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.
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.