Experts’ assessments of biodiversity options and supplementary measures in REPS 4 REPORT Authors Carlin, C.1, Gormally, M.1, Ó hUallacháin, D.2 and Finn, J.A.2 1 2 Applied Ecology Unit, NUI Galway Teagasc, Environment Research Centre, Wexford January 2010 This is a joint project between Teagasc and NUI Galway. Funding was provided under the National Development Plan, through the Research Stimulus Fund, administered by the Department of Agriculture, Fisheries and Food. 1 TABLE OF CONTENTS TABLE OF CONTENTS .................................................................................. 2 Executive Summary....................................................................................... 3 Key Messages 4 Introduction .................................................................................................... 5 Objectives .................................................................................................... 6 Effectiveness of agri-environment schemes ............................................... 5 Methodology: ................................................................................................. 6 Use of experts to estimate environmental effectiveness ............................. 6 Assessment criteria ..................................................................................... 7 Analyses ...................................................................................................... 8 Results .......................................................................................................... 10 Summary of experts’ discussion of individual measures/options .............. 10 Comparison of measures and options ...................................................... 33 Discussion .................................................................................................... 36 Lessons learned ........................................................................................ 37 Value-for-money ........................................................................................ 39 Strategic objectives ................................................................................... 40 References ................................................................................................... 42 2 Key Messages In relation to agri-environment measures/options, the experts recommended that the aims and objectives of the scheme and individual options should be stated with greater clarity and precision. The objectives should clearly identify the type of biodiversity to be benefited/ targeted, and better explain how this will be achieved by the management prescriptions. A number of recommendations were more relevant to design and implementation choices at the scheme-scale: • The experts recommended a move away from a ‘one-size-fits-all’ approach, and toward one that better facilitates spatial targeting. • There is scope for the design stage to consider the additional environmental effectiveness that may be achieved from spatial targeting or incentivised participation of groups of farmers. This approach should also consider the level of participation that is required to achieve specific environmental objectives. • Experts suggested a reduction in the choice of measures within the agrienvironment scheme. A tiered approach was recommended, with the choice of options being strongly guided toward those best suited to the farm conditions. The experts consistently emphasised a number of other comments. • Biodiversity and habitat conservation objectives should be afforded higher priority. Experts agreed that too much emphasis was placed on Measure 1, which detracted from the importance of securing benefits for biodiversity through appropriate habitat measures. The REPS scheme should improve the provision of advice for the protection and management of existing habitats. For relevant habitats, there should be measures that target the achievement of favourable conservation status. • The environmental objectives of the REPS should clearly prioritise and distinguish among the need for conservation of existing habitats, enhancement of degraded habitats, and creation of new habitats. • There should be greater correspondence between the choice of biodiversity objectives in REPS and local and national biodiversity priorities, with the aim of achieving the renewed EU target of halting biodiversity loss by 2020. Guidance on the latter is provided by the National Biodiversity Plan, relevant policy documents and other publications e.g. Red List Data books, National Strategy for Plant Conservation etc. 3 Executive Summary Objectives We consulted with a group of eight Irish agri-environmental experts in order to assess the wildlife value of current supplementary measures and options (hereafter referred to as ‘options’) in the REPS 4 scheme. In the absence of environmental data from monitoring, the assessment utilised a novel methodology which used experts’ judgements of the effectiveness of the REPS options and supplementary measures that are relevant to biodiversity. Agri-environmental experts combined an evidence-based approach and their experience to assess features of scheme design and implementation as indicators of the environmental effectiveness of the REPS options. Key criteria influencing design and implementation were identified as: • validity of the cause-and-effect relationship between the intended objective and the prescribed management, • degree of institutional implementation, • degree of farmer compliance, • the extent to which the measure achieved an appropriate match between the distribution of environmental issues and participation (targeting) and, • the extent to which participation was sufficient to achieve the environmental objective. Methods The assessment occurred in two stages. Experts scored each option using a scoring scale for each of the above five criteria. The scores were then collated and a group meeting of the experts allowed them to discuss each option, elaborate on the justification for their decisions and achieve consensus. The geometric mean of each option was calculated, with higher scores indicating higher effectiveness. Outcomes The use of expert groups proved to be an efficient and effective method to: (i) assess the likely environmental effectiveness of biodiversity options (ii) identify specific aspects of options that are in need of improvement (iii) highlight modifications which should improve environmental effectiveness. Most (but not all) biodiversity options were associated with high scores for both the cause-and-effect and compliance criteria. Thus, for the majority of measures and options, correct implementation of the management prescriptions is expected to achieve the environmental objective, and they are expected to be implemented correctly. Nevertheless, many measures are unlikely to be as effective as expected. Several options were expected to have little or no environmental effect, and some of these were associated with medium to very high participation levels. The assessment identified specific reasons why specific options were not expected to be wholly effective. Many options are likely to have low or no effectiveness (at the scheme scale) because of insufficient participation levels. The experts identified how the environmental effectiveness of several measures could be improved, which would only require relatively minor modification in several cases. 4 Introduction Effectiveness of agri-environment schemes Following Agenda 2000 reform, the Rural Development Regulation (Council Regulation (EC) No. 1257/1999) now combines several policy measures, including the adoption of agri-environmental measures. As a result of these initiatives, large areas of Europe now participate in agri-environment schemes (AESs), although farmer uptake is variable and there is considerable variation in the scope and aims of the various national schemes. Agri-environment schemes in the EU are a major contributor towards CAP objectives to reverse biodiversity decline by 2010, achieve good water quality by 2015 and achieve the Kyoto targets for mitigating climate change. Agri-environment schemes are the only mandatory policy instrument for Member States within Axis 2 of the Rural Development policy. About 51% (~€34 billion) of the Axis 2 Rural Development budget for the 20072013 period was allocated to agri-environment schemes, which now cover nearly three million farms across almost 39 million acres in Europe. Member States are obliged to implement monitoring and evaluation of the environmental, agricultural and socio-economic impacts of their respective agrienvironmental programmes. The evaluation process is intended to identify the extent to which policy objectives are being fulfilled, and to identify any changes necessary to bridge the gap between policy aims and outcomes. Summary reports on agri-environment policy evaluations, however, have concluded that there has been insufficient measurement of the precise environmental outcomes from agri-environment schemes (European Commission 1998, DG Agriculture 2004). In practice, previous evaluation systems have concentrated on administrative issues such as: statements of the aims of the policy programme, the levels of farmer participation, budgetary considerations, administrative structures, the extent of geographical targeting, obligations of participation and the levels of provision and support from extension services. Measures of participation levels, such as the number and area of participating farmers and land, have been widely used to represent the degree of progress made towards the achievement of particular policy objectives. However, participation in AESs per se does not guarantee the actual delivery of environmental protection or improvement (Kapos et al. 2009), and only the monitoring of actual performance and environmental outcomes can demonstrate the true value and environmental impacts of agri-environment schemes (Lee and Bradshaw, 1998). A consequence of the lack of environmental monitoring of schemes is their impaired ability to identify either successes or failures, and to learn how to improve their environmental effectiveness. The Rural Environment Protection Scheme (REPS) is the agri-environment scheme implemented by the Irish Government. The first version, REPS 1, was implemented in 1994 and the latest version, REPS 4, will have participants until 2013. Since 2005, REPS has paid over €305 million annually to Irish farmers, and is currently (2009) paying about €330 million per annum. The stated objectives of REPS 4 are to: 5 • • • establish farming practices and production methods, which reflect the increasing concern for conservation, landscape protection and wider environmental problems; protect wildlife habitats and endangered species of flora and fauna, and; produce quality food in an extensive and environmentally friendly manner. In the most recent iteration, the stated objectives of REPS 4 are: • To promote: a) Ways of using agricultural land which are compatible with the protection and improvement of the environment, biodiversity, the landscape and its features, climate change, natural resources, water quality, the soil and genetic diversity b) Environmentally-favourable farming systems. c) The conservation of high nature-value farmed environments which are under threat. d) The upkeep of historical features on agricultural land. e) The use of environmental planning in farming practice. • To protect against land abandonment. • To sustain the social fabric in rural communities. • To contribute to positive environmental management of farmed NATURA 2000 sites. In Ireland, there has not been a national scale programme to monitor the environmental effects of REPS, and recent studies have highlighted the paucity of data available to judge the environmental impact of the REPS (O’Brien et al. 2008, Finn 2010). A number of studies have conducted research on limited geographical areas, specific measures, and the design of potential new measures (See Finn 2010). Objectives In the absence of environmental data from monitoring, we elicited experts’ judgements on the expected environmental performance of selected elements of REPS. We consulted with a group of eight Irish agri-environmental experts to assess the wildlife value of current supplementary measures and options (hereafter referred to as ‘options’) in the REPS 4 scheme. The assessment utilised a novel methodology which used experts’ judgements of the effectiveness of the REPS options and supplementary measures that are relevant to biodiversity. Methodology: Use of experts to estimate environmental effectiveness Due to a lack of environmental data, we used the judgements of a panel of agrienvironmental experts to assess the performance of different factors that are expected to determine the environmental effectiveness of agri-environment schemes. Use of an expert group can be a quick, cost-effective and efficient method of estimating the effectiveness of a scheme (Carey et al. 2005; Finn et al. 2009). In general, experts were used to engage in a structured discussion and assessment of elements of an agrienvironment scheme. Their quantitative assessment and qualitative information should 6 be highly instructive about reasons for deficiencies and likely opportunities for improvements. The selection of experts was based on several criteria: knowledge and experience of biodiversity, agri-environment policy, applied agro-ecological research and applied interpretation of REPS policy in advising farmers. In addition, an ability to listen to others and express a balanced view was crucial. A pool of likely experts with different backgrounds and competencies was identified. None of those identified had been involved in the design of the existing REPS scheme and therefore were in an independent position to highlight strengths and weaknesses associated with the scheme. Assessment criteria The wildlife value of current options in the REPS 4 scheme was assessed by applying a previously developed approach to investigate the environmental performance of agrienvironment schemes across Europe (Finn et al. 2008, 2009). Within an agrienvironment scheme such as REPS, a number of measures and options are intended to achieve a number of objectives. The project team selected the main biodiversity objective for each measure or option based on the information provided in both the following documents: ‘Farmer’s handbook for REPS 4’ and ‘The specification for REPS planners in the preparation of REPS 4 plans’. The experts were asked to assess different factors that underpin the relationship between an agri-environment measure and achievement of the desired objective. In order to evaluate the effectiveness of the REPS biodiversity options (and in the absence of monitoring data) experts scored options and supplementary measures for a number of assessment criteria, as follows: • Cause and effect: Prescribed management practices should be capable of achieving the desired environmental effects and the intended effects should help to realise the chosen objectives. Thus, there should be a valid cause-and-effect relationship between management prescriptions and the required magnitude of effect to achieve the environmental objectives. • Institutional implementation: The incorrect implementation of a measure may be due to incorrect or inadequate information transfer from the implementing institutions, and/or poor understanding of the ultimate environmental objectives. • Farmer compliance: This reflects the degree to which farmers implement the prescribed management practices as described by the policy. • Participation rate: Sufficient farmers must participate in a scheme (or measure) for the environmental objectives of the scheme to be achievable. • Targeting: A specific feature of participation rate is geographical targeting, which aims to ensure that the distribution of participation in an AES matches the distribution of local or regional environmental issues that are scheme objectives. The methodology and approach is described in detail in Finn et al. (2008, 2009). Each of the assessment criteria was scored by the experts (individually, in advance of a group 7 meeting) on a scale of 0 to 5, where a score of 5 indicated that a measure was ‘fit for purpose’ for a specific assessment criteria. Attainment of a score of 5 should be a reasonable expectation for a measure, and did not require a measure to be perfect. Further detail on the scoring scales for each of the five criteria is provided in Appendix 1. Overall, we assumed that the environmental performance of a specific measure can be estimated and related to the assessment scores for each of the criteria. Higher scores across the different criteria reflect better design and implementation of a measure, which we assume to be strongly related to its environmental performance. Each expert initially worked independently to provide a written individual response. The experts then attended a group meeting at which their scoring of the assessment criteria was collated and presented to the group. Where there was disagreement among individuals on their rating of criteria, the facilitator encouraged discussion with the aim of the expert group reaching a consensus. One can think of this elicitation methodology as a modified Delphi method. An advantage of this modified approach is the reduction in time and effort that is associated with iterations of the traditional Delphi method. It also has the distinct benefit of allowing experts to share knowledge and devote detailed discussion to the issue in question (O’Hagan, 2005). In addition to generating quantitative data on the criteria, the discussions among the experts generate specific discussion that highlighted strengths, weaknesses, uncertainties and opportunities for improving measures. Analyses For each option, the scores that were agreed by the experts were presented for each of the five assessment criteria, and the main features of the discussion noted. Several measures were allocated more than one score for particular criteria, and a decision had to be made how to represent that in the analyses. Within each measure, if a particular criterion received two or more scores, the values for both are given in the table, and the text explains the underlying reason. However for analytical purposes, we needed to use one value only. The choice of which value to use depended on the reason for awarding two or scores in the first place, as follows: (a) For the cause-and-effect criterion, one reason for allocating more than one score recognised the multi-objective nature of several REPS options. For example, both options 3b and 3c addressed water quality as a primary objective, and biodiversity as a secondary objective. In such cases, the cause-and-effect score awarded for the biodiversity objective was used to calculate effectiveness. The same approach was used for nutrient management (option 9a). (b) A few measures were awarded different scores because the experts identified further clarifications to the measure i.e. (7a). Measure 7a concerns creation of a buffer around archaeological or historical features and monuments. Three scores were awarded, 1 for protecting the feature and two for biodiversity. Following (a) above, only biodiversity scores were considered. Given that both scores were for biodiversity, the average of both scores was obtained and used for all further calculations. The same approach was applied to supplementary measure 3 ‘Traditional Irish breeds’. (c) In another situation, experts were unable to agree on the specific aim of a measure. Option 2a is titled ‘Traditional hay meadows’, yet the actual prescription does not appear to benefit traditional hay meadows. Experts awarded a low score assuming the measure to be aimed at restoring species-rich grassland, but 8 agreed a higher score if the aim is simply to allow existing plant species (even if only of low to medium species-richness) to set seed. Based on previous DAFF reports, we assumed that the aim of the measure was the protection of traditional hay meadows, and therefore used the lower score. The same approach was taken with Option 2b: Species-rich grassland. (d) Several situations occurred where experts gave a range of scores e.g. the causeand-effect criterion for option 4c: ‘Nature corridors’ was scored 0-1. In such cases (participation: 2e, 9d, SM6 and targeting: 4a), the mid-point of the range was obtained, and used for all further calculations. For each of the five criteria, the scores were pooled across all options and supplementary measures, and the distribution presented as a histogram. For each option or supplementary measure, the geometric mean of the scores for the five criteria was calculated. 9 Results In this section, we first present summaries of the experts’ discussion of the individual measures and options, with the quantitative scores for the assessment criteria, as well as qualitative information that reflects the main comments and justifications offered by the experts. In a following section, we then collate the results from individual measures and options to better facilitate their comparison. Summary of experts’ discussion of individual measures/options Each measure is described in the following manner: A short summary of the individuals’ assessments is followed by the agreed scores for each criterion (in table format). Highlights of the discussion are noted, in which the group elaborated on the underlying reasons for their scores of the effectiveness of each measure. Options associated with grassland and soil management Option 2a: Traditional Hay Meadows Overall summary: The scores for cause-and-effect (1-4) reflect the group’s concern with the ability of this measure to meet its objective. Implementation also raised concern (2-5 institutional implementation, 3-5 for farmer compliance). Low scores were allocated for targeting (23) and participation (1-3), reflecting the groups opinion that this measure is only likely to make a low-moderate contribution towards halting biodiversity loss. Score Cause and Effect Institutional implementation Compliance Targeting Participation 1 or 3 5 3 3 3 Cause-and-effect: The group agreed that the wording of the objective was insufficiently specific and were unable to decide if the aim was to create, restore or enhance traditional hay meadows (score = 1), or if the aim was to allow some grasses and herbs to set seed (score = 3) and improve the species-richness of the vegetation over time. Two scores were allocated to the cause-and-effect criterion to reflect this difficulty. As a general measure aimed at achieving low level biodiversity by allowing some plants to set seed, a score of 3 reflected the groups’ judgement that this measure would make a moderate contribution towards delivering the environmental objective. The management prescriptions are generally appropriate to achieve the objective, but with several deficiencies. As an alternative interpretation, if the objective was a more ambitious one to restore traditional hay meadows (as a specific type of species-rich grassland, which the phrase ‘traditional hay meadow’ usually suggests), the group agreed a score of 1 to indicate a minor contribution towards delivering this environmental objective. The management prescriptions are limited in their ability to achieve the objective, and possess several major deficiencies. Specifically, the experts were concerned that the management prescriptions are not appropriate to any biodiversity objective. The fertiliser and stocking rates are too high to encourage more flowers or greater diversity of flowers. The timing of cutting is quite early in the season thereby removing shelter and nectar sources for many aerial invertebrates (Humbert et al. 2009). 