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Date: 23rd March 2018
The Irish Wildlife Trust (IWT) is a national, charitable membership-based organisation which was established in 1979. Our goal is to raise awareness of our natural heritage and its benefits to people. Since agriculture is the main land use in Ireland, covering 67%1 of the land surface, the Common Agricultural Policy (CAP) is central to the protection of wildlife, not only on the farms themselves, but in all the river systems which drain the country.
The IWT supports the CAP and the central principle of direct payments to farmers. We acknowledge that farming in the EU produces high quality food at affordable prices and we understand that these are critical aims which must be met alongside the protection of the environment.
However, it must be acknowledged that the CAP has failed in this latter task. Ireland is currently undergoing an extinction crisis at a scale and breadth which has not been witnessed in human history. The National Parks and Wildlife Service (NPWS), the state agency which monitors the health of our biodiversity tells us that only 5 of 58 of our most important habitats are in ‘good’ status. Of species, a slightly better 32 of 69 are in ‘good status’. They highlight agriculture as the single biggest pressure on these habitats and species2. The loss of flowers and the increasing use of pesticides associated with intensive agriculture is responsible for catastrophic declines in bee populations, and one third of species are threatened with
extinction. Indeed, recent studies from across Europe suggest that we have experienced a collapse of insect populations generally (although data from Ireland is lacking) with unknown repercussions for ecosystems and indeed agricultural systems. The Environmental Protection Agency (EPA) tells us that over half of our water bodies are polluted and the single biggest contributor to this is agriculture3. Indeed, there has been a precipitous decline in the number of ‘pristine’ water sites – from over 500 in the 1980s to just 21 today (4).
Meanwhile, land drainage policies, driven by the expansion of available agricultural land and developed in the 1940s, have drastically altered the natural functioning of nearly all of our rivers. This has resulted in the loss of natural flood plains, contributing to the collapse of freshwater fish species like Atlantic Salmon and European Eel and creating flooding pressure
in towns and cities downstream.
In upland areas, where extensive commonage grazing is the rule, all peatland habitats are assessed by the NPWS as in ‘bad’ condition while the typical assemblage of birds characteristic of these areas (red grouse, hen harrier, merlin, ring ouzel, nightjar, curlew, golden eagle, twite and others) are threatened with extinction5. The routine setting of wild fires in these areas is driven by CAP eligibility requirements and has resulted in widespread damage.
The European Commission’s public consultation on the CAP reform attracted an overwhelming response with 92% of non-farmers, and 64% of farmers, agreeing that more needs to be done to protect the environment. The Irish government must acknowledge the overriding imperative to create a CAP which can restore wildlife populations and water quality. The IWT welcomes the emphasis on greater decision-making at a local level, as different geographical locations will require different solutions. The new CAP must also be based upon measurable outcomes, giving farmers the incentive to choose the solutions which best suit their land. Previous schemes such as REPS, AEOS or the current GLAS encourage positive actions but are failing in reversing declines in wildlife populations or improving water quality.
A significant driver of habitat loss under the existing CAP is the requirement for all land to be in agricultural production, regardless of whether it is suitable for this purpose. This promotes the setting of fires, drainage of wet areas and removal of emerging woodland (scrub). The IWT would therefore like to see a new measure which would allow landowners to benefit from restoring land to its natural vegetation cover (typically native woodland). Removing all grazing pressure from uplands, river corridors or low-lying areas prone to flooding or waterlogging would provide new habitat for wildlife as well as public goods such as flood alleviation, carbon storage and amenity. It is a measure which could be applied at a landscape-scale, e.g. across a mountain range, or within fields where farmers know that grass growth is poor. This type of ‘rewildling’ measure, which should be optional for land owners, has enormous potential to deliver public goods at low cost to the taxpayer.
The Irish state has legally-binding environmental obligations to protect and restore biodiversity (Habitats and Birds directives), water (Water Framework Directive) and to reduce greenhouse gas emissions. It is failing on all of these fronts. The impending reform of the CAP provides an opportunity to reverse this poor record while ensuring farmers’ livelihoods and maintaining a high quality of food production.
1 EPA. 2016. Ireland’s Environment: An Assessment 2016.
2 NPWS. 2013. The Status of EU Protected Habitats and Species in Ireland. 2013.
3 EPA. 2015. Water Quality in Ireland 2010-2012.
4 EPA. 2017. Water Quality in Ireland 2010-2015
5 Colhoun & Cummins. 2013. Birds of Conservation Concern in Ireland.