In September 2006 the European Commission published the Thematic Strategy for soil protection, including a proposal for a framework directive and an impact assessment, IFA supports a Thematic Strategy for soil protection. However, the Association considers the requirement to implement a soil directive as excessive because there is a wide range of measures existing under the Common Agricultural Policy (CAP) as well as under European Environmental Legislation that will bring about benefits for soil protection. IFA considers the introduction of a soil directive as a duplication of existing environmental legislation which would create confusion and be contrary to the simplification philosophy of the European Commission. Furthermore it will undercut the competitiveness of the European Farmers and Foresters.
Over 70% of all Member State environmental legislation already comes from the European Parliament. IFA reject a proposed soil framework directive for the reasons outlined below.
1. An EU Strategy for the protection of soils should be holistic and linked to CAP and existing environmental legislation. A specific soil directive is not necessary.
A wide range of measures exist under the reform of Common Agriculture Policy (CAP) as well as under environmental legislation, which will bring about benefits for soil protection. These include:
CAP decoupling – Ireland as a fully decoupled Member State now allocates land use and inputs based on market demands. Cropping patterns and grazing densities are now more flexible.
CAP cross-compliance – Since 2005 the recipients of the single farm payment are required to meet basic standards in respect to soil erosion, organic matter and structure across the entire farm. The detailed on-farm inspections carried out annually can result in significant financial penalties for farmers who breach these standards.
Soil inspections carried out by the Department of Agriculture, under the Good Agricultural and Environmental Condition Inspection Report include:
Minimum Level of Maintenance of Soils
CAP farm advisory system – Farmers awareness of environmental requirements will increase significantly because under the CAP reform requirements Member States are required to provide advice on key regulatory requirements including the protection of soil.
IFA believes that any additional soil protection legislation should only be considered at European level after the effectiveness of existing policies, incentives and legislation for the delivery of soil protection are clearly understood and evaluated in line with the European Commission’s objective of good legislation. Therefore IFA call for an increased simplification and co-ordination of existing legislation.
2. Subsidiarity must be fully respected considering the great diversity of soils in the EU.
The universal implementation of a standard Europe wide framework Directive would not fully consider the diversity of soil types and conditions, climates, land uses, administrative systems and policy priorities across Member States.
There is enormous variability of soils across Europe. Soil conditions are dependent on several factors linked to a national or local context. IFA stress that a strategy should provide headline objectives while issues at a local, regional or national level should be addressed at a national and/or regional and local level in accordance with the principle of subsidiarity.
Current good farming practices play an important role in maintaining the quality of soil and counteracting soil degradation in Ireland and the EU. The reformed CAP will ensure soil protection in agriculture through its requirements for wide-ranging good agricultural and environmental practices, which target the maintenance of soil organic matter, and good soil structure in an effective way.
Farming and soil management share a symbiotic relationship. The capacity of farmers to protect soil, and contribute to its improvement, is related their competitiveness, income and the economic viability of their businesses.
IFA rejects a proposed soil framework directive because it would simply mean increased bureaucracy, the duplication of regulations and consequently additional expenses without bringing about any additional improvement in soil protection.