Irish Climate Justice Group Submission to the Department of Agriculture

Submission on Food Harvest 2020 strategy

The Irish Climate Justice Group is the name under which Oxfam Ireland, Friends of the Earth Ireland, Christian Aid Ireland and Trócaire cooperate on climate change policy matters.

The Irish Climate Justice Group welcomes the initiative to conduct an analysis of the environmental impact of the Food Harvest 2020 strategy (FH 2020) and to hold a stakeholder consultation. We believe an adequate Strategic Environmental Assessment would be more appropriate however. We note with regret that this analysis is being carried out two years after the strategy was launched and more than a year after government supported structures set up and an implementation strategy agreed. We were also disappointed to learn of the consultation late and by chance, rather than via outreach to stakeholders. We believe the procedural and outcome inconsistencies with FH2020 underscores once again the importance of establishing effective, transparent and accountable governance mechanisms, a climate change law in particular, that will ensure ex ante assessment ofproposed sectoral policies and their likely impact on Ireland's ability to meet its national and international obligations, not least its legally binding international obligations to significantly reduce its greenhouse gas emissions. This would ensure timely consideration of options and allow the adoption of coherent government policy that is consistent with its legal obligations.