Ms Geraldine O'Sullivan:

I will follow up on what Mr. O'Brien said about the impact. We have clarity on the drained peatlands. We have some figures and we understand that is a measure under agriculture. The issue we are concerned about is under Article 4 which applies to restoration and the wider enhancement and re-establishment of habitats. That is where we lack clarity about the impact of this regulation and that is why the full impact assessment is essential.

Regarding the Deputy's comment about Article 9 and the cap of 20%, it is also our understanding that 80% of the measure will be the responsibility of farmers who must rewet and restore that area. In examining the regulations, it occurs to me that we need to move that measure from Article 9 to Article 4 because that is where the wider landscape is considered. The responsibility for the measure will not then only be on farmers. One is looking the wider landscape and at letting the member state to determine which areas are best suited to that kind of restoration. That should be moved out of Article 9 and should not be the responsibility of farmers.

On the Deputy's comments about the Directorate-General for Agriculture and Rural Development, we met with the environmental committee in the Committee of Professional Agricultural Organisations, COPA, yesterday. The farming organisations of all member states are concerned about the implications of this. Some member states have carried out analysis and found the impact on production and farming goes far beyond what they initially thought it would. I cannot stress enough that we need to understand the land area and cost involved as well as how it will be managed and resourced at a national level. If this is a legally binding target and if we miss the target by a small percentage, we are potentially open to a legal challenge. This cannot be pushed forward without an understanding of the extent of what is required and the costs associated with it.

In drafting this regulation, it was identified that the reason the biodiversity targets were not achieved was that there was a lack of funding and resources. That was a key reason previous biodiversity targets were not achieved. It is thought that CAP will fund this regulation. CAP does not have the ability to do so. If this regulation is pushed through, we need to see a dedicated funding mechanism for biodiversity and nature restoration and it must be fully costed and understood.