Strategic Environmental Assessment of the Draft Rural Development Programme (RDP) 2014 - Public Consultation Response Shannon Fergus Islands ...

Strategic Environmental Assessment of the Draft Rural Development Programme (RDP) 2014 -
2020.

Public Consultation Response

Shannon Fergus Islands Group.

As invited, I wisii to make a submission to tiie Draft Rural Development Programme 2014 - 2020 on
the challenges island farmers face with regard to their viability and the high infrastructure and
transport costs and the need for greater financial support so that island farmers are treated fairly and
equitably in the implementation of the Rural Development Programme 2014 - 2020.

Uninhabited Offshore Islands where farmers commute to their farm on an Island which always
requires a boat to access the island as there is no public ferry option at any time. 980 Island Farmers
get SFP, of those 390 farm on populated with ferry services, some of the others have causeways
which allow access for certain period. A l l islands have viability issues but some are more severe than
others.

This Submission by the Shannon Fergus Islands Group puts the case for support to the islands of the
Fergus Estuary. This group commissioned a L E A D E R supported Business and Tourism Feasibility
Study in 2013.

"The overall aim of this feasibility study therefore, has been to undertake research of the broad
tourism and agricultural sustainability of the islands while identifying how best to deliver the vision,
taking account of physical access limitations and environmental designation." PHT C O N S U L T A N T S
(*)

There are 13 islands in the Fergus Estuary greater than 2ha. Five of these islands can be reached by
causeway for a period most days depending on the tide. The remaining 8 uninhabited offshore islands
vary in size from almost 5ha to 187ha one of the islands (Canon Island) is in danger of abandonment
while the remainder are actively farmed. The islands became uninhabited through the isolation and
lack of support for island families in the transport and education field where families had no choice
but to relocate to the mainland but still continued to access their farmland daily. This is in sharp
contrast to the present situation whereby inhabited islands have a ferry service currently support rate
€5m+ to ensure safe access to the offshore populated islands. No support is available for these (8)
offshore island to help farmers mitigate their access difficulties in their struggle to retain a farm
income equal to that of their mainland colleagues.

Inputs island extra costs and Limitations. The present timber cattle/goods boats owned by the farmers
has a limited carrying capacity of 4/5 tonnes. This limit rules out the use of ground limestone, sand
and gravel, concrete, bulk feedstuff, fertilizer, fuel, agriculture contractors. No on farm deliveries of
any input is possible.

Island extra Labour costs. Skilled labour to work with boats is dependent on family members'
availability as non island workers don't have the experience necessary to safely work in this
environment. Skilled labour to work on any project on the island is more expensive than mainland
rates plus the hourly rate starts when one leaves the mainland and finishes when they arrive back.
Professional Vet fees for visit to island are twice the cost of a mainland callout.

Island extra utilities costs. No electricity. Water supply on three islands only and Island farmers have
to take full responsibility for all pipe work (installation and maintenance) from a metered point on the
mainland across the estuary to the island and around the farms. Other islands have to find water on
site for livestock.

Island extra insurance costs. Marine insurance is very expensive and our boats and landing
infrastructure would need to be up graded to meet their requirements. This results in farmers only
carrying their own goods on their own boat to prevent any claims on their property.

Island extra time cost Work time on these islands with poor infrastructure is influenced by tidal and
weather conditions. Carriage of goods to the islands is limited to a two hour period for 6 days per 2
week cycle between the hours of 6 to 10 (am and pm) in daylight hours which always includes
weekends. Farmers also maintain their own boats in an effort to reduce monetary costs. A l l boat work
with regard to inputs/outputs is a further drain on time available for farming.

Island choice of farm enterprise. Enterprise choice is limited as access difficulties only suits livestock
or sheep farming.

Farm enterprise Island effect on farm viability and sustainability.       Time spent on mitigating the
effects of island farming results in reduced time for farming enterprise and consequential losses in
productivity. Transport restrictions results in island farmers not being able to avail of grant aid on any
farm buildings schemes including winter housing thereby reducing their overall stocking rate.

Addressing the viability and sustainability of uninhabited offshore islands is complex and we need to
be in a position to be able to avail of all the support structures available to the Department. One only
has to look at the inhabited islands where the access issues have been addressed to see there are still
issues of profitability versus mainland farms. This supports the argument that, as farmers from the
uninhabited islands, we are the most disadvantaged group falling way below ever the disadvantaged
farmers on inhabited islands.

