Ireland’s draft CAP Strategic Plan is failing the environment


Measures in the draft CAP Strategic Plan fall far short of what’s needed to address the biodiversity and climate crisis, Ireland’s leading coalition of environmental groups has said.  

Representatives from the Environmental Pillar met with Minister Charlie McConalogue and Minister Pippa Hackett on Friday 16 October and stated clearly that the actions and measures in Ireland’s draft CAP Strategic Plan nowhere near meet the moment of addressing the biodiversity and climate emergency on farmland.

Dáil Éireann declared a climate and biodiversity emergency on May 9th 2019 and now needs to ensure that Ireland’s CAP Strategic Plan starts to undo the damage caused by agriculture and address the emergency.

There are three particular areas of concern:

1)  Despite agriculture having the most significant impact on farmland birds including breeding waders, there are no specific and targeted measures in the draft agri-environment scheme to halt the loss of this group of birds which includes endangered Curlew, Lapwing, Snipe, etc. Targeted and results-based agri-environment schemes are critical to halt losses. A bespoke breeding wader scheme supported by specialist ecological advice and access to funding for capital works. The Department of Agriculture, Forestry and the Marine (DAFM) already identified the need to address farmland bird declines and must deliver now.

Oonagh Duggan of BirdWatch Ireland and Environmental Pillar representative to the CAP Consultative Committee said:

“In 2021 BirdWatch Ireland published its Birds of Conservation Concern list which showed that the farmland bird species group has grown on the red list more than any other group in the last 20 years and now stands at 16. The increase is due to the intensification of agriculture and forestry in particular and also due to the consequent increase in predators. These species cannot reproduce safely. The Ministers for Agriculture must secure a bespoke scheme for breeding waders in the next CAP or species will fall off the cliff”.

2)  DAFM is not making sufficient progress to reach the EU Biodiversity Strategy and Food Vision 2030 goal of 10% high diversity space for nature (non-productive areas) on farmland [2]. Ireland is not only proposing to cut space for nature from 5% to 4% in the baseline – a 20% drop –  it is only going to achieve 7% in the draft ecoscheme – and ecoschemes are optional. [3]. There’s no focus on improving the quality of habitats and the current list of eligible habitats include catch crops and similar which are not focused on biodiversity. Teagasc research shows that there is up to 13% of habitats in intensive farms already and therefore there is no increase in ambition and critically has no focus on improving quality.

Oliver Moore of the Environmental Pillar said:

“Already intensive beef, dairy and tillage farmers are achieving between 5% and 7%, as Teagasc research shows. In fact, tillage farmers with over 15 hectares are required to have 5% space for nature under the existing CAP rules. In this context, 4% goes against CAP’s no backsliding principle. Government must also increase the percentage to 10% in the ecoscheme and focus on improving quality of habitats or otherwise up to €295 million of citizen’s money for this ecoscheme spent over five years will be a catastrophic waste of money.”

3)  The draft CAP measures contain no concrete action to address methane and the voluntary ecoscheme to address nitrogen use won’t come into force until 2024 as a fertiliser register has to be put into place first [4]. This means that unless other mechanisms are put in place, the draft CAP Plan will not help Ireland meet its climate objectives out to 2027. The Department still has not defined wetlands in order to proceed with rewetting and there’s very little detail on the agri-environment scheme to manage peat soils.  

Charles Stanley Smith, Environmental Pillar representative to the CAP Consultative Committee said:

“Ireland’s drained organic soils and degraded bogs emit about 11 million tonnes of CO2 a year which is about the same as the power sector and still we are seeing little action to address the scale of the challenge. There is also no measure to support farmers to reduce methane. The department is dragging its heels to cut emissions while putting a lot of store in tree planting though we know that fire, storms, disease and inappropriate siting of trees can render tree planting as a source of emissions rather than a sink and threaten biodiversity”.

The Environmental Pillar demands that the Department urgently address these issues and start to address the poor environmental track record of agriculture.



[1] Gilbert, G, Stanbury, A., Lewis, L., (2021) Birds of Conservation Concern in Ireland 4: 2020–2026 Irish Birds 43: 1–22 available here

[2] The EU Biodiversity Strategy calls on Member States: “To provide space for wild animals, plants, pollinators and natural pest regulators, there is an urgent need to bring back at least 10% of agricultural area under high-diversity landscape features. These include, inter alia, buffer strips, rotational or non-rotational fallow land, hedges, non-productive trees, terrace walls, and ponds. These help enhance carbon sequestration, prevent soil erosion and depletion, filter air and water, and support climate adaptation. In addition, more biodiversity often helps lead to more agricultural production. Member States will need to translate the 10% EU target to a lower geographical scale to ensure connectivity among habitats, especially through the CAP instruments and CAP Strategic Plans, in line with the Farm to Fork Strategy, and through the implementation of the Habitats Directive. The progress towards the target will be under constant review, and adjustment if needed, to mitigate against undue impact on biodiversity, food security and farmers’ competitiveness”, available here

[3] and [4] Five draft ecoschemes have been proposed in the CAP. These are voluntary schemes that 130,000 farmers can apply if they wish to receive their full Basic Income Support. If they don’t they will not receive 25% of their basic payment:

1. Non-productive areas and landscape features : Focus on Increasing requirement of land devoted under GAEC 8

2. Extensive livestock production : Specified maximum overall stocking rate for the calendar year.

3. Limiting Chemical Nitrogen Input (likely from 2024 onwards) : Specified Chemical Nitrogen usage limit for the calendar year.

4. Planting of Native Trees A minimum planting rate of native trees per eligible hectare.

5. Use of GPS Controlled spreader to apply chemical fertilisers Application of chemical fertiliser to be done with a GPS controlled fertiliser spreader

[5]. Links to Teagasc research references: