Monday 16 December 2013

National Peatlands Strategy.

The National Peatlands Strategy will be published before the end of the year. While much of the focus will be on the turf cutting issue on SAC bogs the strategy will also address issues relating specifically to blanket bogs and heaths. These are likely to include turf cutting, forestry, wind farms and climate change. The possibility of new types of funding such as the sale of carbon credits is also likely.

How these issues can be developed in partnership with local landowners and other stakeholders will be challenging. While undoubtedly there is potential in the recognition of the public goods value of peatlands it will be difficult to realise this if funding and political support are limiting.

Wednesday 27 November 2013

REPS/ AEOS Payments to begin.

The minister for agriculture has announced that 50 million euro will be paid out to farmers in REPS 4 and AEOS 1 and 2 next week. This represents the initial 75% payment, it is hoped that the remaining 25% will be paid in the near future.

Wednesday 20 November 2013

Commonage process to commence soon.

Sean Kyne TD along with Eamon O Cuiv TD and Andrew Doyle TD have taken a keen interest in progressing the commonage issue. They and a small number of other Deputies have been pressing the Minister for Agriculture on numerous occasions for an indication as to the long term plan towards addressing the commonage issue. Unfortunately the flow of real information as to the Dept. of Agricultures plans has been painfully slow. However in response to a recent question from Sean Kyne the Minister for Agriculture has revealed in more detail than we have seen up to now, how he sees the situation progressing over the coming months.

"Sean Kyne (Galway West, Fine Gael): To ask the Minister for Agriculture, Food and the Marine when liaison committees will be set up in commonage areas as agreed by him with representatives of farm organisations from Galway and Mayo in 2012 in view of the concerns regarding commonage stocking rates, farmer exiting REP scheme 4, the conclusion of the 12 Bens Scheme and the absence of compensation for special areas of conservation and Natura designations to many farmers in 2014 and if he will make a statement on the matter,

Simon Coveney (Minister, Department of Agriculture, the Marine and Food; Cork South Central, Fine Gael).

The CAP Reform package which I negotiated contains elements which could impact on those farming commonage lands. However, I am awaiting the adoption of EU Commission delegated acts; it is expected that discussion on these delegated acts will be concluded before year-end.
The issue of stocking levels on Commonages and the approach necessary to address what is recognised as a very complex matter which requires a very detailed action plan to cover the various issues, is one which has received widespread coverage.

The report of the Oireachtas Joint Committee on Agriculture is a valuable contribution to the ongoing debate regarding the issues surrounding commonage lands, the views of the various stakeholders having being sought and considered by the Committee. As I have indicated previously, while it is generally accepted that this is a very complex matter and requires a very detailed action plan to cover the various issues, I intend in the near future to set out proposals on how these matters will be progressed. My firm intention is that the process will be fully inclusive and that all stakeholders, particularly farmers and their representatives will be central to the process.

Commonage lands form an important part of the farming enterprises of many farmers, particularly along the West Coast. They also form an important part of the local environment from the point of view of bio-diversity, wildlife, amenities and economic returns e.g. tourism. However, there is a substantial risk of land abandonment as under-grazing becomes more of a problem. Under-grazing leads to an increase in ineligible land under Direct Aid and Agri-Environment Schemes and leads to risk of financial corrections being imposed by EU Commission. It is vital, therefore, to maintain the commonages in GAEC (Good Agricultural and Environmental Condition), or where there is under-grazing, to return the habitat to GAEC.

Taking all of these matters into account, it is my stated aim is to ensure that a practical solution is reached, which will ensure that the current farmers actively farming these lands are protected, that the land is maintained or returned to GAEC and that the requirements of the governing EU Regulations are met. In my view, this can best be achieved by working with the farmers directly managing the lands, relevant State Agencies, the farming organisations and all other interested stakeholders. With regard to the specific recommendations of the Committee contained in their Report, I can confirm that these will be included among the range of issues to be addressed in the process that will shortly be commenced by my Department."

If as is anticipated the delegated acts (technical issues delegated by the Council of Minister and the European Parliament to the Commission) are adopted before the end of the year and the draft RDP is finalised then everything will be in place to allow for the design of a workable solution to the commonage issue. The Joint Committee on Agriculture, the Upland Working Group and others have made positive contributions as to how this can be done. It is a positive development that the Minister for Agriculture has confirmed that the process of developing a new approach to commonage management will commence soon. Hopefully real progress will be seen over the next six weeks.

Sunday 17 November 2013

Publication of new Rural Development Plan

Details of the Rural Development Plan for 2014-2020 will be presented to the National Platform for Biodiversity and Research on December 12th. This will give commonage stakeholders the clearest indication yet of how the Dept. of Agriculture intends to proceed with this issue and what they are willing to pay for.

Tuesday 12 November 2013

Lisadell Judgement, How does this affect access to Commonages?

The Supreme Court judgement on the long running dispute about public rights of way on the Lisadell estate in Co. Sligo may have consequences for access to commonages throughout Ireland. The ruling that a long history of public access does not of itself create a right of way for the public is a welcome development, not just for commonage farmers but also for recreational users of upland areas. For farmers this means that a right of way cannot be created over their lands without their consent, this is a key issue because there is a world of a difference between inviting/ allowing/ tolerating recreational users and granting a permanent right of access to anyone at any time. Ironically if people like those in "Keep Ireland Open" could only see it, this is also of benefit to recreational users of the countryside as it allows the many farmers who welcome visitors to continue to do so without fear of permanently losing control over part of their lands. Had the judgement gone the other way it could have precipitated a rush to block access so as to prevent rights of way from becoming established. I do not believe that such a development would have been in anyone's long term interest.

There is no doubt that the recreational value of upland areas is immense, however it is fraught with difficulties. While walking and climbing based tourism generates welcome business in some rural areas, in most cases there is no viable mechanism to allow the benefits of this to trickle down to the landowner. Comparisons with Scotland or England are not very useful, as in places like the Lake District and much of the Scottish highlands, land ownership remains concentrated in a relatively small number of big estates. This allows the creation of viable walking routes by an individual landowner or a very small group of such owners. This task is more difficult in Ireland as land reform in the 19th/20th centuries means that a useful walking route will have to traverse the properties (both commonage and privately owned) of many different farmers. However "difficult" should not mean impossible and by negotiation the establishment of such routes can and does happen. Indeed many of these routes are already operating very successfully.