10 Institutional implementation: The group agreed on a high score because the prescription was straightforward and easily implemented. Compliance: A score of 3 reflected the group’s concern that significant deviations might occur such as: baling silage without turning it and exceeding the allowed fertiliser and stocking rates. Targeting: No targeting is indicated in the prescription. A score of 3 indicates incomplete overlap between where this measure is taken up and where it is most needed. Targeting suffers from the lack of clarity surrounding the objective. No targeting is needed if the measure is intended to ensure more plants set seed and would therefore score highly. If the intention is to undertake activities to support species-rich traditional hay meadows, then this measure should be specifically targeted toward existing hay meadows. Participation: The group agreed a score of 3, indicating that participation in this measure was sufficient to meet a moderate to high proportion of the expected biodiversity output. Option 2b: Species-rich Grassland Overall summary: In general this option scored a little higher than option 2a and there was more agreement between experts that this option could make a better contribution towards biodiversity. However, the cause-and-effect scores (2-4) reflect the groups concern with the ability of this measure to meet its objective. Implementation was also a concern (2-4 institutional implementation, 3-5 for farmer compliance). Low scores were allocated for targeting (1-4) and participation (1-3), reflecting the group’s opinion that this measure is not likely to make more than a moderate contribution towards halting biodiversity loss. Score Causeand-effect Institutional implementation Compliance Targeting Participation 1 or 4* 3.5 4 2 2.5 Cause-and-effect: Similar to option 2a, this option has a counter-intuitive title and an objective that was difficult to interpret. Although this management prescription should benefit biodiversity more than the previous one, the management prescriptions would not be expected to result in species-rich grassland e.g. the experts considered the stocking rates to be too high. Implementation: More guidance is required to enable the farmer to maintain sustainable stocking rates and still maintain species-rich grassland. This option requires more botanical knowledge on behalf of the planner than other measures. Targeting: This option is not appropriate to intensive systems. There is a strong evidence-base supporting the view that it is too difficult and ambitious to restore intensive grasslands to species-rich grasslands. This option should be targeted at those 11 farms with marginal habitat containing remnants of species-rich grassland, to help protect and enhance existing habitats. Participation Although the group agreed that participation was good, the score allocated reflects the overall view that it can only make a low to moderate contribution to achieving the biodiversity objective. Better targeting and implementation would change this. Option 2c: Clover in grassland sward Overall summary: The scores for cause-and-effect (2-5) reflect the group’s difficulty in agreeing on the ability of the measure to contribute to biodiversity objectives. Implementation also raised concerns (3-5 for both institutional implementation and farmer compliance). Scores allocated for targeting (1-5) and participation (2-5) indicated the range of opinions among the experts. Score Causeand-effect Institutional implementation Compliance Targeting Participation 3 3 3 3 5 Cause-and-effect: This is likely to be a good measure for nutrient management and water quality. There is evidence that incorporation of clover in the sward results in a reduced need for nitrogen fertiliser. Clover establishment is less likely under the current allowed fertiliser rates. Implementation and Compliance Inspection is receipt-based and therefore non-compliance can easily occur. The experts recommended field-level inspections that measure clover establishment in the sward. This is a popular option on derogation farms; however, the permitted high levels of nitrogen may be counterproductive to clover establishment and persistence. The experts recommended that maximum allowable fertiliser rates should be reduced in fields where clover is sown, because of the increased risk of nutrient leaching when high levels of nitrogen are applied to swards with high clover content. Targeting: This is popular on intensive grassland farms but its effectiveness is less likely on such farms. It could perhaps be promoted in farms bordering watercourses (assuming that maximum allowable fertiliser rates would be reduced). Participation: This is a very popular measure, with very high participation levels. Option 2d: Use of trailing shoe Overall summary: This measure was assessed as a climate change mitigation measure. It scored highly in terms of institutional implementation and farmer compliance (most scores were 4 and 5). Targeting (1-5) and participation (1-4) scores did vary, indicating a range of opinions within the group but most scores were 4. The group decided to evaluate its contribution to nutrient management, not biodiversity. The score would increase greatly if this 12 equipment could be used on more soil types and could be applied on a wider range of fields. Dedicating some resources to improving those factors would greatly improve its performance. Score Causeand-effect Institutional implementation Compliance Targeting Participation 5 5 4 5 1 Cause-and-effect: This is a good nutrient management and climate change measure. In information not available at the meeting of experts, recent Teagasc research shows that same benefit from trailing shoe in summer can be gained by splashplate spreading with in spring. In a comparison of trailing shoe and splashplate spreading of slurry, the nitrogen fertiliser replacement value of slurry spread by trailing shoe was consistently better than that spread by splashplate at any time of year (Lalor, 2008). Nevertheless, switching the timing of application of splashplate spreading from summer to spring greatly increased the associated fertiliser replacement value (Fig. 1) and costeffectiveness (Lalor & Schulte, 2008). Implementation Implementation is easy, however it is only suitable on certain types of fields and therefore verification of soil suitability is a factor Compliance Compliance will vary depending on the suitability of fields. Targeting: Few people would have access to a trailing shoe. Only farmers who have it (or are in close proximity to a contractor with trailing shoe equipment) are likely to implement this measure. Participation: This has very low uptake and is likely to provide only a negligible proportion of the expected environmental effects of the stated objective. Option 2e: Control of invasive species Overall summary: The experts emphasised that this option would be better titled “scrub prevention on grassland” as it is aimed at grassland only and is not intended to address alien invasive species. It was assessed as an option to prevent scrub on grassland. The scores for all features varied: cause-and-effect, institutional implementation, farmer compliance and targeting all scored from 2 to 5 and with participation scoring less (1-3) indicating the range of opinions within the group. Closer examination of the critical features reveals that refining institutional implementation and increasing participation would improve its effectiveness greatly. Score Causeand-effect Institutional implementation Compliance Targeting Participation 5 2 (see below) 5 5 0-1 (0.5) 13 Cause-and-effect: The experts considered the management prescriptions to be effective for removal of scrub from grassland farms. Implementation To date implementation has been variable, and often resulted in low participation in sites where scrub control was required, because there were easier options to choose (such as the option for nature corridors 4C). (It is debatable whether this issue is more related to the field-level targeting.) Some of the experts suggested that management prescriptions should be more tailored, and should recommend more specific methods for removing named species. Compliance Compliance was not highlighted as an issue. Targeting: Opinions within the group differed greatly, and was reflected in the range of individuals’ scores. Two experts awarded high scores (4-5) for very different reasons - one expert’s opinion was that targeting is not required, while another expert considered that it was very targeted because it was aimed at grassland farms. The experts finally agreed that targeting was not required (thereby awarding a score of 5). The discussion clarified the distinction between implementation and targeting: more specific targeting might curtail its availability throughout the country, which might reduce its potential benefits in some areas, whereas the measure should be promoted more in key areas because it is not taken up where needed most (an implementation issue). The group agreed the measure would best benefit farmers with scrub encroaching on important grassland habitats. Participation: The experts agreed that participation rates were very low. Measures to protect and maintain watercourse, waterbodies and wells Option 3a: Increase watercourse margins Overall summary: Although the scores for all factors varied (2-5), most of the scores for cause-and-effect, institutional implementation, farmer compliance and targeting were high (4 or 5). The participation criterion received a low score. Its environmental performance would be improved by clarifying management requirements, allocating some resources to refining the institutional implementation, and increasing participation. Score Causeand-effect Institutional implementation Compliance Targeting Participation 4.5 3 4 5 1 Cause-and-effect: Despite a relatively high score, the group had serious concerns about the effectiveness of a 2.5m buffer in terms of protecting water quality. All agreed that run-off could still enter a watercourse. The group also discussed the merits of different management regimes (periodic grazing of parts of the margin or rotational flailing) in order to benefit biodiversity, or leaving an unmanaged margin. The group emphasised that while scrub 14 habitats do benefit biodiversity (especially ancient or old scrub habitats that can have high biodiversity value), long-term lack of management will create scrubby margins where this measure is applied and the experts questioned whether this represented the desired contribution to biodiversity. Implementation: Implementation has been variable, and the experts considered that it has often resulted in low uptake where most needed, at least partly because of the availability of other options that are easier to implement (such as adding clover to grassland). Some experts suggested promoting this measure at a landscape scale e.g. incentivising all farms along a watercourse to maintain riparian margins. Compliance: Concerns were raised over the optimal buffer width needed to prevent fertiliser spread or drift. Targeting: The experts considered that participation does not always occur where it may have most beneficial effects. This measure is available throughout the country. It should not be limited to a specific spatial distribution, but it could be implemented to better incentivise group participation on watercourses across multiple farms. Participation: The group agreed that this option has relatively low uptake. Option 3b: Exclude all bovine access to watercourse Overall summary: The scores for all factors varied (2-5), however most of the scores for cause-and-effect, institutional implementation, farmer compliance and targeting were high (4 or 5). Participation scores were lower (more scores of 2-3). Clarifying management requirements, institutional implementation and promoting participation would greatly improve its effectiveness. Score Causeand-effect Institutional implementation Compliance Targeting Participation 3.5 3 5 5 4 Cause-and-effect: Two scores were allocated to cause-and-effect because this is a multi-objective measure (3.5 for biodiversity, and 5 for water quality). As the focus of this report is on the effectiveness of REPS options for biodiversity, the cause-and-effect score allocated was 3.5. All agreed that this measure is more effective as a water quality measure than a biodiversity measure. The group were concerned that erecting fencing on many farms would favour scrub development. Habitat heterogeneity is not promoted by this measure. The biodiversity value of a little poaching to create some bare ground for early colonising species and provide basking areas for large invertebrates was highlighted by one expert. Implementation 15 The group queried the added value to biodiversity from this measure as the experts agreed that the same benefits are provided by the basic measure in which watercourses are fenced and drinking points are established. No major issues arose in discussing compliance and targeting. Participation was initially awarded a score of 2 by four experts, 3 by one expert and 5 by another expert. The group agreed to allocate a score of 4 because although participation in this measure in REPS 3 was quite