Hedge Laying Association of Ireland Miskaun Ballinamore Co. Leitrim
086 3028790 www.hedgelaying.ie
Hedge Laying Association of Ireland comments on the Draft Food Wise 2025 Report and the associated draft SEA Environmental Report
Prepared by N. Foulkes on behalf of the HLAI
The Hedge Laying Association of Ireland is a not-for-profit organisation established in 2004 with the aim of encouraging and facilitating the conservation, protection and appropriate management of hedgerows. We are members of the Irish Environmental Network.
Based on the results of the Badger and Habitats Survey (Smal, 1994) the hedgerow/tree row network in Ireland extends to approximately 382,000 km. According to Teagasc statistics hedgerows, scrub and non-forest trees cover 6.5% of the land area of the Republic. They are a significant resource to agriculture and play an important role in the ecology of the island.
The HLAI response to this consultation will be in the form of a series of challenges to the Food Wise plan (FW) and the Draft Environmental Report (DER).
Challenge to the Terms of Reference of the Strategy
“Is it hard?' Not if you have the right attitudes. Its having the right attitudes that’s hard.” Robert M. Pirsig
The philosophy of the importance of economic growth is at the heart of the Terms of Reference (ToR) of the Food Wise Strategy. Given that sustainability is a key component of the Strategy it is reasonable that the philosophical / ideological basis of the ToR of Food Wise 2025 should be open to challenge. A 4.5% growth rate per annum (KBC prediction for Ireland for 2015) means that economic activity needs to double every (approximately) 16 years – 100 years of such growth would necessitate an economy 80 times greater than the current one – this has massive implications for sustainability - so much so that the whole premise of “sustainable intensification” needs to be questioned. Extending the growth to 200 years from now would require an economy 6656 times greater than the current one. 300 years of such growth would result in an economy over 500,000 times greater than the current one. Is that the challenge / legacy that we want to leave to future generations? Having to generate half a million times more economic activity a year than we do? Should that root of thought be the base for any future planning? Yes, the math is correct – if you don’t know this and you champion economic growth you clearly haven’t thought it through. 300 years may sound a long time but in terms of human history it is the blink of an eye; just a few generations. Admittedly the plan is only for the next 10 years but at what point is it envisaged that growth will need to stop or be regulated? In natural systems significant growth is associated with juvenility, with immaturity. When are our economic systems going to recognise this and grow up?
The mantra that economic growth is good is rarely challenged, but what happens when the irresistible force of perpetual economic growth meets the immovable object of finite resources? The answer, according to Food Wise is “sustainable intensification”.
Why is “growth” the vision? Given the stresses that the natural environment is under why isn’t the vision for “sustainability”? The argument that we have to feed a growing world population doesn’t stand up – this Strategy is targeted at making money from growing (potentially unsustainable) middle class markets in developing countries, not feeding the impoverished.
“The current food system provides enough food for 10-12 billion people, but the food system is failing due to losses, waste, poverty, regulations and distribution issues. “ Compassion in World Farming
If this is correct then the need for intensification bubble is burst: The mantra of “sustainable intensification” used in the context of modern western farming systems needs to be challenged for what it is – a refusal to challenge old values, the old addiction to the need for growth.
We are confusing means with ends. Economic growth is not an end in itself. Meeting the full range of human needs in a way that is harmonious with the natural systems of which we are an intrinsic part is an end. Economic activity is necessary but economic growth (from the point at which we are at) may or may not be a means to that end. It may be an obstacle. It’s validity in this situation should at least form part of the discussion and not be assumed. Garnett & Godfrey’s (2012) paper is a useful precursor to this discussion.
If the ToR are unsound then the strategy is likely to be stained the same way.
Although “environmental protection and economic competiveness will be considered as equal and complementary, one will not be achieved at the expense of the other” the overall framework and tone of the strategy is economic. This strategy is written from the perspective of how the economy can grow and be sustainable not how society can be sustainable and then develop. All aspects of the human economy are, directly or indirectly, dependent on nature and natural systems. Nature is not dependent on there being a human economy.