The suggestion by "Keep Ireland Open" that farmers representatives at such talks are only interested in the "brown envelope" is not helpful. To assert that seeking to realise a cash benefit from the use of your land is somehow corrupt or sinister is unjustified and does not bring a solution to the access issue any closer.

Thursday 7 November 2013

End of Stocking Restrictions on the 12 Bens and Maumturks. How will this affect Eligibility for the Dis-Advantaged Area Scheme.

The additional measures introduced in Nov 2008 in SAC and Commonage Areas in the Maumturks expire this month. The measures were introduced as following detailed monitoring which established that the expected recovery of vegetation was not taking place. Farmers in these areas were obligated to join either the REPS scheme or the NPWS Farm Plan Scheme. Farmers who were in REPS received a top up from the NPWS to compensate for the additional measures required.

The big issue now for many of these farmers is how this will their eligibility for the Dis-advantaged Area Scheme in 2014 and beyond. Farmers in the 12 Bens/ Maumturks were shielded from the increase in the minimum stocking density requirements for the DAS scheme by their obligations to NPWS. However with these restrictions lifted, the farmers will have to meet the normal DAS qualifying stocking density in 2014, this may in some cases require a considerable increase in stock numbers and or a change in farming system. Making this change in one year may be very difficult for some of them. As the only realistic way of increasing flock sizes in upland areas is by ensuring that the number of ewe lambs retained is greater than the number of cull ewes sold, increasing flock size is limited by the availability of ewe lambs.

If the farmer did not make provision for this this year then he may have real difficulties in 2014. However even if a farmer did retain extra ewe lambs, there is a limit to the possible rate of increase in flock size. In most cases increasing the flock by more than 15-20% in one year is not realistic.

Whether this will be enough to satisfy the new requirements for all of the affected farmers is extremely unlikely. It seems inevitable that unless some transition period is provided for by the Dept. of Agriculture that some farmers are at risk of losing their DAS payment in 2014.

Thursday 17 October 2013

Will the Oireachtas Committee on Agricultures Report be acted on?

Dara Calleary (Mayo, Fianna Fail)

To ask the Minister for Agriculture, Food and the Marine if he will implement the proposals contained within the Joint Committee on Agriculture, Food and the Marine Review of Commonage Lands and Framework Management Plans report; and if he will make a statement on the matter.

Simon Coveney (Minister, Department of Agriculture, the Marine and Food; Cork South Central, Fine Gael)

The report of the Oireachtas Joint Committee on Agriculture is a valuable contribution to the ongoing debate regarding the issues surrounding commonage lands, the views of the various stakeholders having being sought and considered by the Committee. As I have indicated previously, while it is generally accepted that this is a very complex matter and requires a very detailed action plan to cover the various issues, I intend in the near future to set out proposals on how these matters will be progressed. My firm intention is that the process will be fully inclusive and that all stakeholders, particularly farmers and their representatives will be central to the process. It is only by adopting this approach that the desired result can be achieved.
With regard to the specific recommendations of the Committee contained in their Report, I can confirm that these will be included among the range of issues to be addressed in the process that will shortly be commenced by my Department - it very clear that matters to be resolved are very wide ranging and complex; it is self-evident that the process required to adequately address these must be fully inclusive and focused. To this end, I am determined, as indicated, to convene a broad group of all relevant stakeholders, charged with comprehensively addressing the range of issues.
Commonage lands form an important part of the farming enterprises of many farmers, particularly along the West Coast. They also form an important part of the local environment from the point of view of bio-diversity, wildlife, amenities and economic returns e.g. tourism. However, there is a substantial risk of land abandonment as under-grazing becomes more of a problem. Under-grazing leads to an increase in ineligible land under Direct Aid and Agri-Environment Schemes and leads to risk of financial corrections being imposed by EU Commission. It is vital, therefore, to maintain the commonages in GAEC (Good Agricultural and Environmental Condition), or where there is under-grazing, to return the habitat to GAEC.
Following the successful completion of the negotiations on CAP reform under the Irish Presidency on 26 June 2013, I launched a consultation process with all relevant stakeholders to ascertain their views on the most appropriate application of the Direct Payment Regulation. The final date for submissions on the Consultative Paper is 20th September. The agreement provides that where there is marginal land the applicant or applicants must graze that land if he or she is to satisfy the eligibility criteria to be deemed an active farmer for the purposes of benefiting from payment under the Direct Payment Scheme. As most of the commonage land declared in Ireland can only be maintained by grazing, this matter will also have to be dealt with in the context of maintaining commonages in Ireland.
Taking all of these matters into account, it is my stated aim is to ensure that a practical solution is reached, which will ensure that the current farmers actively farming these lands are protected; that the land is maintained or returned to GAEC and that the requirements of the governing EU Regulations are met. In my view, this can best be achieved by working with the farmers directly managing the lands, relevant State Agencies, the farming organisations and all other interested stakeholders. I have no doubt that work undertaken by the Oireachtas Joint Committee on Agriculture will greatly assist in this matter.

Comment, The Minister for Agriculture refers to his intention to convene a broad group of all relevant stakeholders. It is unclear what exactly the Minister means by this, but it does seem that the proposals of the Oireachtas Committee on Agriculture will at least be on the table. We have to agree with the Minister that the issue is complex and are happy that the Oireachtas report is being recognised as a good starting point in this process. It was produced with cross party support, after listening to the views of a wide range of stakeholders and expert commentators. Its suggestions, in particular those referring to the need for a co-operative approach, the importance of avoiding a one size fits all approach and the need for an uplands scheme, although in need of fleshing out are a sound basis for progressing the issue of commonage management. We hope that the process being embarked on by his Department will build on this by continuing the engagement with farmers and relevant experts to design a fair, robust and workable approach that can achieve the desired objectives and recognise the central role played by the farmer in providing a food product and an environmental service.

Tuesday 15 October 2013

Commonage Restrictions in the Twelve Bens/ Maamturks

Commonage Framework Plans

Deputy Éamon Ó Cuív asked the Minister for Agriculture, Food and the Marine if a person in County Galway who is participating in the Twelve Bins/Maam Turk Complex can amend their agri-environment option scheme plan to allow them to put their sheep back on the hill due to the fact that the Twelve Bins/Maam Turk Complex scheme is not being renewed after November; and if he will make a statement on the matter.