Many studies have been carried out on the most cost effective method of addressing the problem of
access on inhabited islands and the need for funding both capital costs and running costs. A l l would
agree that this would be non-productive investment which is allowable under Article 17 (4) E U
1305/2013. Productivity per Ha per labour unit on island farms is never going to match sinular size
farms on the mainland so the way to rebalance is by way of a higher livestock payment under Article
33 (3) E U 1305/2013.

 Long term sustainability of island farming is dependent on young farmers' willingness to take on the
challenge of island farming. Support structures here have to match the greater challenge of all farming
locations and the need to support that fact with a higher offshore island top up for young farmers.
Article 7 (3) E U 1305/2013. Agricultural education needs to be coupled with an understanding and
respect for the sea and the challenges it presents. This local expertise and knowledge is normally
handed on through the inter-generational activity of the island family support structure which is so
necessary for continued survival of the offshore island family farm.

This family activity in support of the island farm needs to be encouraged otherwise vital skills will be
lost to the area which are not easily replaced. The inclusion of the Island farm family in suppoit
structures greatly increases the chances of success in dealing with isolation, viability and land
abandonment issues.

The pull factor of the island family farm is currently used to fill skill gaps at weekends when tidal
conditions are suitable for transport requirements. Many family members work away from the area
and as a result the opportunity should be there to allow support payments to these members as they
may come back to live in the local area and their skills and knowhow both new and traditional could
benefit the island viability. This could be allowed up the age of 35 at which time assessments maybe
carried out as to benefits of the supports and decisions made on future funding commitments.

(*) Shannon Fergus Islands Business and Tourism Feasibility Study.

Available at www. cldc.ie    Clare Local Development company.

 A hard copy or soft copy is available if required from email address below.

Seamus Murphy

Chairman Shannon Fergus Islands Group.

sfislands @ gmail .com

04/06/2014

S E A of the draft R D P 2014 - 2020 public consultations.

                               Shannon Fergus Islands Group.

                Additional support material for submission dated 04/06/2014

 The islands are all within the S A C 002165 designated area and also surrounded by S P A
4077 designated area. This Natura 2000 area is very much dependant on island farmers
continuing to farm these islands a fact which is recognised under E U 1307/2013 Article 5
"Union priorities for rural development" 4 "(a) restoring, preserving and enhancing
biodiversity, including in Natura 2000 areas, and in areas facing natural or other specific
constraints, and high nature value farming, as well as the state of European landscapes."

This additional information also includes costs of a ferry service to the islands with extracts
from the study. The costs of developing a ferry service to meet the agricultural requirements
of the local islands was quantified in the Shannon Fergus Island Business and Tourism
Feasibility Study Final report February 2013. This study researched the possibility of future
development of the islands and quantified the transport costs involved. The overall costs per
annum with insurance excluded came to €76,000 (depreciation 15,000, Fuel 8,000,
Maintenance      8,000, Wages 40,000 & Pier charges 5,000.)           Revenue f r o m Tourism
passengers would come to €31,000 with agriculture (regular transport of milk from one
island) transport needs set at €17,500 and other cargo runs including agricultural needs of
other islands at €35,000 as these islands are further away and sailing times would be tide
dependant. Total sales for 2012 of livestock from all the islands was 346 cattle and 180 sheep
which would have to finance the remaining costs would come to €129 per head on cattle
sales and €43 per head on sheep for transport costs alone where no public funding is available
for island transport. Harbour / piers and slipways would also have to be upgraded; the study
estimates a cost of €800,000 for these works. These figures quantifies the disadvantage these
islands have when compared with other islands which have grant aided transport services.
The above figures underline the cost of transport only to uninhabited islands.

It clearly be seen that farming uninhabited islands with Natura 2000 designations is not
sustainable without supports which address the issues raised in our submission.

Seamus Murphy

Shannon Fergus Islands Group.

16/06/2014

The following support material is taken from the feasibility study on these islands.

