank: wild ecotypes* of cultivated species may have advantageous features such as resistance to disease, drought or cold, or a certain tendency to fruit or ripen early. In the foreseeable future, advances in genetic engineering will certainly usher in the use of the genes of each wild species to improve cultivated species.
When we speak of 'agricultural biodiversity', we speak of two aspects, namely (1) the diversity of wild species naturally appearing in farmland, and (2) the diversity of domestic species, i.e. species and varieties of cultivated plants, and species and breeds of reared animals, as well as their forebears and related wild taxons (any unit of classification for living beings: family, genus, species, sub-species, variety, and so on), even if these latter do not occur in farmed areas.
THE DIVERSITY OF DOMESTIC SPECIES
Prior to the period of agricultural intensification, many parts of Europe had, for example, their own breeds of cattle, sheep and poultry. These were adapted to the particular environmental conditions and local livestock-rearing systems. Today, most of these breeds are threatened with extinction because they are being replaced by a small number of more productive breeds. The fact is that these old breeds represent an inestimable genetic potential, which we may well need in the future. The same situation applies to cultivated varieties, particularly where fruit and vegetable are concerned.
THE DIVERSITY OF WILD SPECIES NATURALLY APPEARING IN FARMLAND
Many habitats have been destroyed by the modernisation of farming techniques. Yet woods, hedges and wetlands play a crucial part in the survival of many species such as nightingale, snipe, hedgehog, dragonflies or wetland vegetation. In intensively farmed regions isolated trees have been felled, hedgerows destroyed, land parcels enlarged, areas levelled, land drained, ponds filled in, and so on.
EFFECTS OF HERBICIDE APPLICATIONS ON BIODIVERSITY
In cultivated fields, the use of herbicides has helped to do away with most populations of commensals (a species that is associated with and depends on another species) associated with crops. Consequently, cereal weeds - such as cornflower, corn cockle, larkspur and Venus's looking-glass - have become very rare.
EFFECTS OF INSECTICIDE APPLICATIONS ON BIODIVERSITY
Insecticides used on crops have destroyed not only insect pests, but a large part of the remaining microfauna too. This has reduced the food supplies for animals feeding on this fauna, such as skylarks, partridges and other ground-nesting birds.
PESTICIDES
Pesticides have often been criticised for their adverse affects on fauna, and on people too, for that matter. Some pesticides are also responsible for the poisoning of fauna causing death, abortions, embryo malformation, and lower vitality. Their toxicity does however vary a great deal from product to product. Research carried out by phyto-pharmaceutical companies has helped to market less and less harmful molecules. But much remains to be done in this respect. (EU pesticide use increased by 6 per cent since 1995! Ref: Europnews@poce.cec.be)
GRASSLAND FERTILISERS
In grassland, fertilisers have encouraged productive species - grasses in the main - which have supplanted slower-growing species. So out of the 50 plant species living on 100m² of extensive haymeadow, only 10 to 20 are now to be found in intensively farmed grassland. The disappearance of plants goes hand in hand with that of the insects associated with them, some butterflies, for example. Much grassland, which is unproductive but species rich, has been ploughed up to introduce crops - maize in particular - or re-sow artificial grassland.
GRASSLANDS MANAGEMENT
Changed methods also affect the survival of species. Let us use two examples:
ECOLOGICAL INFRASTRUCTURE
In order to encourage biodiversity in agricultural areas, it is beneficial to retain or rebuild an ecological infrastructure on the edges of land plots and in specific areas where farm production is restricted for various reasons. This infrastructure consists of a network of linear features and isolated features:
These two types of factors may have both a habitat function where organisms can feed, reproduce and live, as well as a dispersal function which helps organisms to move about and colonise new areas.
ECOLOGICAL CORRIDORS Not all species have the same needs when it comes to dispersal. Some, like ground beetles, toads, daffodils or bluebells require continuous corridors. A gap of just a few metres is enough to halt their progression. Other species, like the roe deer, many birds and certain plants may move from one site to the next even if the corridor is interrupted over several hundred metres. The aim, nevertheless, is to form a sufficiently tight mesh. This mesh or grid might amount to, say, 5% of farmland. The ecological infrastructure can be developed as a priority on thin soils, sloping land or forest verges and areas that are too wet or too dry for cultivation. It is not a question, here, of encouraging wildlife within agricultural areas, except in regions where extensive farming is possible, such as high mountain pastures and hay producing upland grassland, which may combine the functions of farm production and biodiversity conservation.
