Download Oxfam 1 - Department of Agriculture

28th August 2013
Comments on FoodWise 2025 / Agri-Food Strategy 2025 and Strategic
Environmental Assessment of same
Thank you for the opportunity to comment on the draft Strategy and the draft
Environmental Report.
Oxfam is concerned about the potential impact of the strategy on developing
countries and the failure of the Strategic Environmental Assessment process
to consider these impacts.
Policy Coherence for Development
Ireland’s recently published Policy for International Development One World
One Future1 commits to a “whole-of-Government approach to international
development”, specifying that “this new policy will guide all of our
development efforts – across Government.”
We were glad to be invited, through our participation in Stop Climate Chaos,
to attend a stakeholder scoping workshop in relation to the Strategic
Environmental Assessment (SEA) process on 9th April last. At this, we
emphasised the need to ensure that all impacts on human health and the
environment should be included in the SEA, no matter where they occur. We
suggested that the SEA process was an appropriate process for some or all
1
https://www.irishaid.ie/about-us/policy-for-international-development/
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elements of Policy Coherence for Development (PCD).
The draft Environmental Report states (p. 53) that the Scoping Report was
updated:
Following receipt of review comments and observations of the draft
Scoping Document, all observations, comments and suggestions were
carefully considered and the scoping report was modified accordingly.
However, our comments seem not to have been taken on board. There is no
record in the draft Environmental Report of the comments nor of the reasons if
any that they were not taken on board. (We have very recently asked for a
copy of the modified Scoping Report referred to in the above quotation but we
have not yet received it.)
At the scoping workshop, we asked how Irish Aid's expertise was being
availed of to ensure PCD. It is surprising in that context that Irish Aid is not
one of the stakeholders listed in Annex III as having been consulted, although
other government Departments/agencies were consulted.
While this will only be clear when we receive a copy of the modified Scoping
Report, it appears that impacts on developing countries have been
consciously excluded or omitted from the scope of the SEA. This is a major
flaw, contrary to SEA legislation and practice and contrary to Government
policy on Development.
We urge you to revise the Strategy and the Environmental Report to
remedy this failure to ensure policy coherence. We are willing to provide
any assistance we can in this regard.
At the scoping workshop, we raised some particular concerns, which we
discuss below.
Breastmilk substitute
In the SEA Issues Paper (which we understand to be same as the Scoping
Report referred to in the draft Environmental Report), the consultants were
clear that this was one of the environmental issues to be considered in the
process:

Potential for significant effects on human health are mainly anticipated
from the dairy and infant formula sector. These relate to the necessary
promotion of formula products, which is in opposition to the World
Health Organisation (WHO) recommendations for prolonged
breastfeeding.
The issue was also covered in the powerpoint presentation given by the
consultants at the meeting.
At the scoping workshop, both Oxfam and Trócaire agreed that this impact
needed to be considered. (An industry representative disagreed with this.)
As far as we can tell, the question of impact on human health due to the
substitution of breastmilk by formula has been entirely omitted from the draft
Environmental Report. We would expect that this omission would be
explained. However, we cannot conceive of any valid reason to omit this
impact from the analysis.
We recommend that the draft Environmental Report be revised to
consider the impact of the strategy on infant health (which is necessary
for compliance with the SEA Directive) and the Strategy be revised in
order to avoid putting downward pressure on rates of breastfeeding in
any part of the world.
Public health, climate change and diet
At the scoping workshop we pointed to the work of the Intergovernmental
Panel on Climate Change (IPCC) in its Fifth Assessment Report Working
Group III on Mitigation, in particular discussion in Chapter 11 at 11.4.3
drawing on estimates of the climate benefit of adoption of a 'healthy diet'. Our
point was a dual one: first, that analysis of the climate impact and of human
health impacts should take account of research relied on by IPCC and
secondly, that predictions of demand for high-emission foodstuffs should take
account of potential climate mitigation actions which would be informed by the
IPCC. (References to healthy diet were also contested by an industry
representative.)
As far as we can tell, these aspects have also been omitted from the draft
Environmental Report, again with no explanation.
We do note that the only reference to the IPCC is its inclusion in the glossary,
which is unusual; one possible explanation is that mentions of the IPCC were
in earlier drafts of the report and were subsequently deleted.
We recommend that the draft Environmental Report be revised to
consider the impact of the strategy on human health through diet,
(which is necessary for compliance with the SEA Directive) and the
Strategy be revised in order to take account of the IPCC research.
Evaluation of greenhouse gas emissions
Oxfam’s analysis of climate change is:
The world faces a real and imminent risk of major setbacks in efforts to
combat hunger because of climate change. That risk is not a remote
future threat. It is emerging today and will intensify over the coming
decades.2
This impact of climate change on food security has led Oxfam and many other
development organisations to engage with all aspects of climate change, both
in seeking action to reduce all types of greenhouse gas emissions and in
seeking to help communities facing food insecurity to adapt to the changes to
which the climate system is already committed.