Minister for Agriculture, Food and the Marine (Deputy Simon Coveney): I am aware that the Twelve Bins/Maam Turk Complex Scheme, which the National Parks and Wildlife Service put in place for the purpose of regenerating these commonages, expires on 1st November, 2013. The future management of these commonage lands will now be considered in the wider context of the ongoing examination of issues relating to all Commonages. This process will involve the farmers directly managing the lands, relevant stakeholders, the farming organisations and all other interested stakeholders. The aim is to achieve a practical solution which will ensure that the farmers actively farming these lands are protected and that the land is maintained or returned to GAEC and that the requirements of the governing EU regulations are met.

There is nothing new in the Ministers reply to Deputy O Cuiv, this has been the standard line for almost a year now. However there is still no sign of any sort of an implementation plan and the mechanisms to attain the goal of keeping commonages in GAEC are still very unclear. The min/ max figures which the Department believed would deliver a solution are at best only a starting point for an implementation plan for each individual commonage. The other aspects of an implementation plan have never been published, without them the Departments commonage management plans are in disarray.

We can only hope that the draft Rural Development Plan which is expected before the end of the year will shed some light on the Department of Agriculture's intentions.

Tuesday 1 October 2013

No Interim Payments for Farmers in the Twelve Bens/ Maamturks left out of an Agri-environment Scheme.

The NPWS will not be making any interim payments to commonage farmers in the Maamturks/ Twelve Bens who were not in an agri-environment scheme in the period 1/12/12 to 1/5/13. This issue was the subject of a question from Fine Gael TD Sean Kyne to Minister Jimmy Deenihan. Both the original question and the Ministers reply are shown below.

Deputy Seán Kyne asked the Minister for Arts, Heritage and the Gaeltacht if interim payments will be made to farmers in the Twelve Bens region, County Galway, for 1 December 2012 to 1 May 2013 in recognition of the fact that said farmers were unable to avail of the agri-environment options scheme as no applications were accepted.

Deputy Jimmy Deenihan: Farmers in the Twelve Bens-Garraun and Maumturk mountain complex special areas of conservation have had to amend their farming practices since November 2008 to ensure these mountain commonage areas recover from past overgrazing. This grazing restriction continues until November 2013 and will assist farmers in ensuring their lands are deemed to be in good agricultural and environmental condition, as required under cross-compliance requirements. As part of the compensation package that was agreed in 2008, an additional annual payment of €2,000 over five years was to be paid by my Department to those farmers who were in existing rural environment protection scheme, REPS, contracts for the additional grazing restriction.

Over this period, however, the Department of Agriculture, Food and the Marine closed the REPS scheme and replaced it with the more limited agri-environment options scheme, AEOS, which was opened periodically for farmers. As an exceptional measure, my Department put in place a system of interim payments to cover gaps in which farmers could not access AEOS funding during periods when the scheme was closed to applicants. Such interim payments were sanctioned on three occasions, notwithstanding the significant reduction in funding available to my Department over this period. This was much appreciated by the farmers in question. In sanctioning the final interim payments in November 2012, my Department made clear that it would not be in a position to make any further additional payments for the period mentioned in the question. This position has not changed and there is no funding available to my Department to make further interim payments. Since November 2008, my Department has paid more than €2.6 million to farmers in this area of County Galway. As already referred to, the five years of this grazing restriction will terminate in November of this year.

Deputy Seán Kyne: I thank the Minister for his reply. I know similar problems were rectified in late 2012, of which the farmers affected were greatly appreciative. However, the farmers in question were mandated by the National Parks and Wildlife Service, NPWS, to join the Twelve Bens destocking scheme. They simply had no choice. One of the conditions was that they were also mandated to participate in the agri-environment scheme. However, REPS had closed and AEOS was not available for certain periods. The end result was that these farmers were left with no agri-environment payment for 1 December 2012 to May 2013. Will the Minister engage with the Minister for Agriculture, Food and the Marine, Deputy Simon Coveney, to see if a solution can be achieved between the two Departments to provide interim payments to these farmers?
Deputy Jimmy Deenihan: I will consult with the Minister for Agriculture, Food and theMarine, Deputy Simon Coveney. I suggest the Deputy does so himself. This matter has been considered by my Department but there is no funding available to make an interim payment. We have been generous in the past. If the moneys were available, I would be delighted to provide interim payments. I have met the farmers affected, who are very hardworking and need this funding. Later this evening I am having a meeting with farmers from County Mayo with a similar problem. However, to date there is no source of funding

Monday 30 September 2013

IFA Hill Farming Conference

Strong cash support from the Government for hill areas in the 2014–2020 Rural Development Plan is crucial, according to the Irish Farmers Association (IFA).

This support must come through a meaningful Upland Agri-Environment Scheme and increased support under the Disadvantaged Areas Scheme (DAS), according to IFA president John Bryan.

Speaking at the IFA Hill Forum in Tuam, Co Galway at the weekend, the IFA president said that farm incomes in hill areas are in a very difficult position as a result of cutbacks to environmental schemes, reductions in the DAS payments and low market returns for hill lamb.

He referred to one sheep farmer he met at the National Ploughing Championships last week whose income has dropped by up to 60 per cent as a consequence of losing REPS and cuts to the DAS.

"This farmer's situation is reflective of hill farmers in every part of the country," said Bryan. "On top of this farmers in hill areas have been under severe environmental restriction as a result of Commonage Framework Plans, which were introduced over 10 years ago. These plans curtailed production and have added to the income crisis." It would be discriminatory against hill farmers and Minister Coveney must take this into account, as well as not introducing regionalisation in the implementation of the new CAP regime.

At the IFA Hill Forum, speakers from the Department of Agriculture, National Parks and Wildlife Service outlined the issues that are relevant particularly with regard to cross compliance, stocking regime and management plans necessary for these areas.

Also IT Sligo and the Wicklow Upland Council presented options for consideration of a new Upland Management Environmental scheme that would go a long way to replacing the loss of REPS in hill areas.

Lisa Deeney , first published in AGRILAND

www.agriland.ie

Saturday 28 September 2013

Commonage Conference

A conference on commonage issues was held in team yesterday. The well attended meeting heard from representatives of the Dept of Agriculture and the NPWS. The importance  of maintaining uplands in GAEC was emphasised by the Dept of Agriculture and the range of environmental services provided by agriculture in upland areas was highlighted.

Details of a proposed new uplands scheme were presented and while there are a lot of points yet to be worked out, the positives are that it appears that it will be objective based rather than prescription led. The proposals made are very much in line with those suggested by the Oireachtas committee on Agriculture. There does not appear to be any firm commitment from the Dept of Agriculture yet but the time for decision is getting very close.  I would expect some clarity by the time the draft Rural Development Plan is published.