Promoting a concept does not automatically translate into an achieved implementation. Saying that you are going to be sustainable is not being sustainable.
What guarantees will the agri-food sector give?
If this strategy is adopted there needs to be a very clear method put forward as to how the industry will underwrite the sustainability aspect of the strategy. Without this, industry, using financial and technical support from government and its agencies, will have a free bet at achieving economic targets without any risk of penalty should it fails to meet the sustainability metrics. Who will pay if the environment is compromised?
Are the “right attitudes” in place, we fear not. It is going to be very hard for this strategy to achieve its stated goals without environmental compromise.
Challenge to the structure of the Committee
Given the wider framework of the strategy one would have to question the balance of the composition of the steering committee. If the intention of the initiative is to produce a plan that is complementary in terms of economic, social and environmental factors why is the Committee guiding the project overwhelmingly weighted in favour of economic interests? There is no representative from a Sustainability body on the committee and limited representation from the environmental and social sectors. The talents of the people on the committee need to be balanced by the talents of others who better understand issues of environmental and social concern.
If balanced development is to be anything more than rhetoric we consider it essential that environmental / social / sustainability interests should be more strongly and meaningfully represented on the Food Wise committee and on the boards of agri-food industry companies and on state sector bodies, like Bord Bia.
Challenge the contradictions
“A guiding principle to meet these sustainability goals will be that environmental protection and economic competiveness will be considered as equal and complementary, one will not be achieved at the expense of the other. “ FW P.24
On the same page the report talks about maximising production efficiency whilst “minimising the effects on the environment and declines in biodiversity”. This is the language of mitigation and concession rather than genuine sustainability; damage limitation rather than developing systems of production that integrate social and environmental needs from the outset. This language is a constant theme throughout the Strategy and DER. It is indicative of the system of conflict between people and nature that is the result of many current agricultural practices. The two quotes above are from the same page of the strategy; they are symptomatic of the inconsistent thinking that underlies this report. It leads to a Strategy that constantly talks about reducing negative impact rather than balanced development or enhancement.
Statements in the report are in contradiction to other state sector reports on the issue of sustainability.
“The sustainability credentials of the sector must continue to be measured and benchmarked to underpin their validity and ensure that these credentials can continue to be enhanced, underwritten by strong records and data. “ FW P.24
This would appear to be in conflict with this statement from the Teagasc report Measuring Farm Level Sustainability with the Teagasc National Farm Survey (2013)
“there is currently no national scale assessment to provide data for a national-scale benchmark of the ecological quality of farming systems in Ireland.”
Sustainability includes ecological sustainability. How can the authors claim a continuance of measurements that apparently don’t exist?
Challenge to the lack of evaluation of previous Plans
FW claims to be “building on the progress achieved under Food Harvest 2020”. We are not aware of any evaluation that has been undertaken in regard of Food Harvest 2020, in particular in terms of its success or otherwise in terms of environmental / social sustainability. Let us see a thorough evaluation of Food Harvest 2020 before claiming progress.
Challenge the Reasonable Alternatives
Are the Reasonable Alternatives considered those as defined by industry or by wider interests? They look biased and restricted from our perspective. Of all the possible scenarios the fact that these are the ones selected and presented needs to be challenged.
Why is there no Base Case presented that just looks at making current practices more sustainable – why does growth have to precede attempts to be sustainable? This may be an industry requirement but not necessarily a societal one. Given that the strategy is extensively export driven alternative scenarios that are cognisant of the potential volatility in international affairs should also have been considered. A model (supported by the UK Foreign Office) developed by a team at Anglia Ruskin University’s Global Sustainability Institute, shows that our current way of life appears to be unsustainable and could have dramatic worldwide consequences leading to global social collapse by 2040.
The key factors are based around climate change, water stress, ongoing globalisation and heightening political instability. Given this, is building the Irish agri-food economy around exports a wise approach? Perhaps an alternative scenario based on local, regional and national food security should form the basis of an alternative.