At the scoping workshop, we pointed out that the evaluation of greenhouse
gas emissions in the SEA could and should be quantitative. Unfortunately
quantitative estimation has not been done.
The scoping report pointed out:
The greatest challenge to Agri-Food Strategy 2025 will undoubtedly be
the question of Greenhouse Gas (GHG) emissions. It is recognised
that the agricultural sector is the biggest contributor the GHG
emissions in Ireland. In their submission, An Taisce points out that the
agricultural sector accounts for 32% of all emissions in Ireland.
Methane (CH4) from livestock digestion and manure, and nitrous oxide
(N2O) from spreading of manure and fertilisers into soils make up the
bulk of agricultural GHG emissions.
Agriculture emissions were 2.6% higher (0.48 Mt CO2eq) in 2013
2
https://www.oxfam.org/sites/www.oxfam.org/files/file_attachments/ib-growing-disruption-
climate-change-230913-en_2.pdf
compared with 2012 levels (EPA, 2013c). The EPA reports that the
most significant driver for such an increase in emissions was the
increased use of synthetic fertiliser by 19.1%, followed by a 2.2%
increase in cattle numbers, and a 1.5% increase in sheep numbers.
Emission projections suggest a 12% increase in agricultural emissions
by 2020 as result of Food Harvest 2020 (Teagasc, 2013). The Irish
Government has committed to carbon neutral agriculture by 2050 (with
ambitious reduction targets of 42-49%) and, therefore, "the scope of
ambition must be within EU emissions targets already agreed to by
Ireland" (An Taisce submission) in order to ensure sustainable
agricultural development within the broader international GHG
obligations (i.e. Kyoto Protocol), and to avoid EU fines for failing to
meet agreed emissions targets. Although a strong case can be made
that Irish agriculture is the most carbon efficient in the EU, the current
regulatory framework seeks to limit agricultural GHG emissions, and
recent research that could inform EU policy‐making actually suggests
that they should be reduced (Fellman, 2015).
Potential Environmental Issues
 The anticipated increase in animal numbers within the dairy
sector in particular but also within the meat sector, cannot be
considered sustainable intensification in relation to GHG
emissions. Increased methane and NOx emissions will lead to
an overall increase in GHG emissions from the Strategy unless
such emissions are offset elsewhere in the Strategy (e.g.
investing in sustainably managed carbon sequestration in
peatlands and forestry).
The National Climate Change Strategy aims at reducing annual CO2
by I Mt, while the White Paper 'Delivering a sustainable energy future
for Ireland' (DCMNR, 2007) sets a target of 33% energy savings by
2020. Therefore, climate adaptation measures regarding the use of
renewable energy, etc. should be incorporated in Strategy 2025
(DECLG submission) since the agri‐food sector has the potential to
contribute to this. More than one submission argues for the
rationalisation of bioenergy crop utilisation, and support for the
development of biodigestion (Irish Country Markets; Farmgas
Community Partners) ‐ and this might provide some mitigation or offset
for emissions from an increased herd size. Any reliance on carbon
sequestration by increased afforestation would have to be dependent
upon evidence that the proposed plantings were indeed better than
carbon neutral. There is additional potential for carbon sequestration by
conserving peatlands, and in hedgerow maintenance and pasture
management (Agri-Food Strategy Group submission) if and when their
contribution to carbon budgeting is officially recognised. Furthermore,
all objectives and targets should be examined in the light of their ability
to maintain sustainability under projected climate change scenarios for
Ireland, at least for the duration of the Strategy (for example, wetter
summers may lead to higher than predicted pesticide use).
Instead of developing the analysis set out in the scoping report, the draft
Environmental Report offers the following discussion - first from the
Description of the Baseline Environment:
Ireland’s obligations for GHG emission reductions are derived from the
EU Climate Change and Re-Renewable Energy Package 2008 which
set national limits on reduction targets in accordance with the Kyoto
Protocol from the United Nations Convention on Climate Change.
Detailed mandatory commutative targets have been set up to the
period 2020, with mandatory annual targets for the period 2016-2020.
The EPA is responsible for monitoring, measuring and reporting on
GHGs. The EPA (2015) predicts that within an overall rising trajectory
of emissions, “under the ‘best case’ scenario, Ireland is projected to
cumulatively meet its compliance obligations over the 2013-2020”. This
takes into account the overachievement of the annual limits in the
period 2013-2017 which is banked and used in the years 2018-2020.
This rising trajectory will make meeting future targets for the period out
to 2030 and beyond to 2050, which will be set in on-going discussions,
more difficult to achieve.
Carbon sequestration as a result of increased targeted area under
forestry and sustainable grass management techniques are not
available as a mitigation measure against increases in GHG emissions
that may result from increased livestock numbers. Currently available
measurement techniques do not account for Ireland’s high-dependency
on agriculture and predominant out-door grazing pattern, giving rise to
a disproportionate (by European standards) contribution of Agriculture
to total national GHG emission.