RITT BJERREGAARD, EU COMMISSIONER FOR THE ENVIRONMENT
The concern for environmental degradation and loss of biodiversity is clearly expressed in a Newsletter from Ritt Bjerregaard, the EU's Commissioner for the Environment, Brussels, back in March 1999, before the final CAP reforms were agreed. Although her aspirations for a closer interlinking of environmental and agricultural policy have not materialised in the CAP agreement, this letter, nevertheless, indicates the seriousness with which the situation is regarded in Europe:
"For far too many years agricultural policy and environment policy have lived their separate lives. This means that lakes and water courses, groundwater and drinking water have been polluted by the excessive use of toxic sprays and artificial fertilisers. Animals and birds have been deprived of their habitats and agricultural land has been exhausted.
Many parts of Community legislation have a significant impact on environmental pollution by agriculture. The nitrates directive is a well-known example, but there is also legislation on toxic sprays, genetically-modified organisms and consumer protection - all of which is helping to reduce environmental pollution in that area.
Admittedly all of this is not quite enough. Thus in late January the Commission member for agriculture, Franz Fischler and I issued a communication on how the environment is to be incorporated into agricultural policy. The desire for greater interaction between agricultural and environmental policy is a further development of the view expressed by the Commission in its proposal for Agenda 2000, which at the time of writing is being discussed by the EU's agriculture ministers. That communication gave practical form to how a reform can be brought about that is so green that environmental protection and agriculture are interlinked.
Much more than now agricultural policy will help us to achieve our environment-policy aims - instead of undermining them. This is because agriculture is a decisive factor if we wish to achieve our aims regarding good water quality, biodiversity and clean air - and also if we wish to persist in our desire to secure Europe's nature and resources for the future.
First of all the guaranteed minimum prices for beef, cereals and milk will fall. The advantage for the environment is that the excessive consumption of artificial fertilisers, (pesticide) sprays and energy can no longer be worth the effort. Then we will make the support for farmers in the Member States depend upon their compliance with environmental law. This will provide a far greater incentive for having the necessary EU rules I mentioned earlier implemented.
Thirdly, there will be more support for farmers that pay more attention to environmental protection. I have, in this connection, advocated that EU assistance to ecological farmers should be increased by a further 10% - a very firm indicator that we are being serious when we say that environmental aspects are to form part of agricultural policy.
The Member States will then give particular support to more environmentally friendly forms of dairy farming. More of the money given will provide support for pasturage and not for numbers of animals, which is currently the case. This will mean less pressure on sensitive soil.
My final point is that we are drawing up an action plan as to how European agriculture will be able to ensure the survival of nature's many-sidedness: biodiversity. This is because analyses have shown that intensive agriculture and forestry are in part responsible for wiping out species.
I think that the declaration on the combining of agricultural and environment policies is a signal to the public, and to green organisations and taxpayers who want a cleaner environment in return for the EUR 40,000 million that they hand out to farmers every year."
THE WAY FORWARD
If we are to take the environmental consequences of our present agricultural policy and our commitment to international agreements such as the Rio Earth Summit, the Convention on Biological Diversity and the Kyoto Protocol on the reduction of greenhouse gasses serious, and if we are to pay heed to consumer trends, we need to act accordingly. The effects of global warming, eutrophication, soil erosion, loss of habitat and biodiversity and acidification are not inconsiderable, and will undermine, more than just agriculture. Combined with the effects of urban and industrial pollutants, they contribute to the absence of a viable future for everyone in the foreseeable future. This is recognised in the Government's Action Programme towards Sustainable Agriculture (ref: Sustainable Development Strategy, Government of Ireland, 1997) when discussing the amount of animal waste produced in this country (equivalent to about 68 million people, according to the EPA) by stating that:
"Apart from the immediate impact on the local environment and its resources, the long-term damage and destruction involved could also have serious implications for the wider economy and society."
We need to formulate and agricultural policy which makes its very real contribution towards a viable future. That contribution does not lie in words, but in decisions and their implementation. It is important to incorporate the principles of ecological resource management into farming. Actions have to be undertaken at the outset and not merely attempt to rectify the adverse effects of these areas of activity after the fact.