The Dept of Agriculture will be keen to make any scheme as simple to administer as possible. While this is important, administrative convenience must not dictate a one size fits all solution.

It is encouraging that the Dept. of Agriculture have engaged with farmers at this stage. It is to be hoped that they continue to develop a workable scheme in an open manner and with input from farmers and other stakeholders.

Friday 27 September 2013

Minister Coveneys response to the Oireachtas Committee's Report on Commonages.

Sean O Fearghail (Fianna Fail TD for Kildare South) asked the Minister for Agriculture for his reaction to the recently published report of the joint Committee in Agriculture, Food and the Marine on the commonage issue. The full text of the both Mr O Fearghail question and the Ministers response are shown below.

Seán Ó Fearghaíl (Kildare South, Fianna Fail)

To ask the Minister for Agriculture, Food and the Marine the actions he is taking on foot of the report of the Joint Committee on Agriculture, Food and Marine in relation to commonages; if he intends adopting the recommendations in the report; and if he will make a statement on the matter.

Simon Coveney (Minister, Department of Agriculture, the Marine and Food; Cork South Central, Fine Gael)

The report of the Oireachtas Joint Committee on Agriculture is a valuable contribution to the ongoing debate regarding the issues surrounding commonage lands, the views of the various stakeholders having being sought and considered by the Committee. As I have indicated previously, while it is generally accepted that this is a very complex matter and requires a very detailed action plan to cover the various issues, I intend in the near future to set out proposals on how these matters will be progressed. My firm intention is that the process will be fully inclusive and that all stakeholders, particularly farmers and their representatives, will be central to the process. It is only by adopting this approach that the desired result can be achieved.

With regard to the specific recommendations of the Committee contained in their Report, I can confirm that these will be included among the range of issues to be addressed in the process that will shortly be commenced by my Department - it very clear that matters to be resolved are very wide ranging and complex; it is self-evident that the process required to adequately address these must be fully inclusive and focused. To this end, I am determined, as indicated, to convene a broad group of all relevant stakeholders, charged with comprehensively addressing the range of issues.
Commonage lands form an important part of the farming enterprises of many farmers, particularly along the West Coast. They also form an important part of the local environment from the point of view of bio-diversity, wildlife, amenities and economic returns e.g. tourism. However, there is a substantial risk of land abandonment as under-grazing becomes more of a problem. Under-grazing leads to an increase in ineligible land under Direct Aid and Agri-Environment Schemes and leads to risk of financial corrections being imposed by EU Commission. It is vital, therefore, to maintain the commonages in GAEC (Good Agricultural and Environmental Condition), or where there is under-grazing, to return the habitat to GAEC.

Following the successful completion of the negotiations on CAP reform under the Irish Presidency on 26 June 2013, I launched a consultation process with all relevant stakeholders to ascertain their views on the most appropriate application of the Direct Payment Regulation. The final date for submissions on the Consultative Paper is 20th September. The agreement provides that where there is marginal land the applicant or applicants must graze that land if he or she is to satisfy the eligibility criteria to be deemed an active farmer for the purposes of benefiting from payment under the Direct Payment Scheme. As most of the commonage land declared in Ireland can only be maintained by grazing, this matter will also have to be dealt with in the context of maintaining commonages in Ireland.
Taking all of these matters into account, it is my stated aim is to ensure that a practical solution is reached, which will ensure that the current farmers actively farming these lands are protected; that the land is maintained or returned to GAEC and that the requirements of the governing EU Regulations are met. In my view, this can best be achieved by working with the farmers directly managing the lands, relevant State Agencies, the farming organisations and all other interested stakeholders. I have no doubt that work undertaken by the Oireachtas Joint Committee on Agriculture will greatly assist in this matter.

Tuesday 24 September 2013

Disadvantaged Area Payments to begin.

The Minister for Agriculture has announced that payments under the DAS scheme will begin tomorrow. 60,000 farmers have been already been cleared for payment. Additional payment runs will be made every fortnight to pay farmers as their cases are cleared.

No New Agri Environmental Scheme in 2014.

No new agri environmental scheme for 2014.There will be no new environmental scheme for 2014. The Minister for Agriculture has ruled out any new package until the CAP comes into effect from January 2105. While this is a disappointment it is not a big surprise. Aside from any financial considerations the Dept. of Agriculture would have been reluctant to get involved with any multi annual scheme at this stage in the CAP cycle.

What is needed now is an assurance that the rules of any new scheme are published as soon as is practical after the Rural Development Plan is approved in Brussels. And that an application period for the new agri-environmental scheme opens in the second half of 2014, even if contracts are not to begin until January 2015. The danger is that this will not happen and that the application window will be short and will not open until spring 2015. This would repeat the mistakes of AEOS 1 and 2 and would ensure that farmers would not get a full years agri-environment payment until late 2016 at the earliest and possibly as late as 2017. This would defeat the whole point of the Pillar II measures within the CAP and would leave many commonage farmers without a meaningful agri-environment payment for more than 3 years.

Monday 23 September 2013

Statement by the Minister for Arts, Heritage and the Gaeltacht.

The Minister for Arts, Heritage and the Gaeltacht Jimmy Deenihan gave the following response to Fine Gael T.D. Andrew Doyle to a question he raised in the Dail yesterday. Like his cabinet colleague Simon Coveney the Minister is not giving much away but it would appear that his Department remains committed to having some input into the commonage review process.

Andrew Doyle (Wicklow, Fine Gael)
737. To ask the Minister for Arts, Heritage and the Gaeltacht his views on the July 2013 report entitled "Review of Commonage Lands and Framework Management Plans", produced by the Joint Committee on Agriculture, Food and the Marine; his views on the ten recommendations contained in this report; and if he will make a statement on the matter. [37247/13]

Jimmy Deenihan (Minister, Department of Arts, Heritage and the Gaeltacht; Kerry North-West Limerick, Fine Gael).
I welcome the Joint Committee report and I believe that it reflects the many complex issues that were discussed over numerous sittings, and that its recommendations are useful. I should, however, clarify that while my Department has had a substantial advisory role in relation to commonages, it is not responsible for the implementation or regulation of the commonage review process, which is a matter for the Department of Agriculture, Food and the Marine.

I believe that further engagement between the relevant parties is necessary so that commonage land is managed appropriately and sustainably. I have, therefore, ensured that my officials will continue to engage with farmers, staff of the Department of Agriculture, Food and the Marine and other interests in terms of the future implementation of the commonage review process, insofar as it relates to the functions of my Department

Statements by the Minister for Agriculture.

