From:†††††††††††††††††††††††††††††††††††††††††††† Tadhg O'Mahony [T.O'Mahony@epa.ie]

Sent:†††††††††††††††††††††††††††††††††††††††††††††† 11 May 2015 17:02

To:††††††††††††††††††††††††††††††††††††††††††††††††† Dowling, Siobhan; Collins, NoelD

Cc:†††††††††††††††††††††††††††††††††††††††††††††††††† Laura Burke; Matthew Crowe; Micheal Lehane

Subject:†††††††††††††††††††††††††††††††††††††††† Strategic Environmental Assessment of Agri-Food Strategy 2025 Scoping Consultation

Attachments:†††††††††††††††††††††††††††††† FH2020 - EPA Submission FH2020Specific Comments 30 01†††† 2013 .pdf; EPAAgriFood2025Strategy260115.pdf; SCP140503 2 EPA Submission Draft Forestry Programme 2014†††† -2020Ireland13 10 2014 .pdf; SCP130304 2 Draft Forest Policy Review EPASubmission†††† 23 08 2013.pdf; SCP130102.4 EPA Submission Draft Rural Development†††† Programme 16 06 2014.pdf

 

Dear Ms Dowling,

 

We acknowledge your notification dated 10th April 2015 in relation to the scoping for the Strategic Environmental Assessment of Agri-Food Strategy 2025consultation. We welcome the opportunity to provide input at this stage of the SEA for the Strategy.

 

Our submission to the initial consultation stage for the Strategy and our previous submission in relation to the environmental analysis for Food Harvest 2020 are attached. Our feedback and information provided at the Scoping Workshop on April 9th should also inform the overall assessment.  Previous EPA submissions on the Rural Development Programme, Forest Policy Review and Irelandís Forestry Programme are also attached.  The relevant aspects of these submissions should be taken into account in preparing the Strategy and undertaking the SEA. 

 

Overall, the EPA is broadly supportive of the aims and vision of Food Harvest 2020/Agri-Food Strategy 2025 provided that it does not result in negative impacts for the environment at national, regional or local levels.  Damage to the environment will have an adverse effect on the image and credibility on which Food Harvest 2020/Agri-Food Strategy 2025 is built. The on-going development of the agriculture sectors without damaging the environment upon which it depends is a significant challenge. 

 

The SEA Directive requires monitoring of the significant effects of implementation of plans and programmes. The proposed environmental monitoring programme for the Strategy should be reflected in specific commitments in the overall Strategy.  This should take into account relevant existing national environmental monitoring programmes including WFD, biodiversity, air quality and greenhouse gas emissions related monitoring and predictions. Clear sector related objectives, targets and indicators should be linked with relevant environmental objectives, targets and indicators. These should be aligned with relevant international, EU and national environmental obligations, commitments and targets. Provisions for environmental monitoring reporting should also be set out in the Strategy. 

 

Consideration should also be given to the overall governance of implementation of the Strategy for the specific sectors and this should be reflected in commitments in the Strategy.  Clear responsibility should be assigned for delivery of the overall Strategy along with the structures to be established to deliver the sector targets and related environmental targets. The merits of lower level regional /catchment based sector implementation structures and relevant guidance and assessments should also be considered.    

 

We will continue to provide feedback input to the Strategy and the SEA though our role in the Agri 2025 Environmental Analysis Steering Group and the Agri 2025 Strategic Committee.  Specific observations on the SEA Strategic Environmental Assessment Issues Paper will issue by or before May 15th

 

Guidance on the SEA process and SEA Spatial Information Sources are available on the EPA website. These can be consulted at http://www.epa.ie/pubs/advice/ea/

 

We look forward to working with the Department of Agriculture, Food and Marine to integrate environmental considerations throughout the development of the Strategy and promote sustainable development of agriculture and food production in Ireland.

 

Yours sincerely

_____________

Tadhg OíMahony

 

 

Tadhg O'Mahony

Senior Scientific Officer

SEA Section

Office of Environmental Assessment

Environmental Protection Agency

Regional Inspectorate

Inniscarra

County Cork

 

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