Food Wise appears corporate driven with corporate goals – there are alternative visions for the future of the agri-food sector which should be considered as reasonable alternatives.
Challenge to some of the details in the Reports
There are numerous unsubstantiated claims or unattributed statements in the Food Wise 2025 (FW) document and the DER. Some examples include:
“Feeding a world population of 9.1 billion people in 2050 will require increasing overall food production by some 70 percent by 2050 from 2005 levels. “ FW P.17
This statistic is unattributed and needs to be challenged. One third of all the food produced every year, approximately 1.3 billion tonnes is wasted (Stuart, 2009). This issue is not addressed in the DER.
“This is due to the sector’s capacity to produce high quality, safe, nutritious foods and products in an environmentally sustainable manner while at the same time delivering economic growth in rural areas and coastal areas.” P23 FW
The sector has not demonstrated a capacity to produce in an environmentally sustainable manner – no evidence is presented to support this statement. The report goes on to say that the Irish agricultural sector faces “significant challenges in meeting some national and international environmental targets for air quality, biodiversity and water quality” which is somewhat contradictory given the earlier claim.
“Overall the draft Agri-Food Strategy 2025 is found to have a positive or imperceptible effect on landscape. “ DER P.22
There is no substantiation for this other than that new afforestation is regulated for its impact on landscape character. We would contend that the proposed strategy has the potential to impact significantly on the landscape – most notably the increase in the dairying sector which could result in more re-seeding of grassland (reducing grassland biodiversity and producing a more homogenous grassland landscape - a reduction from 40 Shades of Green), more intensive management / restructuring of hedgerows, etc. We find the assessment in this area of the plan to be superficial and lacking in rigour. To suggest that limited change in land use patterns will mean a limited impact on the landscape is to profoundly misunderstand ecology. How things are done impacts on the landscape, physically and ecologically.
“The sustainability credentials of the (agri-food) sector must continue to be measured and benchmarked to underpin their validity and ensure that these credentials can continue to be enhanced, underwritten by strong records and data. “ FW P.24
“continue to be measured and benchmarked” suggests that all sustainability credentials are currently being measured. Sustainability credentials (and their metrics) must be defined by all parties to the process including the social and environmental. We do not believe this to be the case so we consider this to be a flawed statement.
Other comments on the Strategy and DER
“These production methods ensures the highest quality safe raw materials are produced for export to markets around the world while doing it in a more environmentally efficient manner than production systems used in other parts of the world. “ FW P.24
Being more environmentally efficient than other production systems is not the same thing as being sustainable. Being less intoxicated than your drinking partner doesn’t mean that you are sober.
“If Ireland wishes to remain a world leader in the production, management and marketing of low-carbon, high quality sustainable food, then significant efforts will be required to maximise production efficiency whilst minimising the effects on the environment and declines in biodiversity.” FW P.24
Sustainability is not about minimising effects, minimising effects is damage limitation, which is not a guarantor of sustainability. Production efficiency that damages nature is not efficient at all. Production efficiency cannot be evaluated without consideration of the wider context in which the production takes place; this is superficial, de-contextualised thinking. Too often industry is claiming to be efficient when all it is doing is passing on its inefficiencies for society and nature to deal with. Production efficiency that targets resources can be beneficial but production efficiency that tries to maximise output from an area leaving nothing for nature is a form of totalitarianism. No wildflowers, no weeds, no “pests”*, no grain going spare for nature. This type of production efficiency is antithetical to the sustainability of natural systems. “Production efficiency” is the outdated language of thinking that has gone past its Best Before date.
“For naught so vile that on the earth doth live But to the earth some special good doth give.” William Shakespeare
“DAFM to work closely with responsible agencies to monitor potential localised/regionalised impacts of dairy herd expansion on water quality and to develop mitigation measures, in conjunction with the scientific findings from the Agricultural Catchments Programme. “ FW P.27
The impact of the expansion of the dairy herd should be examined across the full range of environmental and social parameters not only in terms of its impact on water quality; particularly some of its “production efficiencies” should come under scrutiny.
