The Department of Agriculture has defended the targets and definitions it set out in Ireland’s draft CAP strategic plan in a letter delivered to the European Commission.

The letter was the Department’s first response to the Commission’s initial observations on the plan, which questioned the ambition of environmental aspects of the proposal.

The response began by firstly welcoming "very positive comments by the Commission on a number of elements" in the plan.

Also in its response, Ag House officials informed Brussels that redistributive mechanisms - the convergence of direct payments - had “particular and difficult impacts for a sizeable cohort of farmers”.

It was explained that payment redistribution was a “complex, multi-layered and sensitive issue in an Irish context” and that some smaller farmers with higher entitlement values could lose out, should balance not be kept in the redistribution debate.

It was also said that the Department would provide figures on the expected impact to farm payments of all proposed Pillar I changes combined.

Defending environmental targets

The Commission was told that further details on the environmental ambition of the draft plan would be provided over the coming weeks, with the Department stating that “fundamentally, our approach has been informed by the building blocks of the green architecture”.

The Department also acknowledged that some policy areas within the agricultural sector would be addressed outside of the CAP plan, such as the long-term sustainability of the dairy sector, which it said would be addressed under the Food Vision 2030 strategy.

These strategies and policies will complement the CAP plan and will be coherent with the measures proposed in the plan, the Department said.


The Department also stated that its commitment to environmental action could be seen in the higher conditionality standards it set in the plan, the intended provision of an eco scheme that would be open to all farmers and the potential of Pillar II schemes to improve the environment.

Minister for Agriculture Charlie McConalogue had reiterated his confidence in the proposed plan's robustness two weeks ago, after the Commission's response had been received.


The Department said that it appreciated the Commission’s acknowledgement that increasing the area under organic farming systems from 2% to 7.5% over the term of the new CAP represents ambition on this particular element of the EU’s green strategy.

“We will further reflect on the Commission's call for Ireland to consider a 'still greater' increase in this area, but I'm sure you will appreciate that this would present significant challenges for us,” Secretary General of the Department of Agriculture Brendan Gleeson wrote.