The Irish Wildlife Trust welcomes the Programme for Government as potentially transformative for the Irish landscape

The Irish Wildlife Trust (IWT) is welcoming the Programme for Government (PfG) presented by Fianna Fáil, the Green Party and Fine Gael as containing a number of elements which are potentially transformative in addressing the biodiversity emergency. In February of this year, in advance of the general election, the IWT wrote to all the political parties with our ‘top 10’ asks. We are judging the PfG against these requests.

The IWT welcomes the tone of the PfG and the declaration that that “the wellbeing of our nation goes beyond the narrow confines of economic growth” and that this focus has overlooked damage to the environment. It is a very positive step that new “wellbeing indicators” are to be developed that will correct for this. We also welcome the clear recognition that addressing the climate and biodiversity emergency must not be overshadowed by the response to Covid-19 and that a better quality of life includes “a deeper sense of connection to the natural world around us”. These are important principles which must guide future decision-making across all facets of our society.

IWT Campaign Officer Pádraic Fogarty says, “There are many positive actions to take away from this document which could transform the fortunes of nature in Ireland. If implemented enthusiastically it will bring enormous benefits to people and communities around Ireland who may one day enjoy living in a nature-rich landscape. We particularly welcome the commitment to review the structure and funding of the National Parks and Wildlife Service but there is concern that the language does not reflect the urgency of the task. There must be no delay in initiating this review and setting a path to increasing its funding and setting it on an independent footing. The Budget later this year will be an early test of faith and we’d expect to see a substantial increase in funding at that point.”

Our pre-election asks are shown in the bold below and our response to the PfG is given below each one:

[Ask 1 Governance. Re-structure and properly fund the National Parks and Wildlife Service (NPWS). The NPWS should be independent (like the Environmental Protection Agency), allowing it to provide scientific advice, take enforcement action and run education programmes as well as the day-to-day work of protecting nature. Sufficient resources are required to implement the National Biodiversity Action Plan as well as to meet minimum legal requirements under the Habitats and Birds Directives, including drawing up and implementing management plans for all existing protected areas on land and in the sea. We also need legislation for our national parks which will allow for their management and expansion. There should be a long-term funding commitment to the National Biodiversity Data Centre, which is integral to this work]

• There is a clear commitment to “review the remit, status and funding of the National Parks and Wildlife Service” and this is an essential first step in addressing the biodiversity emergency. We would have liked to have seen a clearer commitment to the independence of the agency. Our chief concern is that this action must be front-loaded, i.e. within the first 100 days of government, as it will not be possible to address other land use and legal compliance issues without a fully functioning nature conservation agency.
• While there is a commitment to “support biodiversity data collection” this does not go nearly far enough in committing to the future of the National Biodiversity Data Centre. This vital agency must be given certainty over its long-term future.
• There is a commitment to “continue to implement the third National Biodiversity Action Plan 2017-2021” however, similar to actions above, there is a lack of urgency in this language given that the current and previous Action Plan have been poorly implemented.

[Ask 2. There should be a clear commitment to fully implement all existing environmental legislation.]

There is a conspicuous absence of this commitment. The lack of implementation of existing legislation has dogged successive Irish governments and has severely exacerbate the biodiversity crisis.

[Ask 3. To convene the Citizens’ Assembly on biodiversity loss as committed to by the Dáil in their declaration of a climate and biodiversity emergency in May of 2019. This must be followed by a sustained, national education programme to inform people of the implications and solutions to the ecological crises.]

We welcome the reaffirmation that a Citizens’ Assembly on biodiversity loss will be established although we note the worrying lack of a timeline.

[Ask 4. Ireland should support the EU in committing to the forthcoming ‘Global Deal for Nature‘ to be agreed at COP15 in China later in 2020 to protect 30% of land and sea for biodiversity conservation. This is in line with the UN Decade on Ecosystem Restoration.]

Since the general election the EU published its Biodiversity Strategy which sets ambitions targets for the protection and restoration of nature on land and at sea. We welcome the commitment in the PfG to this strategy.

[Ask 5. Nature-based solutions for climate. The Oireachtas Joint Committee on Climate Action Plan should be implemented, recognising that nature-based solutions could bring us one third of the way to meeting climate targets.]

We strongly welcome the measures to aggressively address the climate crisis and the reduction in greenhouse gas emissions due to the intimate connections between climate and biodiversity issues. While the phrase ‘nature-based solutions’ does not appear in the PfG we welcome the measures to include carbon sequestration on farmland, in natural forests and the oceans – although the language on peatlands is worryingly vague.