“The strategy proposes an action plan under 18 headings with the object of increasing the dairy industry’s sustainability through technical improvements at farm level; increased research and knowledge transfer; and structural reforms at industry level. “ DER P.14
What is increased sustainability? This is a term that requires clarification. Sustainability is not something that has a unit of measure that can be increased or decreased. “Increased sustainability” is really a euphemistic way of saying that the dairy industry is currently not sustainable without directly admitting it.
“This will require continued investment in monitoring systems, investment in science based research which demonstrates that Irish production systems are environmentally sustainable. “ FW P.24 / DER P.33
The objective of scientific research is to test a hypothesis. Investing in research to demonstrate a predetermined position is not a proper application of scientific method.
If Irish production systems are environmentally sustainable then there is no need for research - produce the research evidence that backs up the statement. If Irish production systems have not been proven to be environmentally sustainable then research is required to test the hypothesis that they are sustainable. We would be very concerned if the above statement is indicative of the level of understanding of scientific method underpinning this Strategy and Environmental Assessment. Is it going to be a case of proving that Irish agriculture is sustainable – whether it is or not?
Table 9-2 of the Environment Report shows the results of the SEA assessment on the sustainability actions contained within Chapter 4 of the draft Agri-Food Strategy 2025. Items 2 and 7 (Monitoring and Research Prioritisation) indicate positives in a number of environmental criteria. Monitoring and Research Prioritisation do not result in environmental positives per se. It is only when the results from these actions are appropriately acted upon that positives should be counted.
The Report does not address the possibility that the targets of the Plan may be inherently unsustainable and that mitigation of negative environmental or social consequences may only be achieved by compromising the targets of the Plan itself.
“At farm level, farm reorganisation is likely to be subject to EIA and removal of hedges from the landscape is prohibited under the basic payment system. “ DER P.75
The HLAI strongly object to the inclusion of this sentence in the report as it is inaccurate and misleading.
The statement needs qualifying – hedges can be removed provided an equivalent length of hedgerow is planted on the holding prior to removal. There is no requirement for equivalence other than length. A high quality, species rich, ancient hedgerow connecting other natural or semi- natural habitats can be replaced with a monoculture of imported plants with no semi-natural links providing it is of equal length. No inspection of the hedge prior to removal is required to see what is being lost. The potential for landscape and ecosystem degradation is obvious. The notion that the hedgerow landscape is protected if hedgerow removal is prohibited fails to understand the complexities of hedgerow conservation.
SEO’s
From Table 2-1
“Protect, and reduce risks to, human health. “
A balanced and sustainable Strategy should have the target of enhancing human health – once again this is the mindset of mitigation rather than integrated thinking. All of the SEO Indicators relate to physical qualities; some assessments of the impacts on mental health need to be built in to the indicators, especially the mental health of farmers and their families. The well being of farmers, their families and rural communities should be at the heart of the vision of a genuinely Wise strategy, not an unguaranteed bi-product.
“Maintain and improve general biodiversity“
The reference to the improvement in general biodiversity is welcomed. However, the quality of design and implementation of agri-environment schemes and greening measures will determine whether biodiversity objectives are underpinned. Environmental groups have repeatedly expressed concerns over the effectiveness of these initiatives as currently implemented.
“Control and Reduce GHG Emissions“
The SEO Indicator fails to take in to account the balancing sequestration of greenhouse gases from agricultural features such as hedges, scrub and non-forest trees. A cross sector review of Bord Bia’s Carbon Navigator tool is required.
“Do not increase flood risk or reduce resilience to climate change impacts“ A balanced, sustainable strategy would be looking at how agriculture can be reducing flood risk and increasing resilience to climate change. Strategically positioned and appropriately managed hedges and trees can help in this regard whilst contributing to a reduction in GHG emissions – integrated thinking.
