Mr. Charles Stanley-Smith:

We are aware that the CAP cannot address everything; however, the CAP's own objectives include environmental care and preserving landscapes and biodiversity. The CAP is therefore responsible, at a bare minimum, for ensuring that what it funds will not impact the environment negatively.

Climate change is with us now. There is a report nearly every other day on levels being breached. Ireland's emissions profile means it is essential that significant reductions in agriculture and land use emissions are delivered over the short and medium term. The CAP strategic plan does not have the ambition to deliver meaningful climate action. There are no clear deliverables listed such as reductions in tonnes of greenhouse gas emissions and associated timelines. The agriculture sector has to meet a cut in emissions of between 22% and 30% by 2030, and it is not clear how the CAP, worth €9.8 billion, will help the sector achieve its target. The timeline of the CAP strategic plan runs from 2023 to 2027, in parallel with the climate action plan targets for 2030. Despite the importance of agriculture and the land use sector to the climate action plan and the Climate Change Advisory Council's carbon budgets, there is a lack of policy coherence across the board.

As for methane reduction, the IPCC's sixth assessment report, AR6, updated our understanding of the global carbon budget and the need for net-zero emissions of long-lived gases - for example, CO2 and N2O - and for a strong, rapid and sustained reduction in methane emissions. There may be arguments about the multiplication factor to be applied to methane in a steady state in respect of the amount of methane, but nobody is in any doubt that increasing or decreasing methane has a large and immediate effect. The biggest reward would be in terms of greenhouse gases. If a reduction in methane levels will not be politically possible, methane must not be allowed to increase. Dairy cows produce at least one and a half times the amount of methane that beef cattle produce. The suckler carbon efficiency programme of the CAP will have a positive effect on emissions produced by beef cattle, but any gains will be drowned out if dairy cattle numbers continue to increase. There is no programme in the CAP strategic plan to help farmers to reduce the number of dairy cattle. There is an extensification eco-scheme which will help to reduce the push for any extensive farmers to become intensive but it will have no impact on the stocking rates of intensive dairy farmers.

As for land use, land use change and forestry, LULUCF, the climate action plan and the carbon budgets place a strong emphasis on the need for increased afforestation and the re-wetting of high-carbon soils. While we would question the feasibility of the targets that have been set, it is clear that any actions must deliver scientifically credible carbon sequestration and be targeted as the right action in the right place. Without immediate action, the EPA projects that emissions from the land use sector will hit between 7 million Mt CO2 eq and 11 million Mt CO2 eq in 2030.

As for re-wetting high-carbon farmland, one of the biggest reductions proposed in the climate action plan is reduced management intensity of 80,000 ha of farmed organic soils, which would deliver direct savings of 880,000 Mt CO2 eq by 2030. The scale of the challenge merits significant attention within the CAP strategic plan. In the absence of an actual intervention, there needs to be a plan started now to include how the strategic plan's agri-environment climate measures, AECMs, can support farmers to achieve these objectives and how we should investigate sustainable paludiculture. Lessons can be learned from the various Irish European Innovation Partnerships, EIPs, and the extensive work throughout northern Europe. One item related to this is that the target of 2024 for GAEC 2 needs to be brought forward immediately to protect peatlands and wetlands.

As for forestry, the current proposals for native trees on farms in the next CAP are wholly inadequate, lacking overarching objectives with targets. Under the current draft eco-scheme proposals, farmers would have to plant between three and six trees per hectare per year, but there is an absence of conditionality or guidance, which means that this initiative will fail to achieve maximum benefits for nature.

As for water quality, the EPA has stated: "Reducing the nitrate levels in our waters must be a priority." The EPA highlights that levels of nitrate pollution are strongly related to increasing agricultural intensification. The EPA has produced pollution impact potential, PIP, maps, which indicate where the greatest risks are for nitrogen and phosphorous run-off. There is no targeting within the CAP strategic plan to ensure that safeguards such as buffer strips are tailored to protect water quality form agricultural run-off, especially in areas indicated by PIP maps.

The pillar also recommends that the definition of "vulnerable water area" for tier 2 be "any water body where agriculture has been identified as a significant pressure". Priority should be given to those identified as having a critical source area, supported by EPA PIP maps. These should be moved to tier 1.

As for renewables, we welcome the move to fund farm renewable energy technology.

As for training, all aspects of the renewed agriculture knowledge and innovation systems, AKIS, must be based on a foundation of the three elements of sustainability.