high, participation in REPS4 was not as high. Option 3c: Use of planted buffer zones Overall summary: The group agreed that there was a strong relationship between applying this measure and achieving its objective (all scores were 4 and 5). The scores for institutional implementation, and targeting varied (2-5) with targeting varying less (3-5) Participation was scored from 0 – 3; as no farmers participate in this measure, the effectiveness is zero. Score Causeand-effect Institutional implementation Compliance Targeting Participation 4 2 5 5 0 Cause-and-effect: Two scores were allocated to cause-and-effect because this is a multi-objective measure (water quality scored 5 and biodiversity scored 4). All agreed that this measure is more effective as a water quality or climate change measure than a biodiversity measure. Implementation and participation: The group emphasised the merit of this option, taking into account the effort that is required to carry it out. Because it is so difficult to do, it is unlikely to be undertaken. Experts suggested that more emphasis should be given about avoiding planting on south-facing banks or on existing habitats. Compliance was judged to be easy. No targeting is needed and this measure should be available everywhere The group was concerned that the effort required to implement this option would discourage farmers from undertaking it. Measures to retain wildlife habitats Option 4a: Creation of a new habitat Overall summary: The scores for cause-and-effect varied from 1-5, suggesting a range of views. Experts’ scores for implementation (2-4) and compliance (3-5) were closer. Opinions also differed widely for targeting (0-5) and participation (2-5). Allocating resources to institutional implementation, targeting and participation could greatly improve its effectiveness, but the management prescriptions should be re-examined and made more specific. This 16 option could be separated into two different measures: (i) a small proportion of the fund allocated to creating new habitat on intensively farmed land, and (ii) refocusing the remainder to safeguard existing habitats of good quality. The majority of the funding therefore should go to protecting existing habitats of highest value on an individual farm. Score Causeand-effect Institutional implementation Compliance Targeting Participation 3 1 5 2.5 3 Cause-and-effect: Three experts allocated low scores because the management advice continues to be misinformed. All highlighted that the fencing and enclosure of habitats without any subsequent active management is a practice that only benefits the development of woodland and scrubby habitats. Some existing habitats may have been damaged prior to REPS 4, when new habitat could be created on existing habitat. Implementation The group highlighted the need for training in order to be able to recognise different habitats. The group also noted that there was a failing in institutional implementation in that the measure should be promoted in intensive systems and therefore implementation was allocated a low score. No issues were raised in connection with compliance. Targeting This feature provoked much discussion. Some experts argued that no targeting is necessary, therefore the measure scored highly, whereas others gave very low scores because it is not targeted, and they argued targeting is necessary. This measure is mostly taken up by extensive farmers. Some experts stressed that the measure should be made more attractive to intensive farmers, as applying this measure in intensive systems would provide greater benefits to biodiversity than in extensive farms. The experts suggested extensive farms should be supported to maintain, restore and enhance existing habitat as a greater priority than the creation of a new habitat. Participation: The group noted that participation in REPS3 was very high, but that fewer farmers would select it as an option under REPS4 because they could no longer create new habitat on existing habitat. Option 4b: Broadleaved Tree planting Overall summary: Scores allocated by experts before the meeting ranged from 2-5 for cause-and-effect, 2.5-5 for institutional implementation and targeting, while most experts agreed a closer score for compliance (3-4) and participation (3-5). This measure was one of the highest scoring across the entire scheme. Score Causeand-effect Institutional implementation Compliance Targeting Participation 5 4 5 5 5 17 Cause-and-effect: Two experts stressed that planting trees is not the same as creating a woodland habitat. The value of scattered trees in the landscape has been established; in particular they act as stepping stones in the landscape for a variety of species. Individual trees however cannot provide the same benefits as a woodland habitat. The experts explained that a woodland provides greater structural variety which in turn enhances species diversity. Implementation Some experts allocated low scores because non-native species were permissible. Another issue raised was the location of planted trees i.e. should avoid planting beside a stone wall. Other experts noted the value of planting a tree along an existing hedgerow. Compliance An Inspector can see if the tree is present or absent, so compliance is easily achieved and assessed. Targeting: No targeting necessary. The group discussed whether this option should be heavily promoted on a landscape scale in regions with little wooded cover. Participation: The group agreed that participation was sufficient to benefit biodiversity. Option 4c: Nature corridors Overall summary: Scores allocated by experts before the meeting ranged from 1-4 for cause-and-effect, 25 for institutional implementation and compliance and 1-5 for targeting and participation, suggesting a range of views. Score Causeand-effect Institutional implementation Compliance Targeting Participation 0-1 5 2 5 5 Cause-and-effect: The group discussed the value of the measure and distinguished between its role as a habitat refuge and as a corridor. They were highly critical of its effectiveness as a nature corridor. The experts questioned the value of recommending ‘ill-considered connections everywhere’. By ‘ill-considered’, experts explained that the corridor either does not link habitats together, i.e. the corridor may act as an isolated field margin, or can provide a connection which may enable the dispersal of alien invasive species. For example grey squirrels can use hedgerows to colonise new woodlands, which could further threaten the red squirrel. The experts also commented that this option requires ongoing management to act as corridor for biodiversity; simply fencing it off will be insufficient to maintain its function as a corridor. Nature corridors may provide a mechanism that enables wildlife passage through the landscape. In principle, habitat corridors are widely supported as a beneficial action to reduce the ecological impacts of habitat fragmentation (Haddad & Tewksbury 2005) despite the lack of empirical evidence demonstrating that dispersal of species benefits by this landscape measure (Sutcliffe et al. 2003). Debate centres on whether investing in 18 connectivity, or the existing site is better, particularly for those species with poor dispersal abilities. The debate is also about scale – to focus efforts on one site and improve patch size and quality there (which may change in time and with climate change impacts), or to invest in several ‘patches’. In spatial ecology terms, this is better described as a stepping-stone concept than a corridor (Dover & Settele 2009). For some species, creating and maintaining corridors has little impact because their occurrence was limited by habitat quality (Wood & Pullin 2002). Research has also shown that corridors need active management to be maintained but that use of them by wildlife varied widely. Implementation This measure does not require much effort and is easily implemented; however, its effectiveness would benefit from more information relating to selection, location and management. Compliance Many concerns were raised over the prescribed distances intended to prevent fertiliser spread or drift. Targeting: The group agreed the measure has widespread application. The group questioned whether this option should be promoted on a landscape scale to link isolated habitats e.g. connect woodlands by a network of hedgerows. Participation: This option is very popular and has good uptake except on intensive farms where it might be most effective. The group agreed that participation was sufficient to benefit biodiversity. Overall, the group suggested that due to concerns regarding the selection, siting and management of the nature corridor, the money expended on this measure could be better spent on a well designed field margin measure for grassland farms. Option 4d: Farm woodland establishment Overall summary: Experts were in close agreement on several criteria (3-5) e.g. cause-and-effect (most were 5), institutional implementation and compliance (most were 4); however, experts held a range of views on targeting (2-5) and participation (1-3). Score Causeand-effect Institutional implementation Compliance Targeting Participation 5 3 5 5 3 Cause-and-effect: The group discussed the value of the measure and emphasised the importance of woodland habitats to biodiversity. One of the experts highlighted the effort required to undertake this measure in comparison to other measures. 19 Implementation Although most experts scored this highly, the group discussion resulted in a lower score. This measure is easily implemented; however, its effectiveness would benefit from more information such as spacing distances among trees, how to create woodland with glades and rides, and linkages with hedgerows and ditches. There was concern that woodland habitat may be created on existing habitat. Experts questioned the use of non-native species. Compliance No issues were raised. Targeting: This option has wide applicability. One of the experts questioned whether this option should be promoted on a landscape scale to create a network of woodlands with linkages provided by a network of hedgerows (this could work well if implemented with another option). Participation: This option was judged to initially have had poor uptake; however, it now seems to be quite popular and has good uptake. Measure 5: Maintain Farm and Field Boundaries: Option 5a: Coppicing of hedgerows Overall summary: Experts were in relatively close agreement on several criteria (3-5) e.g. cause-and-effect (most were 4 or 5) and institutional implementation; however, opinions ranged more widely for compliance, targeting (2-5) and participation (2.5-5). Score Causeand-effect Institutional implementation Compliance Targeting Participation 5 2 3 5 5 Cause-and-effect: The group discussed the value of the measure and several concerns were raised. Experts queried the suitability of all hedgerow species for coppicing and the impact that coppicing might have, in the short term, on the function of a hedgerow as a connective network. Implementation: Some experts noted that this measure was much more precise with more specific information detailed in the prescription. However experts were concerned about selecting the right species, the location of hedgerows selected on farm for coppicing and the lack of information on fencing. For example, coppicing removes all growth to a little above ground level. All broadleaf species can be coppiced, but regeneration from the stumps does not rejuvenate all species to the same degree. Species such as hazel and birch regenerate best because their root buds and other dormant buds are close to the stump, unlike wild cherry and poplar which have poor subsequent growth. This resulted in the experts agreeing a relatively low score. The experts highlighted the risk posed by 20 coppicing hedgerows that might be used by bats or birds as a flight route. Finally the experts expressed a wish for information on the fencing specifications and installation. Compliance: Poor selection of hedges and a lack of experience in managing hedgerows were highlighted as concerns. Targeting: Targeting is not required. Participation: The group agreed that participation was sufficient to achieve the intended biodiversity benefits. Option 5b: Laying Hedgerows Overall summary: Experts’ judgments varied on several criteria (2-5) e.g. cause-and-effect (though most scores were 4 or 5), institutional implementation and targeting. There was closer agreement on compliance (3-4.5) and participation (2-4). Score Causeand-effect Institutional implementation Compliance Targeting Participation 5 3 4 5 2.5 Cause-and-effect: Experts agreed there was a high cause-and-effect relationship. Implementation Some experts suggested that more information on local styles of hedgerow should be provided. These concerns resulted in the experts reducing the score. Compliance: Experts’ views differed greatly in the amount of work required by this measure, and that would influence compliance and participation. Concerns were raised about the use of some equipment e.g. the bucket digger which could damage hedgerow flora. Targeting: Targeting is not required. Participation: Experts agreed uptake is low for two reasons: the expertise and effort required relative to other options (see above comment re extent of work required). Option 5c: Planting new hedgerows Overall summary: Experts judged this measure to be quite effective. There were a wide range of views held e.g. 3-5 for cause-and-effect (though most scores were 5) and compliance, targeting (25) and participation (2.5-5). There was closer agreement on institutional implementation (4-5). Monitoring to estimate farmer compliance may increase its performance. Score Causeand-effect Institutional implementation Compliance Targeting Participation 5 4.5 3.5 5 5 21 Cause-and-effect: Experts agreed there was a high cause and effect relationship in that planting a new hedgerow had known biodiversity benefits. Implementation: Easily implemented although concerns were raised about aftercare. Compliance: Experts were unsure of this as there was not much experience of compliance/non compliance. Targeting: Targeting is not required. Participation: The group agreed that participation was sufficient to benefit biodiversity. 22 Option 5d: Additional stone wall maintenance Overall summary: Experts judged this measure to be an effective measure that completely meets the biodiversity objective. There were a wide range of views held e.g. 2-5 (for cause-andeffect (though most scores were 5) and participation) and 3-5 (for compliance and targeting). There was closer agreement on institutional implementation (4-5). Score Causeand-effect Institutional implementation Compliance Targeting Participation 5 5 5 5 5 Cause-and-effect: Some experts had initially scored this low because they considered it a measure aimed at landscape heritage and stock-proofing (rather than directly benefiting biodiversity). Opinions were revised as other experts highlighted the biodiversity benefit of stone walls in terms of shelter (e.g. lizards basking on south-facing walls) and providing a specialised habitat for plants, ferns, mosses, invertebrates and mammals. Opinions varied about the extent to which stone walls function as a nature corridor, and one expert pointed out that it might be a barrier for some species. Experts agreed that there is a lack of evidence to support the function of stone walls as a nature corridor. Implementation: Easily implemented Compliance: One expert highlighted that non-compliance occurs if inspectors see a map with a stone wall indicated and on site visit, find stone walls with hedgerow growing over it. Removing the hedgerow would be compliant but removes a valuable habitat for biodiversity. To be compliant, planners should indicate that both stone wall and hedgerow are present. Targeting: Measure is aimed at farms with stone walls. Participation: The group agreed that participation was sufficient to benefit biodiversity, primarily in the west of Ireland. 23 Option 7a: Increased buffer margins for archaeological and historical features Overall summary: This is a good example of a multi-objective option in which the farming practice will also influence its effectiveness. A wide range of views were evident, based on experiences of this measure in the context of different farming systems. Different scores were allocated by experts to reflect this. Cause-and-effect Institutional implementation 5 for protecting feature 3 in tillage* Score 0 in grassland 4.5 Compliance Targeting Participation 5 5 5 in grassland, 0 in tillage Average scores to calculate effectiveness (geometric mean). Score Causeand-effect Institutional implementation Compliance Targeting Participation 1.5 4.5 5 5 2.5 Cause-and-effect: Experts all agreed that the buffer margin was effective at conserving archaeological features; however, they did not agree that the additional buffer margin was effective at conserving biodiversity. Furthermore they differentiated between the wildlife value of the buffer margin in grassland and in tillage systems. They placed a higher wildlife value on the buffer margin in tillage systems than in grassland systems. Implementation: Easily implemented although there was an issue raised about sites that were not listed on the Register of Monuments and Places, and the difficulty with sites that were present but not visible above ground. Compliance: No issues were raised Targeting: The option is targeted at farms with features of archaeological or historical interest. Participation: The group again differentiated between participation in tillage and in grassland systems. They highlighted that there is low participation in tillage systems, where it would benefit biodiversity, and high uptake in grassland systems where they questioned the contribution of the measure to biodiversity. Option 8a and SM2: Traditional Irish Orchards Overall summary: Experts’ judgments agreed closely on several criteria e.g. cause-and-effect, institutional implementation and compliance were all 4-5. Targeting was similar with one expert scoring it lower than all the others. A wider range of views was held about participation (1-4.5) 24 Score Causeand-effect Institutional implementation Compliance Targeting Participation 5 3.5 5 4 1 Institutional implementation and Participation: One expert highlighted that this measure focused on the creation of new orchards and did not give sufficient recognition to farms with existing orchards. Option 8b: Install bird and bat boxes Overall summary: Most experts assigned scores of 4-5 for cause-and-effect, with low scores (2-3) from two experts. A wider range of views were held about institutional implementation (2-4) and targeting (2-5) while most agreed on the score assigned to compliance (4-5) and participation (3-4). Score Causeand-effect Institutional implementation Compliance Targeting Participation 5 2 5 4 5 Cause-and-effect: Low scores were initially awarded by two experts because they questioned whether there was a shortage of suitable nesting or roosting sites existing on farms and whether this measure would enhance farmland biodiversity. After discussing the measure, the group agreed that available evidence supported their use by bat and bird species, and confirmed that on a short-term scale, farmland biodiversity would be enhanced. Implementation: Easily implemented, although the group agreed that better and more specific information could be provided. Compliance: No issues were raised, although aftercare may be an issue. Targeting: No targeting is required in general, although this measure could be promoted in areas where bat or bird numbers are lower than expected, if this is known. Participation: This is a very popular option and uptake is certainly sufficient to provide maximum levels of the objective. Participation probably exceeds the level required to achieve the expected environmental effects of the biodiversity objective. Measure 9: Tillage crop production Option 9a: Green cover establishment Overall summary: This is an example of a multi-objective measure. Experts held a wide range of views on cause-and-effect and institutional implementation (3-5) while most agreed on the scores (4-5) assigned to compliance and targeting. Participation scored low (1-3). Cause- Institutional Compliance Targeting Participation 25 Score and-effect implementation 2.5* 5 5 5 0.5 Cause-and-effect: Two scores were allocated to cause-and-effect* because this is a measure with multiple objectives. Experts agreed that this measure is more effective as a nutrient management measure (scoring 5) than a biodiversity measure (scoring 2.5). The contribution to biodiversity is relatively low: as a winter crop it provides a temporary shelter and food source. No issues were raised in connection with implementation and compliance. Targeting: This measure is targeted at tillage farmers. Participation: The absolute level of uptake is very low; however, because it is targeted at tillage farmers, the total number of eligible farms is also low. Option 9c: Increased arable margin Overall summary: Experts agreed on the scores (4-5) allocated to cause-and-effect and institutional implementation (though one expert assigned a lower score to implementation). Experts held a wider range of views on compliance and targeting as reflected in the scores (2-5). Participation scored low (1-3). Score Causeand-effect Institutional implementation Compliance Targeting Participation 5 4 5 5 0.5 Cause-and-effect: The group highlighted that this was an excellent evidence-based measure for biodiversity, benefitting small mammals, partridges, ground beetles and noted specific aims also to create tussocks for over-wintering insects and avoid disturbance to skylarks and meadow pipits. Implementation: This measure is easily implemented, but one expert suggested it should be tweaked to benefit rare arable weeds. The group agreed with this. Compliance: The margin is visible therefore there should be high compliance Targeting: This measure is appropriately targeted at tillage farmers. Participation: There is very low uptake, which makes it difficult to achieve the expected environmental effects for biodiversity. Given the substantial evidence base for the effectiveness of arable field margins (in international literature), the experts recommended that greater participation in this option should be encouraged among arable farmers. Option 9d: Low Input Spring Cereals: SM6 26 Overall summary: Experts broadly agreed on the scores (4-5) allocated to cause-and-effect, institutional implementation, compliance and targeting (though in the cases of implementation and targeting, one expert assigned a lower score). Participation scored low (1-3).. Score Causeand-effect Institutional implementation Compliance Targeting Participation 5 5 5 5 1.5 Cause-and-effect: Experts agreed that this option was an excellent one, which can provide food for birds and wildlife over winter in grassland farms. Implementation (and targeting): This measure is intended to mitigate the reduction in mixed farming and spring cereals. The experts awarded low scores to both criteria due to the fact that although this measure is targeted at grassland farmers, it is mainly taken up in areas where tillage is practised. Few grassland farmers select it as a supplementary measure, therefore the experts recommended that more guidance and input at the implementation would increase numbers and participation in areas where it will benefit biodiversity most, i.e. grassland dominated regions. Targeting: This measure is appropriately targeted at grassland farmers but see comment above. Participation: More needs to be done to incentivise grassland farmers to participate in this measure. There is very low uptake to achieve the expected environmental effects for biodiversity. Option 9e: Minimum Tillage SM7 Overall summary: Experts held a wide range of views on cause-and-effect, institutional implementation and targeting as the scores indicated (3-5). Most experts agreed on the scores assigned to compliance (4-5). Participation scored low (1-3). Score Causeand-effect Institutional implementation Compliance Targeting Participation 5 5 5 5 1 Cause-and-effect: The group agreed this measure was mainly intended to prevent soil erosion, and promote nutrient management but two experts also indicated that it could benefit soil biodiversity. Participation: There is very low uptake to achieve the expected environmental effects of the biodiversity objective. 