Submission to the Department of Agriculture, Food and the Marine in relation to the Public Consultation Process on the Draft CAP Strategy 2023-2027

December 2021

Selected Notes

In an interim review of ASSAP, the adoption of implementation measures by farmers was reviewed; the costs of the proposed mitigation measures was consistently the largest obstacle for implementation;

“The greatest level of non-implementation of measures for the 20 high risk issues identified is in actions that require capital investment by farmers.”

If PAAs are prioritised within the AECM scheme, it will ensure farmers are supported to implement the targeted measures that will have the most effective outcomes for water quality.

The Forum recommends that the definition of ‘Vulnerable water area’ (currently proposed for Tier 2) should be “any water body where agriculture has been identified as a significant pressure”, and priority should be given to those identified as having a critical source area (supported by EPA PIP maps).

The Forum recommends that the proposed ‘vulnerable water area’ eligibility criterion should be included within Tier 1 (not Tier 2 as currently proposed), to allow farmers in these areas to get priority access to the AECM scheme.

The draft RBMP states that 2500km of riverside interception measures (equivalent to 3% length of all river channels) will require targeted mitigation measures to significantly improve water quality. This information is based on the EPA’s Pollution Impact Potential (PIP) maps, or critical source area maps, which combine the soils and the DAFM farm data to show, on a relative risk basis, where these hotspots, or critical source areas, are within the landscape, and also where the quickest response will likely be seen in the river if measures are implemented.

The Forum recommends that farms with a ‘vulnerable water area’, identified by EPA PIP maps as being a critical source area, should be prioritised to receive AECM payments; as targeted measures within these catchments have the potential to have significant improvements in water quality, along with co-benefits for biodiversity and climate.

The Forum is concerned that the proposed limit of 50,000 farmers for the AECM will not be sufficient to support all farmers who are either in a PAA or a ‘vulnerable water area’.

Forum recommends that greater consideration be given to requiring spatially targeted extended buffer
zones, whereby they are added as a mandatory measure within Tier 2 for vulnerable water bodies in poorly draining areas where runoff of pollutants is posing a threat to watercourses.

In freely draining areas, a high proportion of rainfall infiltrates vertically underground to the water table, thereby flowing underground and bypassing much of the nearby buffer zones.

Forum is of the view that that a dedicated strategy will be required for peatland re-wetting, which is properly funded, with inter-department collaboration across Government and transitional supports for farmers, as it has mutual benefits for water quality, climate and biodiversity.

Download the submission here

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