The Minister for Agriculture Simon Coveney gave the following responses to Andrew Doyle T.D., Michael Healy Rae T.D. and Joe McHugh T.D. to questions that they raised in the Dail yesterday. There is nothing very new in any of the responses but they do give some indication of Department of Agriculture policy on the commonage issue.

Andrew Doyle (Wicklow, Fine Gael)
1170. To ask the Minister for Agriculture, Food and the Marine his views on the July 2013 report that was laid before the Houses of the Oireachtas entitled Review of Commonage Lands and Framework Management Plans produced by the Oireachtas Joint Committee on Agriculture, Food and the Marine; his views on the ten recommendations contained in this report; and if he will make a statement on the matter. [37246/13]
Simon Coveney (Minister, Department of Agriculture, the Marine and Food; Cork South Central, Fine Gael) | Oireachtas source
The report of the Oireachtas Joint Committee on Agriculture is a valuable contribution to the ongoing debate regarding the issues surrounding commonage lands, the views of the various stakeholders having being sought and considered by the Committee. As I have indicated previously, while it is generally accepted that this is a very complex matter and requires a very detailed action plan to cover the various issues, I intend in the near future to set out proposals on how these matters will be progressed. My firm intention is that the process will be fully inclusive and that all stakeholders, particularly farmers and their representatives will be central to the process. It is only by adopting this approach that the desired result can be achieved.
With regard to the specific recommendations of the Committee contained in their Report, I can confirm that these will be included among the range of issues to be addressed in the process that will shortly be commenced by my Department - it very clear that matters to be resolved are very wide ranging and complex; it is self-evident that the process required to adequately address these must be fully inclusive and focused. To this end, I am determined, as indicated, to convene a broad group of all relevant stakeholders, charged with comprehensively addressing the range of issues.
Commonage lands form an important part of the farming enterprises of many farmers, particularly along the West Coast. They also form an important part of the local environment from the point of view of bio-diversity, wildlife, amenities and economic returns e.g. tourism. However, there is a substantial risk of land abandonment as under-grazing becomes more of a problem.
Under-grazing leads to an increase in ineligible land under Direct Aid and Agri-Environment Schemes and leads to risk of financial corrections being imposed by EU Commission. It is vital, therefore, to maintain the commonages in GAEC (Good Agricultural and Environmental Condition), or where there is under-grazing, to return the habitat to GAEC. It is my stated aim that this will be achieved by working with the farmers directly managing the lands, relevant State Agencies, the farming organisations and all other interested stakeholders


Michael Healy-Rae (Kerry South, Independent)
1168. To ask the Minister for Agriculture, Food and the Marine his views on the EU policies that have resulted in the de-stocking of many hills over the past number of years which has resulted in areas becoming overgrown (details supplied); and if he will make a statement on the matter. [37186/13]
Simon Coveney (Minister, Department of Agriculture, the Marine and Food; Cork South Central, Fine Gael) | Oireachtas source
Commonage lands form an important part of the farming enterprises of many farmers, particularly along the West Coast. They also form an important part of the local environment from the point of view of bio-diversity, wildlife, amenities and economic returns e.g. tourism. However, there is a substantial risk of land abandonment as under-grazing becomes more of a problem.
Under-grazing leads to an increase in ineligible land under Direct Aid and Agri-Environment Schemes and leads to risk of financial corrections being imposed by EU Commission. It is vital, therefore, to maintain the commonages in GAEC (Good Agricultural and Environmental Condition), or where there is under-grazing, to return the habitat to GAEC. It is my stated aim that this will be achieved by working with the farmers directly managing the lands, relevant State Agencies, the farming organisations and all other interested stakeholders.
In terms of support for those farming commonage lands, it should not be lost sight of that support is already provided through a range of Schemes, including the Single Farm Payment Scheme, Disadvantaged Areas Scheme and the Grassland Sheep Scheme, among others, including environmental support measures. The Grassland Sheep Scheme and the related Sheep Technology Adoption Programme are particularly supportive of farmers with commonage lands, albeit that neither is specifically confined to those farming commonage lands only.
The Grassland Sheep Scheme, as originally implemented, was to run for three years: 2010, 2011 and 2012, with an annual budget of €18 million. However, as the Deputy will be aware, I was in a position to secure funding which allows the Scheme continue for a fourth year, notwithstanding continued adverse budgetary conditions, albeit with adjusted funding of €14 million.
I also decided to make funding of €3 million available for a new Sheep Technology Adoption Programme, which concept has already proven very successful in both the dairy and beef sectors, with a maximum payment of €1,000 per participant. It is important that sheep farmers take action to increase and maximise their income from their enterprises. This can be achieved by improving breeding, animal health/welfare and grazing regimes. The dairy sector has demonstrated that the discussion group concept to achieve such improvements. Notwithstanding the financial adjustment made to the overall funding to the Grassland Sheep Scheme, hill sheep farmers, who join a Sheep Discussion Group will find that the aid they will receive in 2013 will increase by almost €590.