THE RURAL ENVIRONMENT PROTECTION SCHEME (REPS)
Before proceeding to our recommendations, we need to look at the REPS. It was introduced in 1994 under the agri-environment Council Regulation No (EEC) 2078/92 of 30 June 1992. This Regulation concerns "agricultural production methods compatible with the requirements of the protection of the environment and the maintenance of the countryside". The REPS objectives are:
However, a number of submission to the Department of Agriculture from environmental NGOs, the Heritage Council, and our own submission (to be published in September 1999) have highlighted the fact that the REPS is negatively affected by a number of drawbacks, primarily the lack of sufficient and targeted environmental expertise. There is no ecological and nature conservation unit within the Department of Agriculture, Food and Rural Development to oversee the implementation of agri-environment measures. 'Ninety-nine point-nine' per cent (*) of inspectors, and 70% of planning agents are agricultural scientists. (*In fact, and in spite of the huge increase in participating REPS farmers, there are still only 6 Department Inspectors.)
This lack of expertise from the top down means that non-compliance with the nature conservation measures of the Scheme on farms outside designated Degraded Areas (seriously overgrazed commonages) and areas of outstanding conservation value (NHAs/SACs/SPAs) tends to be widespread. Due to the absence of environmental monitoring and evaluation procedures, evidence of abuse tends to be anecdotal. It tends to be spotted by members of the public and environmental NGOs (ref: REPS Discussion Document, Earthwatch, Friends of the Earth Ireland). Non-compliance is the natural outcome, rather than a matter of widespread fraud, of a Scheme that lacks sufficient targeted expertise in all but the most obvious environmentally sensitive areas.
The problem of an expertise-deficit is deep-rooted. Third Level Institutions deliver 'agricultural experts/scientists' (terms used by the Department of Agriculture) who are trained to increase production at the cost of environmental degradation. Unfortunately, universities also deliver 'environmentalist experts/scientists' who lack basic field skills. Environmental Resource Management degree courses tend to focus on the physical, abiotic side of the environmental, such as water-, air-, and soil-quality and management. This physical emphasis goes at the expense of sufficient field-practice in the biotic, living aspects of the environment and ecosystems. Habitat identification and management skills, therefore, tend to be under-represented amongst REPS planners outside the 'sensitive areas' Third-level degree courses in Ecology, moreover, are absent in this country. Ecologists study both the physical and the living aspects of ecosystems, and the interaction between them.
The Scheme suffers, moreover, under the absence of scientific monitoring and evaluation procedures and programmes, and from the structured recording of baseline data which are the prerequisite of monitoring and evaluation programmes.
Lastly, there is a lack of ongoing, mandatory training for farmers. Very few farmers actually undertake the 20-hour REPS course. This further prohibits the Scheme from achieving its nature conservation objectives.
REPS NO INCOME SUBSIDY
" A key principle of our current policy is that the agri-environment measures must not become, nor be perceived as, income subsidies. They should remain measures designed to deliver environmental benefits beyond a reference level, such as good farming practice in the region concerned." Frank Fay, REPS Conference Proceedings, Protecting Ireland's National Heritage, Johnstown Castle, December 1998.
Underlying these draw-backs is a problem of perception. The REPS is seen as an income subsidy, first and foremost. This is illustrated, amongst many other examples, by the following two statements. The first was made by Tom Parlon, IFA, at the REPS Conference Proceedings, Johnstown Castle, 3 December 1998; the second by Michael Cullinane, deputy CEO, Teagasc with responsibility for REPS, Farmers Journal, 12 December 1998:
"With farm incomes going through a very difficult phase at the moment, farmers are seeking every avenue by which to improve their incomes. The REPS Scheme is one of those measures and recent Teagasc National Farm Survey figures point to the scheme playing a significant role in supporting farm incomes." (Tom Parlon)
"Originally REPS was cream on top for dry stock farmers, now it is part of their bread and butter". And: "in relation to REPS, if you get the farmyard right then you are 90 percent there." (Michael Cullinane)
Very few people perceive the REPS for what it is, namely an agri-environment protection and restoration scheme. Instead it is seen as an income subsidy first, and 'to tidy up the farmyard' second.