27 Supplementary Measures: SM1: Conservation of Wild Birds Habitat Overall summary: Experts were broadly in agreement, with most criteria scoring 4-5. Participation scores varied a little more (3-5). Experts judged this measure to be effective. The biggest issue lay with the title and prescription. The measure is intended for wild birds but is only available for corncrakes due to funding shortages. Score Causeand-effect Institutional implementation Compliance Targeting Participation 5 5 5 5 5 Cause-and-effect: The group highlighted that this was an excellent evidence-based measure but emphasised that it is a good example of a successfully implemented measure whose objectives can fail due to external environmental factors i.e. summer flooding in Shannon Callows. Implementation: This option was only available in the Shannon Callows up to REPS 3. REPS 4 extended it to west Connaught and Donegal, where summer flooding has not been such an issue. As a priority, the group recommended that the measure be broadened to cover other vulnerable bird populations. SM2 see option 8A for relevant comments SM3: Conservation of Animal Genetic Resources Overall summary: Experts all agreed that the prescription was appropriate to achieve the objective of the measure (cause-and-effect scores were all 5 and compliance scored 4-5); however, scores varied for implementation and targeting (3-5). Lower scores were assigned to participation (2-4). This could be altered with more resources to promote participation for all other breeds apart from equines. While additional funds are always welcome the group were concerned that wider market forces were influencing the uptake of most traditional breeds with the exception of the Connemara pony and the Irish draught horse. More marketing and targeted promotion may help improve the market value of the other breeds. Score Causeand-effect Institutional implementation Compliance Targeting Participation 5 5 5 5 3.75* Cause-and-effect: 28 This measure should make a major contribution to achieving the biodiversity objective; however the group warned that this might change if the market value of the equine breeds changed. Implementation: This measure is easily implemented. Targeting: This measure is appropriately targeted but it needs to be incentivised as the success of the measure is due to the market value for the equine breeds. Participation: There is relatively low uptake to achieve the expected environmental effects of the biodiversity objective, especially for the non-equine breeds. SM4: Riparian Zones Overall summary: Experts held similar views on cause-and-effect (scores 4-5) but held a wider range of views on institutional implementation, compliance and targeting as reflected in the scores (3-5). Participation scored low (1-3). Score Causeand-effect Institutional implementation Compliance Targeting Participation 4 4 5 3 1 Cause-and-effect: The group highlighted that this measure had potential benefits for pearl mussel particularly, if undertaken properly. Implementation: This measure is easily implemented, but there were concerns about the long-term management of the buffer zone. Compliance: The issue of run-off or fertiliser drift getting into the watercourse was raised. Although the riparian zone is fenced off by the end of the first year to exclude livestock, and spraying is generally not permissible, experts’ experience of fenced margins was that fertiliser was still getting into watercourses in some cases. Fears were expressed that this would continue to happen despite the increased buffer width in a riparian zone because spraying occurs right up to the fence, and drift from the spray would certainly reach the buffer strip. Targeting: This measure is targeted at salmonid, pearl mussel and crayfish rivers, but it should be incentivised along the entire stretch of a particular watercourse. Such spatial targeting will not only benefit key species such as salmon, crayfish and freshwater pearl mussel, but otters too. Research has shown that habitat improvement at the individual farm scale may benefit mink, whereas habitat improvement by farms contiguous with a particular watercourse is beneficial to otters (Lundy & Montgomery 2009,2010). The landscape benefit may be reduced or lost if all farms along a watercourse do not apply this measure. Participation: There is very low uptake to achieve the expected environmental effects for biodiversity. 29 SM5: LINNET Overall summary: Experts agreed on the scores (4-5) allocated to cause-and-effect and institutional implementation (though one expert assigned a lower score to implementation). Experts held a wide range of views on cause-and-effect, institutional implementation (2-5) and targeting (1-5). Their scores were closer in agreement for compliance as reflected in the scores (4-5). Participation scored low (1-3). This measure could be improved with better targeting and more resources to promote participation. Score Causeand-effect Institutional implementation Compliance Targeting Participation 5 5 5 1 3.5 Cause-and-effect: The group highlighted that there was good evidence from research studies in the UK to support the validity of such approaches for the benefit of grain-feeding birds, especially those for which grain was a limiting food source in winter. Implementation: This measure is easily implemented. However concerns were raised about interpretation. Greater guidance is needed to ensure that plots are spread across a farm and away from each other, to ensure the optimum output for biodiversity. At present this seems to be a grey area. This measure works well in the first two years but more guidance is needed for years 3-5 to reflect the fact that it gets harder to maintain the plots. Better implementation might help ensure this measure is taken up in grasslanddominated areas. Compliance: The plot is visible therefore there should be high compliance; however, the experts highlighted that the experience on the ground was that plots were placed close together as the interpretation of the guidance on proximity of plots varied. Targeting: This measure is appropriately targeted at grassland farmers but it is largely adopted in tillage areas. For that reason, a low score was agreed. Participation: There is insufficient uptake to achieve the expected environmental impact. SM6: see Option 9D for relevant comments SM7: see Option 9E for relevant comments 30 SM8: Traditional sustainable grazing Overall summary: Better management prescriptions and more resources to incentivise participation could improve this measure. Score Causeand-effect Institutional implementation Compliance Targeting Participation 3 3 4 5 1 Cause-and-effect: The emphasis should be placed on sustainable grazing, because traditional grazing is not necessarily sustainable. Management prescription should change. The measure currently attempts to prevent undergrazing by allowing overgrazing to occur. The current stocking rate is too high for many vulnerable habitats e.g. machair, dune grassland, turloughs and callows. At the current recommended stocking rate, the above habitats would be damaged. A better option would be to set the current minimum grazing level as the maximum level. Implementation: The wording of the prescription is vague and therefore implementation may suffer. There is research available on what is an appropriate level of grazing for different habitats, timing etc. This could be provided in summary form for farmers, with greater detail for advisors. Training is needed to ensure advisors and farmers can recognize different types of grassland – e.g. wet and dry grassland. Different ranges of management practices could be provided to allow some flexibility. Compliance: There should be high compliance because it should be easy to verify if traditional breeds are on farm and at appropriate stocking densities. These should be monitored and modified if necessary. Targeting: This measure is appropriately targeted at grassland farms with marginal habitat. With an appropriate prescription, this option could be promoted in High Nature Value farmland areas. Participation: Uptake is not sufficient to achieve the expected environmental effects for biodiversity. SM9: see Option 2C for relevant comments SM10: Mixed Grazing Overall summary: Experts held a wide range of views on cause-and-effect (0-4) institutional implementation (2.5-5) and targeting (1-5). Most experts broadly agreed on the scores assigned to compliance (4-5) and participation (2-3). Overall, the experts considered that this is not an effective measure for biodiversity. 31 Score Causeand-effect Institutional implementation Compliance Targeting Participation 0 4 4 1.5 5 Cause-and-effect: The group highlighted that while mixed grazing management has been used to maintain species-rich grassland, especially on High Nature Value farmland, this prescription will not achieve the objective of restoring intensive grassland to species-rich grassland. The experts suggested that the measure should specify reducing sheep numbers. Mixed grazing in the one field creates different vegetation structures, as long as overgrazing does not occur. The group expressed serious concerns about the cause-and-effect relationship for this measure. Implementation: A criticism of REPS 2 and 3 was that they did not provide sufficient measures that were appropriate for implementation by hill farmers. This option may have been designed to remedy that, based on mixed grazing and High Nature Value farmland, but demonstrates a misunderstanding about mixed grazing. The current prescriptions for stocking densities are high, and are likely to result in overgrazing. Compliance: There should be high compliance because an inspector must be able to see cattle and sheep in same field. Targeting: This measure is appropriately targeted at land in danger of abandonment. However it is a popular measure on intensive sheep farms, which are less likely to have difficulties with land abandonment. Targeting therefore needs to be directed at specific areas of the country where land abandonment is a recognised problem. If the measure stipulates that sheep numbers should be reduced, in line with additional cattle, this option may result in higher participation by both sheep farmers and hill-farmers. Participation: Uptake appears to be high in the west of Ireland and other areas where sheep farming predominates. 32 Comparison of measures and options In this section, we collate the results from the individual measures and options (from above) to better facilitate their comparison. The distribution of scores among the scoring categories (Fig. 1) varied considerably among the different assessment criteria. The cause-and-effect criterion was dominated by scores in the highest category, although there were several measures/options that received very low scores. The implementation criterion was distributed across scores from 2 to 5, indicating many measures/options with implementation that can be improved. Scores for the compliance criterion were generally high. The targeting criterion was dominated by scores in the 5 category. The participation criterion had a distinct distribution with many measures/options for which the experts considered to be adequate, and many others that were considered to have such low participation as to completely or almost completely limit the achievement of the associated environmental objective. The separate presentation of the distributions of scores facilitates an overview of which criteria are generally performing best. Alternatively, it can indicate which criterion is generally most in need of improvement, although some care is required about whether all criteria are equally important e.g. one might prioritise the criteria for cause-and-effect and participation. To facilitate an assessment and comparison of the overall performance of individual measures, we assume that the multiple criteria that produce environmental effects act dependently i.e. if one of the criteria completely fails, then the aggregate environmental output is nil. This corresponds to a multiplicative relationship among the criteria, which can be represented as a geometric mean of the different criteria scores for an individual option. Thus, the geometric mean can be used as an overall estimate of the environmental effect of an option. The estimated environmental performance of the different options and supplementary measures is presented in Fig. 2. This should be used as a guide of the relative environmental effectiveness of different options; it is likely that the small changes in a few scores would result in some shift in the rank order of the measures. Nevertheless, the rank order is likely to represent broad patterns of the estimated effectiveness of the different options. About half of the measures/options have a value <3.5. Some combinations of factor scores that result in a value of about 3.5 include: [1, 5, 5, 5, 5]; [3, 3, 3, 4, 5]; [2, 3, 4, 5, 5]; [2, 2, 5, 5, 5,] and of course [3.5, 3.5, 3.5, 3.5, 3.5]. Thus, for options with a value of about 3.5, there are usually three or four criteria displaying some deficiencies (at best), or one or two criteria that display serious deficiencies (a score <2). The quantitative and qualitative information for each individual option indicates where the most obvious deficiencies occur, according to the experts (see above). 