“Protect, maintain and improve soil quality, quantity and function by promoting sustainable agricultural practices“
The Objective is to “protect, maintain and improve” but the Target does not reflect this being only concerned with avoiding negative impact. The SEO indicators for Soil Quality are superficial and need to be reviewed by soil scientists.
“To minimise the effects upon the sustainable use of land, mineral resources or soils“
Where to start on this one? How is this Objective, as stated, consistent with the sustainability philosophy of the Strategy? Surely the Objective should be “the sustainable use of land, mineral resources or soils”. The Target is flawed and the Indicators are superficial. The true colours have shown through the rhetoric here.
“Protect cultural landscape features“
The SEO indicators are inadequate.
“Restricted hedge removal BPS“
The reduction in hedgerow quality through inappropriate management needs to be considered, as does the long term loss of hedgerow through abandonment of management. A more suitable monitoring indicator would involve the use of the Condition Scoring element of the Hedgerow Appraisal System.
“Increase the area of land under agri-environmental management“
This is subject to the same comments regarding quality of design and implementation as above. If the Rural Environmental Protection Scheme is used as an example then, in our opinion, a decrease in area would offer more protection from a hedgerow perspective. Given the spend all A-E Schemes have provided very poor value for money in terms of hedgerow conservation in our view: Partly through poor design, but largely through poor implementation (lack of standards) and monitoring.
“Minimise impacts on broader landscape features (protect, enhance and manage the distinct identity, diverse character and special qualities of Irish landscapes) “
We find this Objective confusing. Is it about minimising impact or landscape enhancement? The Objective refers to broader landscape features but the Targets seem to be restricted to seascapes / coastal areas and designated areas. Targets for the landscape of the wider countryside and urban areas should also be set. It is unclear to us how the LA Landscape Character Assessments can act as a SEO Indicator. Some clarification is needed on this.
Mitigation Measures
We have not had time to review this section but a preliminary reading suggests that the problems lie with the foundations not the furniture.
Animal Welfare Intensification of agriculture has involved treating many species of animal as commodities. We suggest that Compassion in World Farming should be fully consulted on any aspect of the Strategy that has implications for animal welfare. We suggest that there should be a place on the Steering Committee for a representative from CIWF.
Monitoring
The composition and terms of reference of the Environmental Sub Group to be convened under the monitoring proposals should be approved by the Environmental Pillar of Social Partnership.
In Table 7-1 for a number of categories there is a complete lack of consistency between the Issues, the Indicators and the Monitoring. It is so flawed that it would take too much of our time to highlight all of the inconsistencies. This whole section needs a complete overhaul. There appears to be no specific monitoring of biodiversity for any of the categories despite it being mentioned in the Issues for virtually all of the categories.
Pollinators Given that pollinator species are vital to the sustainability of many agricultural production systems it is disturbing, given concerns over pollinator populations, that there is no mention of pollinators in the Strategy and only limited reference in the DER. This issue needs to be very specifically included in the monitoring.
Origin Green
Since many of the actions of the Strategy require uptake of the Origin Green programme we feel that is relevant that the Origin Green programme is put under some external, independent scrutiny.
Genetically Modified Organisms
Although there is no overt reference to the use of Genetically Modified Organisms (GMO) in the Strategy there is a strong undertone of the use of programmes for genetic improvement. Since there is no statement precluding the use of GMO’s the fact that the DER makes no reference to the potential environmental impact of the use of Genetically Modified Organisms is a serious omission.
Challenge to the general use of the term “Grass-based livestock production systems”
The terms “Grass fed” or “grass based” production systems are used frequently in both reports as an example of Ireland’s inherent sustainability and competitive advantage. Grassland is a single term that covers a wide range of types. There is a wide variance in the inherent sustainability of different grass-based systems from low input extensive systems on species rich grassland to high input intensive systems using grass monocultures and a SEA that does not recognise this lacks rigour. In terms of fossil fuel energy usage, above and below ground biodiversity, animal nutrition these systems differ and this needs to be acknowledged, analysed and the implications considered in the DER.