 PHT   CONSULTANTS
Final Report P a n 2
 19

6.3.4 Crovraghan Passenger Boat Service

Whilst a large vessel would provide the link between Rosscliff and Deer Island, we
propose that all other passenger crossings to the islands would be undertaken by
smaller sized faster craft, as exampled earlier within this section. The two
proposed vessels are already providing successful passenger services elsewhere.
The 12 seater 'Ribcraft Boat' provides services off the west coast of Scotland as
well as in the Shannon Estuary, and when fitted with all the necessary safety
equipment for passenger operations and twin outboard engines, it would run at 8 -
10 knots with a small draft. A crew of 2 persons is proposed on this vessel though
it may be possible to have approval for single manning. The boat is available in
covered or open versions and the capital cost is between €80,000 and €100,000
according to specification. Its first M C A covers 3 to 5 years and after that it may
require low cost regular surveys that do not take the vessel out of service. Running
costs depend on the speed when operating but we are advised averages around
€30 - €40 per hour plus the crew costs.

The alternative boat we have illustrated is the 'Pioner Multi Boat' which can carry
up to 8 passengers. This has a bow door for easy access when landing on
beaches, and can withstand such landings without damage. Maintenance costs are
low and the M C A certificate will initially be for 4 years after which on-going
inspection is required biannually. The capital cost would be about € 50,000/€
60,000 when fully equipped with a 70 HP outboard. Operating costs are about €20
per hour plus crew costs, although it is anticipated that single manning would be
approved.

Indicative Operational        Timetable

As an indication we have set out the sort of timetable which could be deployed to
enable a 2 boat operation providing a timetable programme of boat trips to the
islands. This is based on a 22 week summer operation which could provide a
regular service and be sufficient to test the market.

Daily
Crovraghan depart 9:30 16:00
Coney arrive 10:00 16:30
Coney depart 10:30 16:30
Crovraghan arrive 11:00 17:00 T O T A L 14 return trips per week (308)
Daily Tuesday/Thursday
Crovraghan depart 10:30 13:45
Canon Island arrive 10:45 14:15
Canon Island depart 12:15 16:15
Crovraghan arrive 13:15 16:45 T O T A L 9 return trips per week (198)
Mon - Wed - Fri - Sat Sunday
Crovraghan depart 13:30 Crovraghan depart 11:00
Horse Island arrive 14:00 Low Island arrive 11:30
Shore Island arrive 14:10 Low Island depart 16:00
Shore Island depart 15:20 Crovraghan arrive 16:30
Horse Island depart 15:30
Crovraghan arrive 16:00 T O T A L 5 return trips per week (110)

PHT CONSULTANTS
Final Reporl Pari 2
20

The above schedule would allow full and short day trips to Coney Island. Deer
Island trips could also include short and full day excursions and additional trips to
Deer could also be operated from Rosscliff as indicated below. Canon Island
would have a daily service and an afternoon trip on 2 days that provides time to
visit the Abbey. Lowe Island would have a weekly sailing on Sunday allowing time
on the island. Horse Island and Shore Island would have a service on 4 days that
allows time to explore the islands. In total this would provide 616 boat trips over the
forecasted 22 week period. The proposed vessels would have ample capacity to
make additional special trips and to gradually expand schedules as required.

Operational Revenue Implications.•-

These annual revenue estimates have been established from discussions with
manufacturers and operators to provide an initial indicative guide for the proposed
SFI passenger service operating form Crovraghan. Estimates are based on the sort
of boats suggested above and the 22 week service indicated over the page.

Ribcraft 12 seater Pioner 6/8 seater
(300 hours) (200 hours)
Annual Depreciation €9,000 € 5,000
Fuel €12,000 €4,000
Maintenance €1,500 €1,000
Wages €6,000 €2,000
Pier duties €6,000 €2,000
€34,500 € 14,000

The operational costs for the proposed visitor passenger tourist service to the
islands would therefore total somewhere in the region of €48,500 per annum
including depreciation. It is estimated that the total revenue income generated over
the proposed 22 week summer period would be about €60,000 based on a total of say
616 trips at an average load of say 5.5 passengers per trip (Total Visitors = 3,388) and
an average €18 return fare charge plus landing tax. Insurance will depend on boat
and operator but advice suggests that these additional costs should be estimated at
between €6K -€10K per year. The nature ofthe operational business plan for boat
operation will vary according to the final details, but our assumptions suggest that
an above break-even trading position could be generated from such an operation.

ROSSCLIFF

Located close to Ballynacally, the
quay at Rosscliff provides the
closest and main local access point
for Deer Island. As identified within
our audit, the shoreline and
inadequate pier infrastructure
serves as the only available location
for the day to day backwards and
forwards agricultural access and
transportation of cattle between the
mainland and Deer Island.