In his paper to the REPS Conference at Johnstown Castle, 3 December 1998, Mr. Fay refers to the large number of discussions on agri-environment policy taking place, notably in the OECD, particularly the conclusions of a seminar in Helsinki in 1996. At this seminar, several important elements of EU policy were endorsed, including the fact (agreed by all delegates) that farmers should only be paid for the provision of environmental services where the farming activities go beyond a reference level, such as that of a baseline of good agricultural practice in the region concerned. However, many of the elements of the basic REPS consists of just that: measures toward good agricultural practice. Outside of the REPS, moreover, codes of good agricultural practice are voluntary. Research has shown that very few large farmers are aware even, of these codes (ref: Impact of Agriculture Schemes and Payments on Aspects of Ireland's Heritage, a report for the Heritage Council, June 1998).
Moreover, there is a tendency amongst REPS planners, inspectors and farmers to focus on these code of good practice, at the cost of the nature conservation measures. This is due largely through the lack of sufficient ecological expertise outside of the designated Degraded Commonages and the NHAs/SACs/SPAs.
The fact that the REPS financially supports farmers to protect and restore the environment is a positive development. Indeed, efforts must be made to ensure that the drop in EU structural transfers will not affect funding rates for the REPS. However, income support can only be regarded as a positive aspect of the Scheme so long as the environmental remit of this Scheme, such as sufficient professional expertise, baseline biodiversity data at farm level, a centralised baseline data-base, biodiversity monitoring and evaluation procedures, and mandatory training for farmers are not neglected. In addition, a baseline reference of good agricultural practice needs to be formulated and become legally binding on all farmers outside of the REPS. The future REPS should focus on additional efforts made in terms of environmental protection and restoration. For the present, however, funding should be made available to enable farmers to carry out the necessary pollution control works, which are currently not funded under the REPS, but which are a requirement of the Scheme.
RECOMMENDATIONS
In the agricultural sector, measures to avert the risk of environmental catastrophe are manifold, and include the following:
ENVIRONMENTAL NGO PARTICIPATION IN THE FORMULATION OF AGRICULTURAL POLICY
ECO-AUDITING OF AGRICULTURAL POLICY
A MINIMUM STANDARD OF GOOD AGRICULTURAL PRACTICE
This minimum standard of good agricultural practice should be made legally binding on all farmers.
ENVIRONMENTAL CROSS-COMPLIANCE OR ECO-RESPONSIBILITY
As support payments decline, which they inevitably will, it will become increasingly important to provide incentive schemes for measures to enhance the environment. To this end, we would like priority given to the following:
GREENHOUSE GAS ABATEMENT
Good Practice Methods should be incorporated in the minimum standard of good agricultural practice. Where technical pollution abatement measures are insufficient to achieve the desired goal of emission reductions, a reduction in livestock numbers must be considered and be made obligatory in areas of overcapacity. Compensatory payments should be made in such cases.
ACIDIFICATION: AMMONIA
As detailed in Chapter 5 of the EPA Water Quality Report on the quality of groundwaters, there were 10 sampling stations where the mean ammonia concentration was greater than the maximum allowable 0.23 mg/l N. In addition there were 8 stations where the concentration in a single sample was greater that the threshold of 0.23 mg/l N. Several of these waters are used for domestic purposes, and for drinking water.
The greater problem with ammonia, however, is its effect on the environment. Ammonia is produced from the breakdown of urea, a substance in the urine of pigs and cattle. When released into the atmosphere, it returns to the ground in the form of acid rain. A great deal of the groundwork regarding research has been carried out in other countries, where the problem has been much more acute. Thus, the new proposed Air qulity directive gives a clear picture of the effects acid depositions. Acid rain damages buildings and cultural monuments. It reduces the alkalinity of lakes and streams, which can have both acute and chronic effects on biological populations. Part of the biological effect is due to the increased aluminium levels that accompany lowered pH levels. Reduction of forest soil pH and leaching of vital nutrients (base cations), lead respectively to reduced root distribution and nutrient deficiencies, which in turn make forests vulnerable to drought, disease and insect attack. Acid groundwater causes severe corrosion damage to drinking water supply systems, while dissolved metals (aluminium, cadmium, copper) may also pose a health hazard. Under the CLRTAP, an extensive ammonia monitoring network has recently been established in Ireland, and research into concentration levels will improve our understanding of deposition and critical loads exceedances and their associated risks in this country. To this must be added the risks of cross-border pollution and the effects on the marine environment.
Based on this research, Good Practice measures must be incorporated in the minimum standard of good agricultural practice. Where technical pollution abatement measures cannot prevent exceedances (this has been the experience, for example in The Netherlands), a reduction in livestock numbers must be considered and be made obligatory in areas of over-capacity. Compensatory payments should be made in such cases.