33 Causality Percentage Distribution 70 60 50 40 30 20 10 0 0 1 2 3 4 5 Scores Compliance 70 70 60 60 Percentage Distribution Percentage Distribution Implementation 50 40 30 20 10 50 40 30 20 10 0 0 0 1 2 3 4 0 5 1 2 4 5 3 4 5 Scores Scores Participation Targeting 70 70 60 Percentage Distribution Percentage Distribution 3 50 40 30 20 10 0 0 1 2 3 Scores 4 5 60 50 40 30 20 10 0 0 1 2 Scores Figure 1. Percentage distribution of scores across all five criteria for each measure or option (n=33). Categories (0 = 0 – 0.99, 1 = 1 – 1.99, 2 = 2 – 2.99, 3 = 3 – 3.99, 4 = 4 – 4.99, 5=5) 34 REPS measures and options SM1 5d 4b SM3 5c 4d 3b 8b SM6 9d 5b 5a SM7 9e 2d SM5 7a SM9 2c 3a SM2 8a 9c SM4 SM8 2a 9a 4c 2e 4a 2b SM10 3c 0 1 2 3 4 5 Geometric mean Figure 2. Estimated relative environmental effectiveness of biodiversity measures and options based on experts’ judgements. Bars represent the geometric mean of scores of assessment criteria, where higher scores indicate better environmental performance. 35 Discussion In addition to eliciting quantitative data on each of the assessment criteria, the experts’ discussions provided a rich source of qualitative information that clarified and justified the quantitative score for each criterion, especially those with low values. Such information explained and gave insight into the experts’ justifications of why a measure was considered to deliver sub-optimal levels of environmental effectiveness. Importantly, this approach can contribute to learning how to improve the environmental effectiveness of the measures. Based on the value of the qualitative information, therefore, we believe that the process of conducting the expert consultation can be a significant opportunity for scheme designers to learn how to improve (a key aim of evaluation). Of course, it also assists the aim of evaluators not just to assess the current environmental status of AESs, but also to suggest modifications to enhance environmental performance. Finn et al. (2008) discuss in further detail how expert panels can be used for learning how to improve agri-environment schemes with a number of examples, as follows: 1. In the design stage of a new scheme (or new policy cycle), the assessment criteria used above could be used as a checklist to ensure that important attributes of environmental performance are not omitted from consideration. 2. Ex ante (or mid-term) evaluation could use experts judgements’ of the assessment criteria to predict the likelihood of environmental effectiveness of measures in the proposed scheme design. Such an approach could harness the expertise of ecological and environmental experts in a systematic manner, and highlight measures for which there is more uncertainty about the effectiveness. 3. Ex post evaluation could also benefit from the use of experts’ expertise to attain a consistent and valid synthesis and interpretation of the effectiveness of measures. A consistent evaluation could use experts’ judgement of available empirical data as a basis for scoring elements of a policy against the key criteria that underpin the delivery of environmental effectiveness. 4. Once a new scheme (or new policy cycle) is implemented, unforeseen problems may arise. The quicker a scheme identifies necessary changes for improvement, and the more responsive it can be in implementing recommended changes, and the more likely it is to be effective. The use of experts’ judgements to conduct a rapid evaluation would address a genuine need to learn about the progress of a scheme, and would seem particularly appropriate soon (e.g. one year) after the implementation of new or substantially modified schemes. It is important to stress that the measure of environmental effectiveness presented in Fig. 2 is an estimate, based on the best available evidence to the experts, and including a strong element of tacit knowledge. This methodology does not remove the need for measurement of the environmental performance of schemes. However, when environmental monitoring detects a failure to achieve the expected level of environmental performance, this methodology can help to more specifically identify the 36 reason for such failure. In addition, the best implementation of this methodology will be achieved when experts’ judgements are based on a collation of relevant evidence from research studies. In these ways, we see this methodology as complementing the research and monitoring that should be conducted as part of the effective environmental evaluation of AESs. Lessons learned While many measures/options are not performing as they should, the results highlight at least one and often two features that need to be modified in order to improve the effectiveness of the measures. In many cases, the biggest issue is that participation is insufficient to achieve the objective of the measure. In the Results section (above), we presented detailed comments from the experts on specific measures and options. At a higher level of scheme design that takes a more holistic perspective across the different measures and options, several overarching issues arose during the discussion among the experts. Several comments addressed the overall structure of REPS: • A significant proportion of the REPS planners’ time has been devoted to the implementation of Measure 1 (Nutrient Management Plan), and the experts highlighted several benefits of removing this measure from REPS. This is not because such issues are unimportant, but because they address crosscompliance only, generate a small payment (for soil sampling and analysis), and detract attention from the wildlife elements of the REPS plan. • One expert suggested removing all of the options that apply under cross compliance in order to place a greater focus on wildlife and emphasise the positive contribution that can be made to safeguarding biodiversity. • Another suggestion was to move away from the one-size-fits-all approach in favour of a more tiered approach; however, there were also strong recommendations not to provide more options. • The experts suggested that the current implementation of REPS can facilitate choices that may produce relatively small benefits for biodiversity. The REPS format should be able to create a package of measures that would be tailored to the environmental priorities on a farm and optimise the benefits for biodiversity depending on its location, and farm type. For example a suite of riparian measures – e.g. riverside margins (3a) should be undertaken by all farms on banks of any river or other large watercourse, and such farmers should be precluded from selecting less relevant options for their farm e.g. adding clover to a grassland sward (this is also relevant to issues that address targeting and institutional implementation) The experts suggested that the scheme would benefit from better decision-support systems to improve the spatial targeting of measures/options. • Experts questioned whether the achievement of targeting and linkage of specific environmental objectives to regional areas should be planned at the design stage of the scheme (incorporating it as part of institutional implementation) rather than simply being at the discretion of individual planners? Such an approach would prioritise different objectives that reflect the most pressing environmental issues in different areas (e.g. at the county-or provincial scale. For an example from the 37 UK, see Natural England (2010). in some cases, there is relatively little financial incentive to select options that may require more input or time. At the least, measures and options should ensure that they fully pay for farmers’ costs (direct costs and transaction costs) to reduce any financial obstacles to undertaking what are perceived to be more demanding options. • The need for targeting arises due to the one-size-fits-all approach that characterises the REPS. Targeting may be achieved through regional objectives and priorities (see above) but also through targeting of named farming systems. Thus, there could be clearly differentiated priorities for intensive dairy systems, extensive beef systems, lowland pasture, coastal grassland, uplands etc with a corresponding differentiation of appropriate measures/options. The benefits arising from most options will differ across those farmland systems, and a way that depends on the conservation status of the habitats on the farm and the biodiversity targeted. In addition, the experts considered how the biodiversity objectives in REPS might be afforded higher priority and targeting: • Greater clarity is needed in the environmental objectives. The intention of the objectives is sometimes non-specific and difficult to interpret. Titles often suggest one intended outcome while the prescriptions indicate a somewhat different one– e.g. species-rich grassland, traditional hay meadows and traditional sustainable grazing. • Not all biodiversity options are targeted at named species and habitats. Even where this detail is clear, the experts indicated a lack of correspondence between many of the biodiversity objectives selected by REPS and the biodiversity objectives associated with protected or vulnerable habitats and species at localand/or national-scale (see below). • More specific measures with more specific aims and prescriptions should be made available to target species at greatest risk of extinction. • The experts suggested that management prescriptions for Measure A farmland habitats (Natura 2000, SAC, SPA, NHA) may not be sufficient to restore or maintain habitats in favourable conservation status (see also NPWS 2008). • The REPS could better differentiate between the aim of protecting and managing existing habitats and that of creating new habitat. More advice is needed on when to conserve and protect habitats or when to opt for creating new habitats. Conservation should have higher priority in high value habitats such as speciesrich grassland or traditional hay meadows. • The experts pointed to examples of environmental marketing where the high biodiversity value of farmland is linked to a commercial product from that farm or that area (e.g. in the Burren, West Cork, Yorkshire and France). In this way, farmers and consumers link the value of an existing habitat or species to the quality and price of the product. There are several added benefits to this approach. The link between biodiversity and farm products encourages bottomup support for environmental quality. It encourages farmers’ knowledge of the habitat or species, beneficial management management, and likely threats and risks. 