PHT COiNSULTANTS
Final R c p o n Pari 2
21

We have proposed that Rosscliff should also be developed as a lower key
secondary visitor access point to Deer Island, but also being the location for a
larger landing craft type of vessel to enable more effective agricultural
transportation and assist the proposed milk product set out later in this section.
Rosscliff is approached from the main R473 road via a road and rough track leading
to the quay area, as illustrated on the following map.

ROSSCLIFF - MAIN ACCESS POINT TO DEER LSLAND

6.4.1 On Site Welcome and Visitor Information      Signage

Although it is proposed that Crovraghan serves as the main visitor destination as an
islands access point, there will still be a need for some very low key finger post road
direction signs pointing to Rosscliff from the main R473. In addition there will also a
need for providing visitor welcome and information signage on the Rosscliff quay
area to advise visitors about where to go and what to see and do on their visit.
Signs will also need to display passenger boat timetables to Deer Island and
costs etc. Budget cost: €2,500for design, artwork, manufacture and
installation.

Main Road Access

PHT C O N S U L T A N T S
Final Report Pari 2
22

6.4.2 Car Parking

The shore and quay area currently
provides limited parking for vehicles as
shown in the photograph. We would
recommend some low key
landscaping improvements to enable
increased space for accommodating
up to say 10 vehicles. A total budget
of €15,000 would provide a sufficient
sum for undertaking this work.
Low Key Car Parking Improvements

6.4.3 Landing Slipway

As indicated within our audit, Rosscliff
currently suffers from an inadequate
quay to accommodate the variations in
tidal water levels. The recommended
detailed survey should investigate the
potential for providing a new and
extended length slipway or road
arrangement as illustrated in the
photograph. This should provide
adequate landing arrangements for the
proposed larger boat described earlier
within this section. It is proposed that
this would facilitate both agricultural
and cargo use (including transport of
milk product) as well as supplementary
visitor passenger transport to Deer
Island.
There is also a private landing area at
Ballynacally Creek which could
perhaps serve as a supplementary
access point for agriculture use.

6.4.4 Rosscliff Boat Service

We have proposed a larger vessel to meet the need to transport tankers of milk
between Deer Island and the mainland as well as providing a supplementary direct
passenger service to Deer Island when required. The proposed vessel is an open
front access boat that can use simple sloping slipways for docking with a capacity
for 20 ton deck loading to enable farm machinery and transportation for all
agricultural needs. The boat would also have a 12 person passenger certificate to
provide visitor access between Rosscliff and Deer Island as required. We have
information that a second hand vessel could be secured at between €150,000 and
€ 200,000.

Potential for improved slipway road or extended pier

PHT CONSULTANTS
Final Report Pari 2
23

Operational    Implications

To provide some assessment we iiave based our operational appraisal on the
above larger sized boat operating 52 weeks a year to support agriculture needs,
with the visitor passenger services operating over the 22 weeks summer season,
and some occasional use during the rest of the year.
It is intended that the proposed cargo service would service the needs of the
proposed new dairy project on Deer Island - whose milk would require regular
transport between Deer Island and the mainland.
The Deer Island passenger service would also operate on a twice daily basis to
and from Rosscliff to Deer Island. In addition, working in conjunction with the main
Crovraghan passenger service, it could also make additional return trips per week
to other islands as required. Based on this usage we have assumed a total of 308
trips over the summer period. The boat could also provide cargo and agricultural
trips to other islands as required.

Operational Revenue Implications.•-

We have assumed the capital cost of the proposed vessel would be
€150,000 to €200,000. Our estimates for the annual operational costs are based on
the above usage to provide an initial guide for the proposed Rosscliff service. It is
estimated that in total this would amount to €76,000 pa including depreciation on
the purchase price of the vessel (ie. no grant). This is based on information
provided about similar operations elsewhere
Depreciation required say €15,000
Fuel € 8,000
Maintenance € 8,000
Wages €40,000
Pier charges €5,000
€ 76,000

It is estimated that the passenger revenue income earned over the 22 week
summer period resulting from 1,694 return passengers (based on 5.5 visitors
per trip at €18 + plus landing tax) would total say € 31,000. We have
assumed a total annual contract value for the regular transportation of milk
and other general agricultural needs would total €17,500. Other cargo runs
have been estimated at a total of say 100 trips based on a charter rates of say
€350 per day, equating to a total annual revenue of € 35,000. On this basis
total income generated from these activities would amount to €83,500 per
annum.