NITROGEN
As with all agricultural emissions, those of nitrogen must not be under-estimated. In spite of some 50 years of cancer research, very little is known about the causative factors. Some work on nitrogen and cancer has been carried out, and there is no harm in quoting extracts from a communication from Brigitte Pignatelli, Ph.D, D.Sc. Unit of Endogenous Cancer Risk Factors, International Agency for Research on Cancer, Lyons, France:
"The two main risks associated with nitrate for human health are methemoglobinemia and the carcinogenicity of N-nitroso compounds that stem from nitrate. Methemoglobinemia results from the acute toxicity exerted by nitrite causing the inability of blood to transport oxygen. The risk of methemoglobinemia in healthy adults is limited, but the risk to infants is higher and can lead to death. In most reported cases, infants were exposed to water containing high levels of nitrate associated with either microbial contamination of water or gastroduodenal infection.
In terms of the carcinogenic risk, nitrate has been suggested to be involved in the cancer of the stomach, urinary bladder and colon. Nitrate in drinking water should be more hazardous than in vegetables. Its levels in our dietary items and drinking water depends on many factors, but particularly on inappropriate agricultural practice, pollution from animal wastes in industrial farming and food processing. The abusive use of nitrogen fertilisers leads to an increase of nitrate concentration in vegetables. Further studies are required." It is obvious that this research will not be funded by the farming community!
Strangely, livestock can ingest water containing up to 450 mg/l nitrate. This seems entirely inappropriate and requires further examination. After all, we consume the livestock.
Under natural conditions, nitrate is present only in low concentrations - normally in the 5-9 mg/l of nitrate. In the recently launched EPA publication Water Quality in Ireland 1995-1997, elevated nitrate values (ie with a mean nitrate concentration greater than the 50 mg/l NO3), were found in Carlow, Kildare, Limerick and Louth. No measures have yet been taken to address this problem, though under Council Directive 91/676/EEC of 12 December 1991, legally binding measures have to be taken where concentration levels exceed the 50 mg/l ceiling.
In all of this we must not oversee the fact that standard water treatment does not remove nitrate!
Excess nitrogen also leads to soil eutrophication. Where-ever we see an abundance of common grasses and nettles bordering on fields and waterways, we may be sure that an excess of nitrogen applications has led to the destruction of plant community composition and biodiversity. The integrity of many of the plant communities that are protected in nature reserves is dependent on low soil nitrogen availability. As indicated under Acidification, above, nitrogen inputs into forest soils have been linked to forest decline. Thus, nitrogen inputs and ammonia emissions affect, not only our agricultural land, but also our forests and forest plantations, and our protected areas (NHAs, etc.)
There are moves underway to raise the permissible limit of organic and chemical nitrogen in the REPS. This move has been inspired by the Intensive Agricultural Enterprises sector (IAEs), particularly the pig sector. (The pig sector actually proposed to introduce a £10 per acre supplementary measure in REPS to encourage farmers to take in pig slurry.) As a result of such pressure, the nitrogen application rules and penalties have been relaxed in the REPS terms and specifications of 1 January 1999. This will need to be reviewed, in light of the environmental arguments against such a development.
In fact, in their report on the Limitation and Reduction of CO2 and Other Greenhouse Gas Emissions in Ireland, the Department of the Environment and Local Government and the Department of Public Enterprise recommend that further incentives could be given for reducing nitrate use through the use of a tax. Such tax should be aimed at reducing over use.
WATER QUALITY AND EUTROPHICATION
Achieving significant water quality improvements is not going to be easy. The most meaningful initiatives undertaken thus far fall under the REPS. However, the Lough Derg and Lough Ree catchment management initiatives have shown that, when the uptake of REPS in the area was considered it emerged that significant uptake (40 per cent) did not correspond with the area of greatest need. Recommendations regarding the effectiveness of farm surveys indicated that these are useful in terms of raising awareness and providing information. Resources are needed to fund the surveys and to support any remedial measures needed. Research into pollution with other toxic substances and heavy metals needs to be stepped up. Bacteriological contamination of water supplies is unacceptable and needs remedial action immediately.
