The Dept. of Agriculture have recently published their proposals for ensuring that commonage lands remain eligible for direct payments in the next round of the Common Agricultural Policy. The background to this move includes the impact of the significant changes in the structure of the CAP (Common Agricultural Policy) after 2014. The EU Commission is proposing that direct payments should progressively converge and payments to large beneficiaries be subject to progressive capping. Within Ireland this proposal would have effect of reducing the value of the single payment scheme entitlements received by large farms principally in the south east and increasing the value of those held by farmers in the west of Ireland. While the extent of this change is still under negotiation it is likely that western farmers and in particular Suckler Cow and Sheep enterprises could be significant beneficiaries.
The present CAP is based on a two pillar structure. In simple terms Pillar I pays for the Single Payment Scheme, Pillar II is for Rural development and co-finances the agri-environment schemes, e.g. REPS/ AEOS along with the Dis-Advantaged areas scheme. At the moment most commonage farmers payments are dominated by REPS/AEOS and the Dis-advantaged area payment with the Single Payment Scheme a poor third in many cases. This is not the case on a national level where the Single Payment Scheme is by far the most important source of direct payments. Even a partial implementation of the EU Commission proposals will lead to a change both in the size of direct payments to commonage farmers but also in makeup of these payments. In particular it is likely that the Single Payments Scheme or its successor will become more important to the commonage farmer. One benefit of this is that this payment is completely financed by the EU and so is not exposed to budget cuts in Ireland.
While the new CAP offers significant opportunities for commonage farmers, the key challenge is to ensure that the land on which the payments could be drawn down remains eligible. An understanding of the purpose and objectives of these payments is central to appreciating the impact on current practices. A key objective of EU funding is to support farmers in adopting and maintaining farming systems and practices that are favourable to environmental and climate objectives. The direct payments are in part, a payment for the provision of these public goods, i.e. land in GAEC (Good Agricultural and Environmental Condition). The difficulty for commonage farmers is that if these public goods are not provided then how can they be paid for?
In a shared grazing resource like commonage, the primary issue is whether the public goods, i.e. land in GAEC that are being paid for by direct payments are being provided or not. The issue of who is responsible for a failure to provide them is very much a secondary issue and one primarily for the landowners themselves. The challenge therefore for both the Dept of Agriculture and for commonage shareholders is to ensure that as much commonage land as possible remains eligible for direct payments.
The Dept. of Agricultures response to this challenge is to introduce a requirement for Collective Agreements on stock numbers between the shareholders on each commonage. This appears to solve the eligibility issue; the maintenance of land in GAEC then becomes an ongoing requirement for the shareholders themselves based on the implementation of these agreements. A lead in time of two years has been proposed by the Dept of Agriculture to achieve the required stock numbers. At this point it is important to appreciate that the situation in every commonage is different, some commonages are already in GAEC, other suffer from under grazing, some are still damaged by overgrazing. In addition the farmers involved in each commonage are different; they have different enterprises and different views on how the commonage should be managed. Considering all of these differences it is clear that imposing a one size fits all solution is not realistic and that the only way to accommodate the wide range of situations is to involve the shareholders themselves in the decisions affecting their commonage.
The proposals made by the Dept of Agriculture are radical and represent the greatest change to commonage management since the introduction of the commonage framework plans. Like the situation in the late 1990’s action is required in order to assure the continued eligibility of commonage for direct payments. Unlike the commonage framework plans which were imposed from above, a large part of the current proposals involve devolving decision making down to the shareholders of each commonage. The shareholders of the commonage perform this role by participating in a collective agreement. The objective is to ensure that the land is maintained in GAEC and so secure continued eligibility for payments. To assist in this process the Dept of Agriculture and the NPWS have calculated maximum and minimum stocking levels for each commonage land parcel. This was based on the stock carrying capacity of the habitats involved, their condition when the commonage framework plans were produced and the expected recovery in condition since then. The expected recovery was based on that observed during a wide ranging monitoring program over the past 10 years. Where the shareholders believe that these figures are incorrect they can be appealed.
While the Dept of Agriculture have made these maximum and minimum figures available it is for the shareholders through their collective agreement to decide on how a stock number between the maximum and the minimum can be best achieved.
The changes that are underway are dramatic but they offer the potential for increased payments which will be secured until 2020 along with an opportunity in some commonages for active farmers to develop their enterprise. Commonage is a shared resource, by co-operating with each other; farmers can ensure that they share in the benefits from this resource. While the process will present difficulties, it would be a mistake to dwell on problems elsewhere or mistakes made in the past. In difficult times making use of the opportunity presented, getting as good a deal as possible particularly in respect of the lead in time and addressing local issues by considering an appeal appear to be better strategies.