Submission to the draft CAP Strategic Plan 2023-2027

In its submission to the Department of Agriculture, Food and the Marine on the draft CAP Strategy 2023-2027,the Water Forum welcomes the ‘Green Architecture’ outlined in the new CAP, which proposes to address the climate, biodiversity and environmental crises through the enhanced conditionality, the Eco Scheme Intervention of Pillar 1 and the range of climate/environment interventions of Pillar 2.

The members of the Forum held a number of meetings to discuss the content and how the CAP Strategic Plan could better address Ireland’s water quality; expertise and perspectives from a range of organisations and experts were shared and used in the development of the recommendations outlined in the Forum’s submission.

The Forum welcomes the proposal that “the underpinning principle for the (Pillar 2 AECM) scheme will be ‘right action in the right place’ in order to ensure effective targeting of measures to deliver biodiversity, water and climate action in an integrated manner on farms”. The Forum supports this proposal for targeted measures for optimum environmental outcomes, which is a significant improvement relative to previous AECM schemes of CAP.

The view of the Water Forum is that the national CAP Strategy would similarly benefit from the conceptual framework provided by the Forum’s  Framework for Integrated Land and Landscape Management (FILLM), as a means of optimising efficiency and effectiveness in achieving environmental outcomes for climate, biodiversity, water quality and soil enhancement. The Forum believes that while designing actions/measures to be included in the new CAP Strategy or assessing applications for various CAP interventions, that emphasis is placed on those with a range of co-benefits for water, climate, soil and biodiversity to maximise capacity and resource efficiencies (see Table 1, Page 20, FILLM report). The implementation of the new CAP will require cross-component planning where disciplines and organisations from multiple Government departments and agencies should work together in a co-ordinated manner to achieve climate and environmental targets.

A total of 27 recommendations were made in the submission across Pillar I and Pillar II interventions

Recommendations for Prioritisation within Pillar II AECM schemes:

  1. PAAs, where agriculture has been identified as a significant pressure, should be ranked highest within Tier 1 for priority access to Pillar 2 AECM scheme.
  2. The definition of ‘vulnerable water area’ currently proposed for Tier 2, should be “any water body where agriculture has been identified as a significant pressure”.
  3. The proposed ‘vulnerable water area’ eligibility criterion currently proposed for Tier 2, should be included within Tier 1 to allow farmers in these areas to get priority access to the AECM scheme, with additional priority given to those identified as having a critical source area (supported by EPA PIP maps).
  4. In addition to PAAs and vulnerable water areas, applications for AECM payments which propose measures with multiple co-benefits for water, soil, climate and biodiversity, should be prioritised for eligibility for the scheme.

Recommendation for Conditionality:

The Forum recommends there is greater emphasis on targeted measures within Pillar 1, such as consideration of spatially targeted buffer zones in poorly draining soils under GAEC 4

The full submission is available at:

Water-Forum-Submission-on-CAP-Public-Consultation.pdf (


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