Other measures include:
ANIMAL WELFARE
Animal welfare needs to be improved as a matter of urgency. This applies particularly to the pig and poultry sector. A major new European Commission study on the impact of farming practises on the environment warns that overcrowding is a major problem on Irish pig farms. They tend to have more than 500 swine each, over five times higher than the EU average. Problems in the pig sector should not be used as an excuse to avoid acting on animal welfare issues.
The live transport of farm animals also needs to be reviewed. The shipment of animals inside transport trucks, in particular, needs immediate corrective action. This is a matter of morality over expediency.
GENETIC ENGINEERING
We are concerned that our government is making trade-related interests the priority in how we develop policy for regulating and managing genetic engineering and GMOs. Biotechnology in agriculture is currently being promoted aggressively by corporate interests who also have a major influence on trade negotiations.
In fact, genetic engineering and GMOs raise many other important concerns for our society. We should manage them in light of their serious social, environmental, health and ethical implications. Choices about the direction of biotechnology and its use should be made with the full participation of civil society, taking into account all these concerns. All such decisions must be taken on the basis of the precautionary principle.
For instance, we are concerned about the impacts of genetic engineering and GMOs on human and animal health, and on biodiversity, genetic resources and other environmental values. We are also concerned about the socio-economic implications relating to food security, North/South equity, and displacement of farmers. We are concerned about the relationship of biotechnology to the concentration of corporate control over our system of production, distribution and consumption of food. And we are concerned about the ethical, environmental and social-economic issues raised by the expansion of intellectual property rights over life forms and agricultural biotechnologies.
PROPOSED NEW FARM HABITAT SCHEME OUTSIDE OR INSTEAD OF THE REPS
Less than 10% of Ireland has been identified as NHAs and their sub-sets, e.g. SACs and SPAs (Special Protection Areas). In the remaining 90% of the country, there are many habitats of local interest, which could benefit from positive environmental management or restoration by farmers. To that end we support the recommendation in the Report for the Heritage Council on the Impact of Agriculture Schemes and Payments on Aspects of Ireland's Heritage, 1998, (p. 247), for a new scheme, similar to the Countryside Stewardship Scheme operating in Britain, to provide an incentive for habitat management on those farms which are unsuited for the REPS, or where farmers do not wish to join it. These could include those more intensive farms which nevertheless may retain habitats of interest or which have scope for habitat creation and restoration.
Alternatively, if a mandatory baseline of good agricultural practice was established, the REPS could confine itself to habitat protection and restoration measures. (See below under Biodiversity: Maintenance of wildlife habitat on each farm, and Habitat restoration and ecological infrastructure, p.17.)
FARM FORESTRY
The mistakes made in the commercial farm forestry sector are symptomatic of a lack of vision and of strategic thinking and policy. The most blatant mistakes include the haphazard planting of tree species on totally unsuitable soils and the absence of planning for the transportation of timber from forests.
But the exclusion of principles of sustainability in a scramble for short term gain is. also highly regrettable. Irish forestry policy needs to adhere to international principles of sustainability and to include a greater proportion of broadleaf species.
10% RESERVE OPPORTUNITY
Many states including Brazil have agreed with the World Bank and the World Wildlife Fund to protect a 10% minimum of their forests for indigenous genetic reserves. The rest would also meet international SFM criteria. We can match this initiative in Ireland by careful application of the new "Native Woodland Scheme" particularly to the existing broadleaf estate.
HEADAGE FOR NATURE
Currently forest farming is considered as an income substitution measure rather than as a means to develop habitats and biodiversity. A financial scheme could be introduced to provide farmers with a "headage for nature" where they would receive equivalent grant aid to foster the development of habitats that would enhance the natural amenity of the farm. These habitats may provide the basis for future tourism opportunities as well as increasing the recreational quality of the land.
RENEWABLE ENERGY WIND ENERGY
The Irish wind energy potential is enormous and the rural development policies needs to look at a structural balanced of introduction of co-operatively owned wind projects in local areas. This form of local enterprise can secure a return for generations to come, firstly through providing local electricity needs and then by selling the surplus to the national grid. The Danish experience should be studied and a strategy formulated before outside investors have capitalised on the best available sites. Community participation in the selection of sites is essential and may be a means to avoid protracted bitter planning disputes. Obviously all projects need to incorporate the principles of sustainability with full regard for habitat consideration.
BIOMASS SHORT ROTATION COPPICE.