Joe McHugh (Donegal North East, Fine Gael)
1165. To ask the Minister for Agriculture, Food and the Marine if he will provide a list of commonages in County Donegal and his views on those properties in view of the report on the review of commonage lands and framework management plans. [37044/13]
Simon Coveney (Minister, Department of Agriculture, the Marine and Food; Cork South Central, Fine Gael) | Oireachtas source
Commonage lands form an important part of the farming enterprises of many farmers, particularly along the West Coast. They also form an important part of the local environment from the point of view of bio-diversity, wildlife, amenities and economic returns e.g. tourism. However, there is a substantial risk of land abandonment as under-grazing becomes more of a problem.
Under-grazing leads to an increase in ineligible land under Direct Aid and Agri-Environment Schemes and leads to risk of financial corrections being imposed by EU Commission. It is vital, therefore, to maintain the commonages in GAEC (Good Agricultural and Environmental Condition), or where there is under-grazing, to return the habitat to GAEC. It is my stated aim that this will be achieved by working with the farmers directly managing the lands, relevant State Agencies, the farming organisations and all other interested stakeholders.
I readily acknowledge that it will not be an easy task, but it is achievable if all stakeholders work in a co-operative basis. If action is not taken now, the areas will continue to deteriorate and will lead to more land abandonment. If this is allowed to happen, Ireland will lose a valuable resource from the point of view of farming, rural economy, bio-diversity and wildlife. While grazing is the only method of managing these lands, the task facing us is how to ensure that these grazing levels are appropriate to the individual commonages.
In order to ensure that the achievement of this objective, as already stated, we need the input of individual shareholders. Grazing plans, at the level of each commonage, will allow for greater flexibility for shareholders and will enable the active farmers to increase their stock to cater for dormant and inactive persons. It will be matter for agreement between the shareholders – as was always the case – to decide how best to reach the stocking levels. Professional assistance will be required, in particular where the commonage has been damaged by under-grazing.
The Grazing Plan will have to cater the traditional farming methods for the area, with provision made for sheep and other animals, such as cattle, providing that they are appropriate to the habitat. An appropriate time-scale will have to be put in place but the Plan should include the incremental steps to achieve GAEC. The whole concept will be output driven, in that the assessment of the Plans will be based on whether the commonage is in GAEC or not or whether the appropriate progress has been achieved.
Apart from ensuring that the Grazing Plan is valid, there are a number of other complications, including:
- Dormant shareholders – in the majority of cases, these persons are no longer farming;
- Current claimants on the commonages, who do not farm or manage the lands. The issue of whether the latter claimants will continue to be eligible for payment will have to be examined.
There are other issues that will need to be considered. These include the fact that many commonage habitats have been significantly damaged by under-grazing, with resulting problems that must be addressed including land abandonment, spread of scrub and invasive species.
The report of the Oireachtas Joint Committee on Agriculture is a valuable contribution to the ongoing debate regarding the issues surrounding commonage lands, the views of the various stakeholders having being sought and considered by the Committee. As I have indicated previously, while it is generally accepted that this is a very complex matter and requires a very detailed action plan to cover the various issues, I intend to set out proposals on how these matters will be progressed in the near future. My firm intention is that the process will be fully inclusive and that all stakeholders, particularly farmers and their representatives will be central to the process. It is only by adopting this approach that the desired result can be achieved.

Thursday 25 July 2013

Oireachtas Report on Commonages 2013

The Joint Committee on Agriculture, Food and the Marine have produced their report n the review of commonage lands. It is a useful synopsis of current thinking and the proposals made to the Committee by a range of stakeholders. The big uncertainty is the degree to which the Dept of Agriculture will support it. 



Click link below to Download Report: (PDF)

Monday 13 May 2013

The Ministers plan for a new Commonage Management Regime Imminent


The Minister for Agriculture has confirmed that a new system for managing commonage is to be put in place in the near future. In reply to a question for Deputy Joe McHugh on May 8th, the Minister announced that;

“In order to ensure that the achievement of this objective, as already stated, we need the input of individual shareholders. Grazing plans, at the level of each commonage, will allow for greater flexibility for shareholders and will enable the active farmers to increase their stock to cater for dormant and inactive persons. It will be matter for agreement between the shareholders – as was always the case – to decide how best to reach the stocking levels. Professional assistance will be required, in particular where the commonage has been damaged by under-grazing.”


While acknowledging that this was a complex matter the Minister stated that he intends to set out proposals on how this matter is to be progressed in the near future.

A full transcript of the Ministers statement is given below. 


Commonage Division



Deputy Joe McHugh 


Asked the Minister for Agriculture, Food and the Marine the proposals he has to update regulation of commonage lands; and if he will make a statement on the matter. 

Minister for Agriculture, Food and the Marine (Deputy Simon Coveney): Commonage lands form an important part of the farming enterprises of many farmers, particularly along the West Coast. They also form an important part of the local environment from the point of view of bio-diversity, wildlife, amenities and economic returns e.g. tourism. However, there is a substantial risk of land abandonment as under-grazing becomes more of a problem. 

Under-grazing leads to an increase in ineligible land under Direct Aid and Agri-Environment Schemes and leads to risk of financial corrections being imposed by EU Commission. It is vital, therefore, to maintain the commonages in GAEC (Good Agricultural and Environmental Condition), or where there is under-grazing, to return the habitat to GAEC. It is my stated aim that this will be achieved by working with the farmers directly managing the lands, relevant State Agencies, the farming organisations and all other interested stakeholders.

I readily acknowledge that it will not be an easy task, but it is achievable if all stakeholders work in a co-operative basis. If action is not taken now, the areas will continue to deteriorate and will lead to more land abandonment. If this is allowed to happen, Ireland will lose a valuable resource from the point of view of farming, rural economy, bio-diversity and wildlife. While grazing is the only method of managing these lands, the task facing us is how to ensure that these grazing levels are appropriate to the individual commonages.

In order to ensure that the achievement of this objective, as already stated, we need the input of individual shareholders. Grazing plans, at the level of each commonage, will allow for greater flexibility for shareholders and will enable the active farmers to increase their stock to cater for dormant and inactive persons. It will be matter for agreement between the shareholders – as was always the case – to decide how best to reach the stocking levels. Professional assistance will be required, in particular where the commonage has been damaged by under-grazing. 

The Grazing Plan will have to cater the traditional farming methods for the area, with provision made for sheep and other animals, such as cattle, providing that they are appropriate to the habitat. An appropriate time-scale will have to be put in place but the Plan should include the incremental steps to achieve GAEC. The whole concept will be output driven, in that the assessment of the Plans will be based on whether the commonage is in GAEC or not or whether the appropriate progress has been achieved. 

Apart from ensuring that the Grazing Plan is valid, there are a number of other complications, including:

- Dormant shareholders – in the majority of cases, these persons are no longer farming;

- Current claimants on the commonages, who do not farm or manage the lands. The issue of whether the latter claimants will continue to be eligible for payment will have to be examined. 

There are other issues that will need to be considered. These include the fact that many commonage habitats have been significantly damaged by under-grazing, with resulting problems that must be addressed including land abandonment, spread of scrub and invasive species.

While it is generally accepted that this is a very complex matter and requires a very detailed action plan to cover the various issues, I intend to set out proposals on how these matters will be progressed in the near future.

Friday 22 February 2013

Commonage Lands

Agriculture Committee to continue discussions on use of Commonage lands

The Oireachtas Joint Committee on Agriculture, Food and the Marine met with officials from
Teagasc, the Golden Eagle Trust and the NARGC on February 12th to hear from them how they
see the commonage management issue progressing. If you wish to see a transcript of this debate it
can be downloaded from the link on this page

The Oireachtas Joint Committee on Agriculture, Food and the Marine will meet with officials from
the Dept of Agriculture and the NPWS on Feb 19th 2013 to further discussions to further their
debate on commonage management. A transcript of this hearing should be available on www.
yourcommonage before the end of the month. It is hoped that this meeting can give us some insight
into how the Dept. of Agriculture thinking on the matter and on what their favoured approach is
likely to look like.