[Ask 6. Agriculture.Payments under the Common Agricultural Policy should be based on measurable results/outcomes rather than actions. Payments under Pillar 1 should be given for land which is not farmed (abolishing current eligibility rules which require land to be in ‘good agricultural condition’). Allowing land to revert to woodland/wetland has multiple benefits to society.]

• We strongly welcome the commitment to “seek reforms to the [Common Agricultural Policy] to reward farmers for sequestering carbon, restoring biodiversity, improving water and air quality, producing clean energy, and developing schemes that support results-based outcomes”.
• We also strongly welcome the commitment to “advocate for a fair system of eligibility conditionality, under the reform of the Good Agricultural and Environmental Condition rules, recognising that farmers should not be unfairly penalised for maintaining land that contributes to biodiversity principles”. Other measures to “incentivise the rewetting of carbon-rich soils”, reducing pesticide use and the incentivising of small-scale rewilding on farmland.
• We would have liked to have seen a greater commitment to the use of the CAP for large-scale rewilding, particularly in upland areas.

[Ask 7. Forests. Large areas of connected native woodlands should be created which will be set aside predominantly for nature, with no commercial extraction. Future commercial forestry should be ‘close to nature’ with ‘continuous cover’.]

• We welcome the commitment to publish a new forestry programme and expect that this will be more aligned with meeting climate and biodiversity goals.
• We welcome the commitment to “promote close to nature-continuous cover forestry systems to ultimately create permanent biodiverse forests containing trees of all ages” as well as “’protection forests’ along rivers and lakes to protect water quality and assist in manging flood risks”.
• We would have liked to have seen a clear commitment to meeting EU levels of tree-cover (~30%).
• We would have liked to have seen a clear commitment to reviewing the remit of Coillte, the state forestry-company, to remove their ‘profit-first’ mandate and so steer them towards addressing the climate and biodiversity emergency.
• We strongly welcome the commitment to a “radical expansion of urban tree planting and neighbourhood and community forests”.

[Ask 8. Oceans. Legislation should be introduced for the designation of large, effective and fully managed Marine Protected Areas. The network of protected sites should cover at least 30% of Ireland’s exclusive economic zone by 2030 and 50% of sites should be no-take-zones. The Wildlife Act should be amended to give legal protection to (non-mammal) marine species such as sharks.]

• We welcome the commitment to a successor to the Harvesting Our Ocean Wealth plan which has greater focus on protection of the marine environment. We also welcome the commitment to the environmental goals of the Common Fisheries Policy: ending overfishing, eliminating the dumping of unwanted catches and the elimination of illegal fishing through robust enforcement.
• We strongly welcome the commitment to meeting the overdue target of creating Marine Protected Areas over 10% of the sea “as soon as practical” and aiming for 30% coverage by 2030.
• We were disappointed that there was not a clearer commitment to ‘no take zones’ or ‘strict protection’ of some of these areas, as required under the EU Biodiversity Strategy.
• We are disappointed that there is no specific commitment to amending the Wildlife Act to give to legal protection to marine species of fish or invertebrates – something which is conspicuously absent at present.

Ask 9. Rivers. The Arterial Drainage Act of 1945 should be repealed/replaced to give priority to the restoration of river systems, water quality and natural flood prevention over heavy engineering.]

The poor water quality in our river systems gets disappointingly little attention in the PfG. We are disappointed that there is no specific mention of the Arterial Drainage Act, which is responsible for on-going damage to our river systems. We would have liked to have seen a commitment to review the oversight and functioning of the Office of Public Works, which administers drainage schemes.

[Ask 10. Bogs and peatlands should be restored/rewetted where possible. Rewilding should be used to reforest areas of peatland where this is appropriate.]

We welcome the commitment to review the mandate of Bord na Móna to realign its activities with climate and biodiversity goals. However, a clear commitment to rewetting, restoring and rewilding all peat bogs seems to be lacking, this is particularly puzzling.

Additional

• The commitment to a National Soils Strategy, the reduction in use of inorganic nitrogen fertiliser and the promotion of ‘multi-species’ grasslands are significant steps towards restoring nature on farmland.
• We warmly welcome the commitment to end Badger culling “as soon as possible” and the implementation of a TB eradication strategy.
• We warmly welcome the commitment to “aggressively tackle” the issue of waste, ghost nets and illegal dumping in the marine environment.
• We welcome the commitment to undertake a ‘national land use review’ which could guide the appropriate policies for the longer-term however this must not be used to delay actions and policies in other areas which require urgent attention, e.g. peatland restoration.
• We warmly welcome the ban on oil and gas exploration which not only addresses greenhouse gas emissions but will reduce the significant level of ocean noise which is a plague on marine life.