Grass fed systems are stated as allowing production
“in a more environmentally efficient manner than production systems used in other parts of the world.” FW P24
It should be reiterated that being more environmentally efficient than other production systems is not the same thing as being sustainable.
Maintaining land under “permanent pasture” is a SEO indicator for “greening”. In light of the above comments on grassland types there needs to be much more differentiation of the “greening” potential under the heading of “permanent pasture”.
Fossil Fuel Dependence There is no reference in the DER to the dependence of agriculture on fossil fuels; there is reference to volatility of fuel prices but that is not the same thing. The infrastructure of society is built on a resource that is being consumed over a period many, many times shorter than the time that it took to be produced and that won’t be around in current quantities for ever. This is inherently an unsustainable system. Any plan or environmental analysis than purports to have sustainability at its heart needs to address this issue.
Recommendations
There needs to be more balanced representation (environmental, social and sustainability) on the committee of the Strategy and within the Agri-Food Industry in general. There needs to be a complete review of the SEO Objectives, Targets and Indicators with final agreement coming from all pillars of social partnership. There needs to be a complete review of the Monitoring proposals. The composition and terms of reference of the Environmental Sub Group to be convened under the monitoring proposals should be approved by the Environmental Pillar of Social Partnership Sustainability metrics need to be defined and agreed by all pillars of social partnership. Any knowledge gaps in these metrics need to be addressed with immediate effect in order to set the requisite benchmarks without which it will not be possible for the industry to substantiate any sustainability claims. A cross sector review of Bord Bia’s Carbon Navigator tool is required. A full independent evaluation of the objectives and operation of the Origin Green programme should form part of the monitoring of the Strategy. The issue of agriculture’s dependence on fossil fuels needs to be addressed in the context of sustainability. The selection of the “Reasonable Alternatives” considered needs to be reviewed from a wider perspective than that in the DER. A mechanism must be developed for how industry will underwrite the sustainability aspects of the strategy.
Conclusion
In short we consider that the Food Wise 2025 strategy is based on an ill considered philosophy, contradictory ideas, unsubstantiated claims, an unbalanced process and a lack of rigour in terms of environmental assessment.
There has to be more to this Strategy than sustainable rhetoric. The underlying thinking, the mindframe needs to change.
“The true system, the real system, is our present construction of systematic thought itself, rationality itself, and if a factory is torn down but the rationality which produced it is left standing, then that rationality will simply produce another factory. “ Robert M. Pirsig
The Food Wise Strategy is conflicted. The drive for perpetual growth is in conflict with the sustainability of the systems of nature on which we depend. The constant reference to mitigation is an admission of this but the circumscribed rationality that is behind this Strategy does not have the scope to devise a consistent solution, so we are left with “sustainable intensification”. Trying to eat your way out of obesity is an unlikely route to health. There needs to be wider context brought to the thinking of this process; different voices need to be listened to, different ideas aired, different approaches developed - a different vision. Although this is just a 10 year strategy it has the potential to impact well beyond that timespan. Getting it right is important and for this to happen the Agri-Food Sector needs to break out of its insularity and connect with others to bring some wider perspective. The Strategy itself lacks character, it lacks passion and joy for life, it is spiritually hollow*; the underlying framework of thought is narrow and inconsistent. The Food Wise Report reflects the bad end of the agri-food sector – dressing up and bulking up cheap, unhealthy ingredients in fancy packaging, giving the product an eco-friendly name and developing the marketing spin.
Wisdom is one thing that does not shine through in Food Wise 2025.
* compare it with the recently circulated Draft Waterways Ireland Heritage Plan, which contains all of these qualities
References
Stuart, T. (2009). Waste: uncovering the global food scandal. Penguin Books, London.
Garnett T and Godfray C (2012). Sustainable intensification in agriculture. Navigating a course through competing food system priorities, Food Climate Research Network and the Oxford Martin Programme on the Future of Food, University of Oxford, UK