The cutting of willow, poplar and alder on short rotation for fuel in chip form is essentially linked to traditional coppice of a myriad of broadleaf species. The main difference is in the size of the wood fuel product produced and the monocultural nature of "biomass" versus the diverse species nature of most traditional coppice. To date industrial biomass has not been linked to the notion of traditional coppice as silvicultural systems. This leaves biomass in the realm of agriculture and Teagasc, whereas traditional coppice integrated alongside modern silvicultural systems may ( or may not ) be shortly reinstated into mainstream forestry and hence Forest Service funding. If the advocates of industrial wood biomass were to focus on their products as derivatives of forestry then their ability to draw down funding would be greatly increased. Creating links between the traditional and new short rotation forestry would strengthen both, generating new markets for the produce of each. E.g.: Alder for charcoal from either approach, Willow rods for basket making and thatching from either, fuelwood from either.
RECOMMENDATIONS II: BIODIVERSITY
On page 28 of Questions and Answers: Agriculture & Biodiversity, the Council of Europe expresses its commitment to biodiversity conservation, by stating that:
"Governments must incorporate biodiversity conservation into their national farming policies", and that "States must fund research into new solutions to ensure that biodiversity is given higher priority in efficient farming systems".
It specifically recommends training and awareness-raising programmes for farmers. And it declares the desirability of research at regional and local levels to do with the real effects on wildlife of measures taken.
A National Biodiversity Plan was scheduled to be completed by the end of 1997. (Government sustainable Development Strategy; Action Programme towards sustainable Agriculture). However, in 1999, no such Plan has, as yet, materialised. Obviously, any agriculture policy needs to push for the speedy publication of this Plan.
LOCAL BIODIVERSITY ACTION PLANS
Farming practices have a significant contribution to make to the conservation and enhancement of biodiversity, both directly on the farm and throughout the wider countryside. Government agriculture departments and agencies should give high priority to delivering their commitments under the future Biodiversity Action Plan and maintain their involvement in the Biodiversity Planning process at the Irish level. Local Biodiversity Action Plans should be implemented to provide the mechanism for all landowners and managers to become actively engaged in working to meet biodiversity targets. Such local Biodiversity Action Plans should include the restoration of past losses of habitats and species. They should be written to take account of both Irish priorities and local considerations.
Interest groups such as industry associations and NGOs should be associated in the development and implementation of the Action Plans. The development of the Action Plans normally will require a review of existing policies and instruments to determine how they affect species and ecosystems.
CROSS-COMPLIANCE AND BIODIVERSITY
In terms of biodiversity, cross-compliance will achieve significant environmental benefit throughout the farmed landscape without delay. This is crucial because the REPS, welcome though it is, can only help maintain and enhance a proportion of existing habitat features. However, a genuine reversal in the decline in biodiversity will only be achieved if all farms, and the total farmed landscape, are playing their part.
ECONOMIC AND SOCIAL INCENTIVES
Economic and social incentives such as subsidies, taxes and duties may have a considerable effect on biodiversity. These can include:
BIODIVERSITY RESEARCH
There is a need to fund research into new solutions to ensure that biodiversity is given higher priority in efficient farming systems.
GRASSLAND MANAGEMENT
The adoption of legislation to control the use of phyto-sanitary products or the late mowing of grassland are all actions favourable for biodiversity which should be adopted at the most appropriate level.
MAINTENANCE OF WILDLIFE HABITAT ON EACH FARM
Environmental conditions can reward the 'good' farmers who are already doing something positive for the environment on their farm. This can be achieved by introducing a requirement that every farm maintains a certain percentage of the farm as wildlife habitat. This would include hedges, ponds, field margins, woodland and other features. Farmers who have retained habitat on their farm would be rewarded, while others would have to create habitat in order to be eligible for support.
HABITAT RESTORATION AND ECOLOGICAL INFRASTRUCTURE
TRAINING AND AWARENESS RAISING
Training and awareness-raising programmes for farmers regarding landscape protection and biodiversity, to culminate in practical recommendations and a greater awareness on the part of farmers, resulting, for example, in an improvement of grassland biodiversity.
THIRD-LEVEL EDUCATION
Training and instruction at every level must be developed to achieve the economic goals by means of environment-friendly methods. All agricultural courses and degree courses should incorporate module on ecology: how do the ecological systems of life function, how are we tied into those systems, how do our practices affect them. They should also give sufficient outdoor time toward the development of habitat identification and basic field skills.