Tuesday 12 February 2013

Joint Committee on Agriculture, Food and the Marine Meeting

Joint Committee on Agriculture, Food and the Marine
to discuss Commonage Issues.

The Joint Committee on Agriculture, Food and the Marine will meet this Tuesday, 12 February with representatives from Teagasc to discuss the use of commonage lands and proposals to ensure good agricultural and environmental practices on farms. The Joint Committee will also meet with representatives from the National Association of Regional Game Councils and Golden Eagle Trust Ltd. to discuss the development of a new agri-environment scheme for the Irish uplands under the Rural Development Programme.

Monday 11 February 2013

Eligibility of Commonage for consideration as Forage Area


Keelderry Commonage Dispute.

Readers of the Irish Farmers Journal (9/2/13) may have noticed an article about the eligibility of land as forage area on the Keelderry Commonage in south Galway.  While this is a complicated case, it arose from a series of inspections by local Dept. of Agriculture staff.  These inspections determined that there was no eligible land on the commonage.  Following an appeal, an area supervisor increased this to 10% eligibility.  While this particular case is now subject to a review by the petition Committee of the European Parliament it highlights a problem that will affect all upland commonages in the near future. 

The core of the issue is that where there is little or no agricultural activity and where the habitat is a climax community, i.e. where it is maintained in its present condition by natural processes alone there is no justification for considering the land as being part of a farms utilisable agricultural area.  This is the case on many uplands, in particular those dominated by blanket bog.  

The recent max/ min figures for commonage published by the Dept of Agriculture may provide a way out of this difficulty for all concerned.  If the shareholders can demonstrate that the commonage is being farmed sustainably and that real agricultural activity is occurring than a determination that large parts of the commonage are ineligible can be avoided. 

To demonstrate this however creates several real difficulties for the active shareholders.  These include;
1) The real difficulty faced by individual farmers in appealing a determination that a large proportion of commonage is ineligible.  In such a case the Dept of Agriculture will write to all the farmers who have declared shares on the commonage informing them of an over claim. If even one applicant accepts this, either by carelessly signing and returning the form or in the hope of removing a barrier to their payments than the position of the remaining farmers is undermined.  

2) While the stock numbers on each farm and hence the whole farm stocking rate can be relatively easily determined, the level of stocking on the commonage itself is difficult to establish.
3) Inactive shareholders who do not contribute to a solution.

Understandably the reference area for the parcel applies to all the share-holders; however the implications of this will vary considerably.  In cases where the commonage share represents a small proportion of the overall farm area the resulting penalties may be very small.  While other farmers in the same commonage for whom the commonage makes up a greater proportion of their overall farm area the risk of punitive penalties for over-claiming forage area under all schemes is very real.  

This is an example of how essential it is that shareholders have a joint approach to issues of common concern.  If the shareholders as a group can decide on a common position how their commonage is managed including stocking rates and appeals against inspection findings then they will be able to respond effectively to threats like what faced the shareholders in Keelderry. 

Monday 4 February 2013

Good News AEOS 3 Commonage Applicants


Good news for commonage applicants to AEOS 3.  Although the scheme was over-subscribed, with 10,000 farmers applying for only 6,000 contracts, it appears that only 4,600 applicants had commonage, SAC or SPA lands.  As applicants in these categories have been prioritized it would appear that all valid applications from commonage farmers will be accepted. 

The situation for non commonage, non SAC/SPA farmers is more uncertain and it is likely that only one in four will be accepted into the scheme. The Dept of Agriculture will write to all applicants in the coming months confirming the status of their applications. 

Tuesday 29 January 2013

Commonage Management - The Issues


The current impasse in respect of the introduction of proposed new stocking levels has generated controversy throughout commonage areas. It is clear that the Dept of Agriculture have failed to adequately communicate their objectives and to explain the implementation plan to the farming community. The present situation benefits no one and we can only hope that a resolution can be achieved sooner rather than later.

Let us consider the main issues of concern that have been raised by the farmer’s representative bodies and the Dept of Agriculture.

The Farming Community Position. 

As a prelude to this section I must make clear that I am not a representative of the farming community but am attempting to paraphrase the comments of others including ordinary farmers and the various farming organisations as honestly as I can. 

Collective Agreements, farmers are legitimately concerned about the practicalities of achieving a collective agreement with other shareholders. The lack of clarity on how issues such as difficult shareholders, the role of facilitators, the time available for drawing up agreements and the lead in time for adjusting flock sizes to the required numbers has created unnecessary confusion. There are legitimate concerns about the transfer of responsibility from the Dept of Agriculture to ordinary shareholders. The assertion that the responsibility for dealing with third parties or errant shareholders is a civil matter and not a concern of the Dept of Agriculture is not helpful. 

Penalties, farmers are legitimately concerned about the prospect of being penalised for the sins of others. 

Damage caused by third parties. The issue of unfenced boundaries of commonages and the grazing of stock belonging to people who are not shareholders at all. This is a widespread problem and creates real difficulties for shareholders who may try to stock their commonage appropriately and yet due to open boundaries have to deal with extra stock coming in from adjacent commonages. The reverse is also possible, where shareholders increase their stock numbers to meet minimum requirements and yet the stock stray to neighbouring lands due to the poor palatability of the vegetation on undergrazed hillsides.    

Dormant/inactive shareholders. How commonages with large numbers of dormant or inactive shareholders can be managed appropriately. Very often large commonage shares are paired with small areas of poor quality enclosed land. The capacity of the enclosed lands places a very real ceiling to the size of the flock/ herd that the farm can support. An attempt to force farmers in this situation to make up for the large number of dormant shareholders could create more problems than it solves. Among the problems created are: 
  • Overgrazing and soil enrichment on an inadequate area of enclosed lands being used for lambing, tupping etc, leading to a possible breach of GAEC standards on the inside land and possible eutrophication of soils and watercourses
  • A greater dependency on supplementary feeding particularly on enclosed lands. This has a negative impact on both the farmer’s margins and on the potential for soil eutrophication and nutrient runoff.
  • Poorer lambing and weaning rates as more ewes may have to lamb on the open commonage. This also impacts negatively on the already tight margins associated on these farms.
  • Uneven utilisation of the commonage area, with possible localised overgrazing in the vicinity of feeding stations and under grazing on areas not favoured by flocks. 
  • There is also the legitimate question as to how farmers can be expected to maintain all of a parcel in GAEC yet only be eligible for payment on a small proportion of the parcel. It is clear that in some cases an attempt to reach minimum stock numbers on large commonages with large numbers of dormant shareholders could be economically and environmentally unsustainable. 

