Submission on Environmental Analysis of Scenarios Related to Implementation of Recommendations in Food Harvest 2020 (FH2020)

Download report: Environmental-Pillar-Submission-on-the-Analysis-of-the-Environmental-Impacts-of-FH2020(Posted on July 6, 2012)
Summary

  • Food Harvest 2020, as a Government Strategic Policy Document should have been subjected to a screening under Article 6 of the Habitats Directive. This would have inevitably resulted in the need to conduct a number of Appropriate Assessments (AA).
  • During the development of Food Harvest 2020, as a Government Strategic Policy Document a Strategic Environmental Assessment (SEA) should have been conducted as required by the SEA Directive.
  • The current process of, Environmental Analysis of Scenarios Related to Implementation of Recommendations in Food Harvest 2020 (FH2020), does not fulfil the obligations of government under either of these legally binding EU Directives.
  • FH2020 will impact on at least 75% of the land and most of the surface, estuarine and coastal waters of this state.
  • Apart from the impacts on sites protected under EU and domestic law, this Government Strategic Policy Document has the potential to impact on all aspects of the biological systems that maintain the productivity of agriculture. In particular intensification will provide even greater incentives for the on-going destruction of many small but important pockets of biodiversity for example in hedgerows, scrubland and wetlands.
  • FH2020 will also increase Green House Gas emissions with consequent climatic, environmental, health and economic consequences both domestically and globally.
  • Adaptation and resilience to climate change need to be considered in the assessment of both the implementation of the Strategy, and analysis of its impacts.
  • The absence of clear targets, with the exception of the dairy sector, makes a full analysis very difficult.
  • Similarly, the absence of good data, in particular regarding soils and coastal biodiversity makes analysis and consequent decisions not much more than guess work.
  • The desire to increase employment and farm incomes in the short-term should not be done at the cost of destroying the fundamental wealth that supports all human activity for this and future generations. This wealth is our clean seas, freshwater, stable atmosphere, good quality soils, and a healthy biodiversity.
  • The greening of agriculture is the great hope for Irish farming if we are to retain our brand as the unpolluted Green Ireland. Value added to primary production should be the first step in improving income from agriculture, coupled with a serious drive towards high nature value farming practice that makes the produce more attractive to the premium markets.
  • The development and implementation of this Government Strategic Policy without the serious look at how it impacts on the long-term well-being of the country is both illegal and irresponsible.

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