With regard to the 2030 EU Climate and Energy Framework, Ireland is
working closely with other member states and the Commission to
examine the best means of progressing. Ireland’s view (DAFM, 2015a)
is that the proposed EU policy framework must do three things:



Promote sustainable intensification of food production to reduce
the carbon intensity of food production and to contribute to both
food security and GHG mitigation objectives.
Encourage sustainable land management, afforestation and
other forest sector mitigation activities, including forest product
uses, that contribute to climate change mitigation and
sustainably manage soil and forest carbon stocks
Seek to move as far along the road to carbon neutrality as is
possible in cost-effective terms, while not compromising the
capacity for sustainable food production”.
Then from the Identification of Likely Significant Effects:
Actions within the draft Agri-Food Strategy 2025 in connection with
policy development and recognition of agriculture’s role in formulating
energy policy have the potential to be significantly positive in relation to
GHG emissions and moderately positive in relation to climate change.
All other actions are deemed to moderately positive or imperceptible in
relation to GHGs. As a result of uncertainty undefined growth
opportunities are deemed to represent a slight moderate threat.
At a sectoral level actions within the forestry sector are deemed to
have a have a moderate positive effects. Uncertainties in relation to the
consequences of some actions in relation to grassland management
have been deemed to represent a slight negative threat. The greatest
challenge to Agri-Food Strategy 2025 will undoubtedly be the question
of GHG emissions, whether or not any substantial increase in the size
of the national herd is proposed. Although a strong case can be made
that Irish agriculture is the most carbon-efficient in the EU, the current
regulatory framework seeks to limit agricultural GHG emissions.
The difference between the Scoping Report and the draft Environmental
Report is striking.
The shift of attention from the topics at hand (baseline emissions and likely
effects) to presentation of EU negotiations and DAFM policy positions (neither
of which is directly the issue) is a diversion of the SEA process away from the
scientific assessment process. (It is also indicative of a change in personnel in
the course of the process. We note that some of the members of the
consultancy team at the scoping stage appear not to have been involved in
the production of the Environmental Report.)
However, the main issue with the draft Environmental Report is the
unjustifiable decision (s. 2.6 and s.4) to allocate increased emissions to the
baseline and not to the strategy which is intended to facilitate the increase.
This leads to an analysis which assumes the emissions will happen with or
without the strategy and a conclusion that the strategy is positive as it will
include measures to slightly abate the emissions. This was not part of the
analysis at the scoping stage, which, as quoted above, identified GHG
emissions as the greatest challenge to the Strategy. That analysis did make
its way into the draft Environmental Report but was then qualified with the
phrase “whether or not any substantial increase in the size of the national
herd is proposed”. This completely confused the analysis, and put it in the
context of an apparent (and, for the purposes of the SEA, irrelevant)
suggestion that EU policy should not seek to limit agricultural GHG emissions.
Agricultural economist Alan Matthews has recommended that “the fiction
underlying the draft Environmental Report that agricultural expansion is
something that was pre-existing and should not therefore be considered in the
evaluation should be dropped.”3
During the scoping consultation, we recommended that the analysis of GHG
emissions should be quantitative, deriving numerical estimates of the impact
of the strategy on emission. This recommendation has not been adopted.
We recommend that the draft Environmental Report be revised in a
manner which allows the impact of the Strategy on GHG emissions to be
compared, quantitatively with current emissions, with a ‘do-nothing’
scenario, and with a range of alternative strategies. These changes are
necessary for compliance with the SEA Directive. The draft Strategy
itself should then be revised to make it consistent with a global
emissions trajectory keeping warming within 2º or 1.5º.
Imports of animal feed and land demand
At the scoping workshop we also pointed to the likely overseas impacts of
increased demand for imports of animal feed to supply increased livestock
populations, noting the likelihood/risk of negative impacts due to land take,
loss of land from natural ecosystems, affecting the populations who rely on
them and diversion of agricultural land from production of human food to
animal food.
The draft Environmental Report has not addressed this issue.
We recommend that the draft Environmental Report be revised in a
manner which allows the impacts of the animal feed imports envisaged
in the Strategy to be estimated, and the draft Strategy be revised to
avoid negative impacts (whether by changes to the factors driving the
types and quantities of feed to be imported, mitigation measures or a
combination of both.) These changes are necessary for compliance with
the SEA Directive.
In summary, the transboundary impacts of the draft Strategy have been
effectively ignored in the draft Environmental Report. The draft Strategy and
the SEA process have so far failed to give effect to Government policy
3
http://capreform.eu/food-wise-2025-agri-food-strategy-launched-in-ireland/
requiring Policy Coherence for Development. This is despite the fact that we
and other NGOs flagged these issues at the scoping stage. The process
needs major changes in order to comply with EU law and Irish government
policy and we have set out above our main recommendations in this regard.