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. 

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