The Dept. of Agriculture’s position. 

EU Pressure. The EU Commission requirement for lands on which payment is made to be maintained in Good Agricultural and Environmental Condition. EU audits which have discovered obviously undergrazed commonages have resulted in the Dept of Agriculture coming under sustained pressure from the EU Commission over whether commonage lands are being kept in GAEC. 

Dormant shareholders. The large numbers of dormant shareholders who are drawing down payments on land that they do not farm. This is a particularly serious issue in respect of schemes supported by Pillar II payments. Due to the financial constraints faced by the Government, co-funded schemes such as the dis-advantaged areas scheme and agri-environment schemes are under severe pressure and facing further cuts. The continued diversion of resources to people who do not farm a commonage is effectively forcing further cuts on active farmers. These cuts undermine the schemes, their objectives and future sustainability. 

Continued eligibility of commonage lands. The question mark over the continued eligibility of commonage to be considered as forage area. The eligibility of some commonage lands to be considered as forage area is in some doubt, if the area under scrub or rank heather expands or if overgrazing continues. This is already leading to large reductions in the reference area for some commonages. This is a penalty in all but name as it reduces the eligible area for all shareholders and undermines active farmers. 

AEOS 3. Due to the selection mechanism for AEOS 3 applicants, the scheme will be dominated by commonage farmers. The minimum and maximum stock numbers planned for these farmers only takes into account their share of the commonage. The figures were only ever considered as provisional pending a commonage agreement between the shareholders on the commonage in question. It was also made clear during the application periods for that scheme that an appeal mechanism would be put in place. Without these steps the entire AEOS 3 scheme is hollowed out. The commitments made by many applicants and the overall commonage objectives set by the Department are unachievable without the initially planned follow through with appeals and subsequent commonage wide agreements. 

Administrative overheads. A desire to ensure a simple and uniform approach to all commonages (from the Dept of Agriculture’s perspective). This is understandable in the context of reducing the administrative burden of administering any system that may be put in place. 


Points to Consider. 

It is clear that all parties have very legitimate concerns in respect of what a solution to this problem should look like. While it is not my intention to present a solution to all of these issues, I believe that any solution should;

Recognise that the situation on every commonage is different and that a one size fits all approach is not going to be workable. 

Be objective oriented rather than prescription oriented. The objective being to maintain sustainable agriculture on commonage lands. This implies a realisation by all sides that maintaining vegetation in GAEC is a good thing, as it secures direct payments, maintains agricultural production and protects agricultural resources, river catchments and landscapes of heritage and conservation value. It also avoids any penalisation of farmers for minor breaches of stock numbers where no damage is being caused. 

While the devolution of decision making to the active farmers in a commonage is the ideal approach there is a need for a default mechanism where such agreement is not possible. This could perhaps allow for a qualified majority of active shareholders to form an agreement, perhaps 80%. Shareholders outside such an agreement could be restricted to the maximum/ minimum figures based on their share and have a guaranteed right to join the collective agreement if they so desire. 

Define what GAEC in respect of upland commonages actually means. While this may seem a very basic question, it is one that has never been adequately addressed. The Dept. of Agriculture has long stated that rank heather cannot be considered as being in GAEC but have ignored rank Purple Moor Grass (Molinia caerula). The window for utilising this grass is short, in particular for sheep and it is arguable that it is a bigger problem than rank growth of a woody plant such as heather. 

Use the maximum/ minimum stocking figures for stock numbers on each commonage as guidelines and not as an end in themselves. The objective is after all to maintain the lands in GAEC and this should be the objective. Breaches of advised stock numbers should be considered as warning signs that a problem may exist. Such breaches could be used to identify commonages where further investigation of the condition of vegetation is warranted. They should not be used to penalise farmers either individually or collectively without evidence that the land is not meeting the GAEC standard. Vegetation change in all but the most extreme cases is a slow process that takes place over years rather than weeks or months. Changes in flock sizes will occur in response to seasonal factors, market fluctuations and the personal circumstances of individual farmers. Such changes of themselves do not necessarily cause a problem particularly if they are of short duration. Also In many cases the shareholders as a group may be able to rebalance their agreement to deal with the matter internally if given sufficient time. 

Allow an adequate timeframe for farmers to reach agreement and to adjust flock/ herd sizes. 

Provide a meaningful information campaign to explain what is intended, its objectives and what is required of individual farmers along with a facility to answer farmers queries.


Conclusion. 

The situation is not without hope for the future. With imagination and an acceptance by all sides of the multi faceted nature of the commonage problem a solution is possible. However this issue cannot be put on the back burner. All parties would agree that support from the next round of CAP funding is essential for commonage farmers. To obtain the maximum benefit from this funding agreement on a process is required sooner rather than later. All parties should note that any workable solution will require a considerable length of time to implement, time that will not be available if agreement on a process is put on hold.

Monday 28 January 2013

Commonage Impasse

The Dept of Agriculture have delayed the issuing of letters to individual commonage farmers informing them of new commonage requirements. The current state of play is unclear however The Minister for Agriculture Simon Coveney T.D. has responded to numerous parliamentary questions from among others Sean Kyne T.D., Joe McHugh T.D. and Eamon O Cuiv T.D.. The standard response in each case has been;

“The Commonage Framework Plans, first published in 2002, have been reviewed to take account of the current vegetative condition of commonages nationally. This review which will replace the Commonage Framework Plans has been carried out by the National Parks and Wildlife Service in co-operation with my Department. The review was carried out on a commonage LPIS basis and sets a minimum and maximum number of ewe equivalents (EE) required to graze the commonage parcel to ensure that it is maintained in Good Agricultural and Environmental Conditions (GAEC). I am currently considering an implementation plan to take account of the changed stocking levels. 
My Department is trying to reconcile the reality of commonages with the EU requirement of GAEC. I will work with the farmers, farm organisations and others to design a practical solution”. 

This answer is obviously just a holding statement, how far things have actually progressed since mid November is uncertain. The Christmas break, the burger scandal and the start of the EU presidency have probably all served to push the commonage issue further down the priority list. However the issue is still live and will have to be addressed at some time in the next year.