38 Value-for-money Although this study focused on the assessment of environmental effectiveness, it is difficult to assess agri-environment schemes without some consideration of their economic efficiency. Although this issue is beyond the scope of this study, our results impinge on any assessment. Indeed, this is a topical issue, as the value-for-money of REPS was mentioned in the Report of the Special Group on Public Service Numbers and Expenditure Programmes: It would be timely to conduct another in-depth value-for-money review of the scheme for the effectiveness of REPS in protecting water courses, supporting the rural environment, highlighting impacts on biodiversity particularly in sensitive regions, as well as the impact on the economy in rural areas. The outcome of the review should inform decisions on the future scope and shape of the REPS Scheme in Ireland. (McCarthy et al. 2009, Vol II, p. 12) Some general remarks may highlight the relationship between environmental effectiveness and costs, and how an understanding of this relationship may inform decision-making. Here, we assume that the total costs only represent the total payments made for a measure (the product of participating hectares and per hectare rate), rather than the cost per hectare for a measure (and we ignore public and private transaction costs). In general, any measure that has low or no effectiveness will not achieve the intended objective, and therefore deliver poor value-for-money. In general, measures that address higher priority objectives would be expected to be allocated more funding than low priority objectives. In this way, the priority level of the objectives is another important factor in decision-making on value-for-money, and a further justification for the clear prioritisation of different objectives (Finn et al. 2009, Finn 2010. Effective measures that are associated with low costs and address highest priority objectives represent (in this example) the ideal from the perspective of policymakers and the efficient use of public funds (Fig. 3, bottom right). Ineffective measures associated with high costs (Fig. 3, top left) should be a priority for evaluation and identification of remedial action. For measures with medium effectiveness, those that are low- or medium-cost represent an opportunity to improve effectiveness (without increasing the cost). Measures with high effectiveness and high total costs (Fig. 3, top right) could be examined to determine whether there is a lower-cost option that does not compromise effectiveness (Fig. 3, bottom right). 39 Very low value Good to high value for higher priority objectives Low to medium value Excellent value total cost effectiveness Figure 3. Illustration of the value-for-money implications of different combinations of environmental effectiveness and total cost of a measure. Strategic objectives Finn (2010) pointed out that: “Ultimately, it is only by their contribution to national-scale priority issues that the success of agri-environment schemes can be judged. It is important to point out that monitoring of implemented measures can only assess the extent to which measures fulfil their immediate objectives for each individual measure; it is the role of evaluation to conduct an overarching judgement of whether the initial choice of measures was appropriate to achieve the objectives of a scheme, and that the scheme objectives themselves address national priorities for e.g. biodiversity, water quality and mitigation of climate change. This issue is summarised in the distinction between doing the right job versus doing the job right, which contrasts strategic decision-making (that informs task selection) with the proper execution of tasks.” The biodiversity goals of agri-environment schemes might be expected to reflect stated policy priorities as provided in e.g. Biodiversity Action Plans, Ireland’s National Biodiversity Plan (www.npws.ie), the National Strategy for Plant Conservation (http://www.botanicgardens.ie/gspc/inspc.htm) and the Rural Development Programme. For example, schemes supported by modulation funds are intended to address specific challenges that include climate change, renewable energies, water management and biodiversity. For biodiversity, halting the loss of biodiversity and protection of High Nature Value farmland are headline performance indicators. A consideration of such policies and appropriate consultation should guide the prioritisation of the different types of biodiversity that policymakers can choose to prioritise. A greater differentiation of farmland biodiversity could include, for example: - priority habitats that occur on Natura 2000 sites; - priority habitats that occur outside of Natura 2000 sites e.g. traditional lowland hay meadows, calcareous grasslands and many others; - rare and threatened species that are named in Red Data Books; - species that receive legislative protection and are listed on the Wildlife Act, 1976, the Wildlife (Amendment) Act, 2000 and the European Union (Natural Habitats) Regulations, S.I. 94/1997 (as amended S.I. 233/1998 & S.I. 378/2005), 40 Habitats Directive (92/43/EEC) and the Birds Directive (79/409/EEC) e.g. barn owl, otter, natterjack toad, marsh fritillary; - other rare and threatened species; - species that are declining, but are not yet rare or threatened; - common farmland habitats; - common farmland species (e.g. frog, hedgehog, cowslip, wren); - creation of farmland habitat to support named species; - creation of common farmland habitats - minor restoration of common farmland habitats. In July 2009, the Minister for Agriculture, Fisheries and Food announced the closure of REPS 4 to new entrants. However, there will continue to be a significant number of REPS 4 participants (and associated expenditure) up to 2013. A new agri-environment scheme will take effect in 2010, although the details of objectives, implementation and budget are not yet clear. An outline of the new agri-environment scheme was released on 7th August 2009. All of the 20 proposed measures (as of August 2009) have been previously available as basic measures, supplementary measures or options in REPS 4 (Table 1). The new scheme will not be a whole-farm scheme. The issues raised by the experts would be relevant to any evaluation of the design and structure of existing measures that may be included in future agri-environment schemes. However, highest priority should go towards : • strengthening links between the biodiversity objectives of REPS and national conservation priorities. This will be necessary to meet the new EU target of halting biodiversity loss by 2020, and; • monitoring and measuring the environmental effectiveness of REPS. Where necessary, monitoring would also learning how improve any measures with deficiencies. Most importantly, the aim of monitoring would be to demonstrate the environmental benefit of well-designed measures and options. Acknowledgements We thank the members of the panel of experts for their valuable contribution. This is a joint project between Teagasc and NUI Galway. Funding was provided under the National Development Plan, through the Research Stimulus Fund, administered by the Department of Agriculture, Fisheries and Food. 41 References Aughney, T. and Gormally, M. (2002). The nature conservation of lowland farm habitats on REPS and non-REPS farms in County Galway and the use of traditional farm methods for habitat management under the Rural Environment Protection Scheme (REPS). 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Measure participation wholly or almost wholly matches the distribution of the relevant environmental need/impact More than enough farms undertake measure to provide maximum levels of the objective. Participation exceeds the level required to achieve the expected environmental effects of the stated objective. Score of 4/5 The measure should Measure make a moderate to participation major contribution mostly matches towards delivering the distribution the environmental of the relevant objective. The environmental need/impact. management prescriptions are mostly appropriate to achieve the objective, with some deficiencies. The measure should Quality of The measure is Measure make a moderate implementation usually Participation contribution towards by responsible implemented usually matches Participation rates provide all or almost all of the expected environmental effects of the stated objective. Score of 3/5 Quality of Degree or institutional extent of implementation farmer compliance High quality of Implementation implementation of measure by responsible wholly or almost institutions wholly in accordance with management prescriptions. No deviation occurs. Quality of The measure is implementation mostly by responsible implemented institutions is according to the management medium to high. prescriptions. Minor deviations may occur. Degree of Degree of Participation targeting to distribution Participation rates provide a moderate to high proportion of the expected 45 delivering the institutions environmental medium. objective. The management prescriptions are appropriate to achieve the objective, with several deficiencies. Score of 2/5 The measure should make a minor to moderate contribution towards delivering the environmental objective. The management prescriptions are limited in their ability to achieve the objective, with several deficiencies. Score of 1/5 The measure or option should make a minor contribution towards delivering the environmental objective. The management prescriptions are is according to the management prescriptions. Significant deviations often occur. the distribution of the relevant environmental need/impact. A significant amount of participation falls outside the distribution of the relevant environmental need. Quality of The measure is Participation implementation seldom appears random in by responsible implemented institutions is low according to the relation to the management to medium distribution of prescriptions. the relevant Significant environmental deviations need/impact. usually occur. environmental effects the stated objective. Quality of implementation by responsible institutions is low. Participation rates provide only a negligible proportion of the expected environmental effects of the stated objective. The measure or option is rarely implemented according to the management prescriptions. Significant deviations Participation mostly fails to match the distribution of the relevant environmental need/impact. of Participation rates provide a low proportion of the expected environmental effects of the stated objective. 46 Score of 0/5 limited in their ability to achieve the objective, and possess several major deficiencies. The measure or option does not contribute to the environmental objective. almost occur. The responsible institutions fail to achieve appropriate implementation. always The measure or option is not implemented according to the management prescriptions. Significant deviations always occur. Participation There is no participation completely fails to match the distribution of the relevant environmental need/impact. 47 Appendix 2 Table 1a. List of biodiversity options in REPS 3 and REPS 4 and whether they were included in this study Biodiversity option 2A 2B 2C 2D 2E 3A 3B 3C 4A 4B 4C 4D 5A 5B 5C 5D 7A 8A 8B 9A 9B 9C 9D 9E Title Traditional Hay Meadows Species-rich Grassland Use of Clover in Grassland Swards Use of Trailing Shoe Technology Control of Invasive Species Increased Watercourse Margin Exclude bovine access to watercourses Use of Planted Buffer Zones Creation of a New Habitat Broad Leaved Tree Planting Nature Corridors Farm Woodland Establishment Hedgerow Coppicing Hedgerow Laying New Hedgerow Establishment Additional Stonewall Maintenance Increase in Archaeological Buffer Margins Traditional Irish Orchards Bird and Bat Boxes Green Cover Establishment Environmental Management of Setaside Increased Arable Margins Low Input Spring Cereals Minimum-tillage Notes Contribution REPS 3 & 4 REPS 3 & 4 Only REPS4 Included Included Included Only REPS4 Only REPS4 REPS 3 & 4 REPS 3 & 4 Included Included Included Included Only REPS4 REPS 3 & 4 REPS 3 & 4 REPS 3 & 4 Only REPS4 REPS 3 & 4 Only REPS4 REPS 3 & 4 REPS 3 & 4 REPS 3 & 4 Included Included Included Included Included Included Included Included Included Included Only REPS4 Only REPS4 REPS 3 & 4 REPS 3 & 4 but now ended REPS 3 & 4 Only REPS4 Only REPS4 Included Included Included Excluded Included Included Included 48 Table 1b. Supplementary measures in REPS 3 and REPS 4 and details about their inclusion in this study Code Supplementary measure Notes Contribution SM1 SM2 Wild Bird Habitats Traditional Irish Orchard REPS 3 & 4 REPS 3 & 4 SM3 Conservation of Animal Genetic Resources Riparian zones - Salmon/Crayfish, pearl mussel LINNET habitats Organic Farming REPS 3 & 4 Included Same as option 8A Included REPS 3 & 4 Included REPS 3 & 4 REPS 3 only Included Excluded Low Input Cereals Only REPS4 SM7 Minimum-Tillage Only REPS4 SM8 SM9 Only REPS4 Only REPS4 SM10 SM11 Traditional Sustainable Grazing Incorporation of clover into grassland swards Mixed Grazing Lakes and Catchments SM12 Heritage Buildings Only REPS4 Same as option 9D Same as option 9E Included Same as option 2C Included Pilot excluded Excluded SM4 SM5 SM6 2007 SM6 Only REPS4 Only REPS4 49 50