RECOMMENDATIONS III
LANDSCAPE DIVERSITY
Landscape diversity also needs closer attention. In this respect, Ireland needs to participate in and contribute to the Pan-European Biological and Landscape Diversity Strategy. Relevant findings and research under the auspices of the Irish Landscape Forum and the Heritage Council need to be incorporate in agricultural policy.
ORGANIC FARMING
There are considerable environmental benefits from organic farming: the absence of pesticide use allows plants and invertebrates to flourish and the mixed farming systems are likely to bring a more varied habitat and benefits for wildlife.
Other environmental benefits include the preservation and sympathetic management of landscape, the reduction in the risks of water pollution and contamination, the increase in soil organic matter and the reduction of some emissions affecting air quality.
Demand for organic food has steadily increased over the last years. Under the REPS, payments on land being converted to organic production are made over two years. We would like to see a five-year scheme aimed at supporting the conversion period from conventional to organic production, and to have this applied outside the REPS also. Teagasc needs to pay much greater attention towards increasing production from organic and low-input farming.
Financial support for measures to improve marketing and public awareness of the environmental benefits of organic products need to be stepped up. The ideas can be dispersed through publications particularly the Farmers' Journal.
PRESERVATION OF RARE BREEDS AND SPECIES
Hardly any attention is given to this aspect of genetic diversity. The REPS has a provision for this category of farming, but there are few takers. This needs to become part of a research and conservation strategy.
RESEARCH AND DEVELOPMENT
We welcome the inclusion in Teagasc's Corporate Goals of "the further development and more extensive application of sustainable grass-based milk, beef and sheep production systems, and also crop and pig production systems". However, we find that the allocation of resources places too much emphasis on improving economic performance at the expense of protecting the environment and animal welfare.
FARMER INVOLVEMENT
No real progress will be made without the full co-operation and agreement of farmers. To that end, farmers need, first of all, to be fully informed. This can be done through regular features in the farming press. Additionally, farmers need to come together to examine the issues at hand: how do we proceed into the future, given the environmental facts of eutrophication, climate change, acidification and loss of biodiversity? How can farming enterprises change, diversify and convert into organic farming without loss of income? Inside the EU, farmer discussion groups on these topics are not unusual. The Department of Agriculture, Teagasc and the Irish Farming Groups need to encourage such local farmer groups. However, the emphasis should be all inclusive, ie inclusive of the environmental facts of farming life.
BIBLIOGRAPHY
Agriculture & Biodiversity - Questions and Answers, Council of
Europe
Newsletter from Ritt Bjerregaard, EU Commissioner for the
Environment, Brussels, March 1999
REPS Conference Proceedings,
Johnstown Castle, 3 December, 1998
Impact of Agriculture Schemes and
Payments on Aspects of Ireland's Heritage, a report for the Heritage
Council, June 1998
Sustainable Development Strategy, Government of
Ireland, 1997)
Agri Aware, EU Direct Payments, Answers to Commonly
Asked questions, Agri Awareness Centre
Pilot Environmental Accounts,
compiled by Sue Scott of the Economic and Social Research Institute on
behalf of the Central Statistics Office
European Environmental
Bureau, info@eeb.org
Training Materials on Agriculture, Friends of
the Earth Europe and European Environmental Bureau, 1998
Teagasc
2000, A strategy for Teagasc services to the food and agriculture industry
in Ireland.
Proposal for a Directive of the European Parliament and
of the Council on national emissions ceilings for certain atmospheric
pollutants, COM99-125final.
The Pan-European Biological and Landscape
Diversity Strategy, Council of Europe, UNEP, European Centre for Nature
Conservation
Policies and Priorities for Ireland's Landscape,
Conference Papers, Tullamore, Co. Offaly, April 1999,
The Heritage
Council of Ireland Series.
Irish Landscape Forum, Landscape Alliance
Ireland, Old Abbey Gardens, Waterfall, Cork.
Agriculture,
Environment, Rural Development - Facts and Figures - A Challenge for
Agriculture. Eurostat, DG VI, DG XI.
4gene: unit of genetic data, situated within a chromosome, responsible for the expression of a specific feature; ecotype a taxon lower than the species, defined by its ecological requirements. For the same species, some ecotypes can be adapted to dry land and others to wetlands; taxon: any unit of classification for living beings: family, genus, species, sub-species, variety, and so on.