Based on our estimated operational costs of €76,000plus additional
insurance costs of say betyveen €6K - €10K per year, this would indicate an
above break-even trading surplus could be created. However, the nature of
the operational business plan for the boat operation will vary according to
the fmal details, but our assumptions suggest that an above break-even
trading position could be generated from such an operation.

Irelands draft Rural Development Programme                    2014/2020.

The Shannon Fergus Islands Group has taken an active part in and have made a number of

submissions    during the consultation     process    i n the Rural   Development     Programme

2014/2020' The draft Rural Development Programme (RDP) 2014-2020 ( D A F M , 2014) in

our view is not compliant with the Treaty on the Functioning of the European Union T F E U , ^

article 174 and 175, (Europa.eu, 2008) or The Charter of Fundamental Rights of the

European Union"', article 5(2) (Official Journal of the European Union, 2010).

Natura 2000 mandatory forced compliance!

The draft R D P 2014/2020, outhning the proposed structure of G L A S / G L A S + , highlights the

inequality in the system. A limit of €5000 /€7000 suggests that the fuU cost of compliance in

designated areas, w i l l be covered by this sum. However this is not the case, as the costs

quantified in the draft R D P 2014/2020, associated with compliance with Natura 2000, in

many instances are higher where multiple priority habitats/species exist in the one designated

area with consequential increased costs for farmers involved.

Compliance is mandatory and forced on farmers by penalties up to and including prison

terms, as stated in the draft R D P 2014/2020.        These actions are non compliant with the

Charter of Fundamental Rights of the European Union Article 5(2) stating that no one is to be

required to perform forced or compulsory labour. The E x - Ante Evaluation (Fitzpatrick

Associates, 2014)'' noted "the Principles of equal opportunities and discrimination prevention

received little discussion i n the R D P documents"

Inequality and unfairness of uninhabited island farming in a Natura 2000 site.

References in the accompanying Strategic Environmental Assessment Report suggest that a

low level of farm activity is best suited to designated areas. Regardless of designation, island

farming results in greater expense, expense that must be absorbed by the farm. The Draft

R D P document includes a €75 topup on A N C payments to uninhabited islands and twice that

amount for inhabited islands, this is unfair as access infrastructure costs on inhabited islands

are heavily subsidised f r o m national funds also some of this cost can be shared with other

users of the islands infrastructure. Uninhabited islands get no support; their costs cannot be

shared as there are no other users. A t present, all access infrastructure costs have to come

f r o m farming activities. N o recognition of extra costs on designated offshore islands where

farming is necessary for continued existence of Natura 2000 sites is included in the draft R D P

2014/2020. This increases the risks where abandonment w i l l remain the natural progression

for these islands.

The Draft R D P ex - ante evaluation includes extracts from the Commission Position Paper on

heland which makes a number of statements on the inefficient use of resources, including the

unfavourable conservation status of Irelands Nature 2000 sites. The Evaluation again flags

the shortcomings of G L A S / G L A S +       proposals in the draft R D P and includes specific

recommendations in this regard. The policy adopted by the department continues the policy

which under spent Natura 2000 areas funding in the R D P 2007/2013 period where a massive

82% of €528m allocated was not spent as of November 2013. Ireland's obligations under the

Habitats   and   Birds   directives w i l l   not   be   achieved. Equality and   fairness   in   the

implementation and adoption of E U directives and regulations at national level is a

fundamental right of every individual within the E U .

The Shannon Fergus island group believe that the draft R D P 2014-2020 w i l l not achieve the

objectives of the European Parliament and of the Council in our area.               The threat of

abandonment because of an insufficient response to the unique challenges this vulnerable

isolated group of island farmers have to contend with is very real, as they struggle with the

double disadvantages of island farming and farming in a Natura 2000 designated area.

^http://www.agriculture.gov.ie/ruralenvironment/draftruraldevelopmentprogramme2014-

2020/

^http://www.consilium.europa.eu/uedocs/cmsUpload/st06655-re01.en08.doc

^Official Journal of the European Union, 2010. Charter of fundamental rights of the European

Union 2010/C 83/02, p. 389-403.

''Fitzpatrick Associates, 2014. Rural Development Programme 2014-20 Ex-Ante Evaluation.

June 2014.

Seamus Murphy.

Shannon Fergus Islands Group.         sfislands@gmail.com