Monday 27 January 2014

Commonage and Agri Environment Schemes

Undergrazed Commonage leading to Purple Moor Grass dominated sward.
Fire Hazard, no winter grazing potential, minimal value to sheep. Can GLAS plans manage this situation?

At the recent Teagasc Hill Sheep conference held in Bantry, Mr Liam Fahey of the Dept. of Agriculture spoke on the subject of the commonages and future agri environment schemes. Management of Commonages and Agri Environment Schemes. In particular he set out the rationale for the grazing agreements that will be a feature of GLAS contracts on commonage farms. He explained the background to the current proposals and how the new approach differs from the implementation of the commonage framework plans. Interestingly he stressed that a grazing agreement and the stock numbers within it applies only to the commonage, it is not a whole farm commitment and that subject to normal GAEC and cross compliance requirements a farmer can keep whatever number of stock he wants on his privately owned land. In addition the new agreement will finally break the last remaining links with the old coupled ewe quota.

There is still no blueprint for the grazing agreement required by the Dept. of Agriculture nor is there any detail on what timescale will be available for drawing up such agreements or on the support that will be available for farmers to assist in this process. Mr Fahey is correct in his assertion that the task of drawing up these agreements will not be easy, however he gave no indication of how long this process would take. The fact is that each commonage is unique and that each agreement will have to be made to measure. It is inevitable that the process will get off to a slow start as it will be a new and unfamiliar program and so adequate time to deliver it is essential although the financing of a number of flagship projects could speed this up considerably. In any case the process must start very soon, certainly no later than early summer this year. If not, than many commonage farmers will find themselves ruled out of GLAS for 2015 due to the absence of a grazing agreement.

We are still unaware of how the Dept. of Agriculture intend the program of developing and negotiating grazing agreements to be financed, one solution may be to use the extra payments allowed for under the provision for GLAS+. The formation of new commonage governance structures at community level certainly qualifies as a "particularly challenging action". I hope that full clarification on what exactly is proposed can be given as soon as possible.

The full transcript of Mr. Fahey's speech at the Teagasc conference follows.

Liam Fahey,
Senior Inspector,
Agri-Environment and Structures Division, Department of Agriculture, Food and the Marine (DAFM)


Agri-environment schemes such as REPS and AEOS compensate farmers for income forgone or costs incurred as a result of participating in an agri-environment scheme. REPS was introduced in 1994 and at its peak in 2007, there were 60,000 farmers in REPS. When REPS 4 closed in 2009; there were approximately 30,000 farmers in the scheme. A total of 1,000 of these farmers completed their 5 year contract at the end of 2012 with a further 12,000 completing their contracts in 2013. The vast majority of the remaining 17,000 farmers will have completed their REPS contract by the end of 2014. The average REPS payment in 2013 was €5,400.

In terms of AEOS, there are approximately 20,000 farmers across AEOS 1, 2 and 3. The AEOS 1 scheme started in September 2010, with AEOS 2 commencing in September 2011. AEOS 3 commenced in May 2013. The average AEOS payment in 2013 was €3,200.

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. There is a substantial risk of land abandonment as under-grazing become 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 the EU Commission. It is vital, therefore, to maintain the commonages in GAEC (Good Agricultural and Environmental Condition), or where there is undergrazing, to return the habitat to GAEC.

The farming of commonages lands has a long tradition in Ireland. It is by its very nature a complex area. In the vast majority of cases, however, commonage shareholders work well together on a cooperative basis. Each year approximately 4.7 million hectares of eligible land is declared by applicants under the Direct Aid and Agri-Environment Schemes. Of that area, in excess of 330,000 hectares of commonage lands are declared – representing 7% of the total area declared. In 2012, almost 15,000 applicants declared commonage lands – equivalent to 11% of scheme applicants.

Commonage lands in Ireland are mainly situated along the western coast, in particular, in Donegal, Mayo, Galway and Kerry. The areas of commonage lands in these counties, as is illustrated below; comprises of almost 71% of the total commonage land declared. (Mayo: 84,000 ha; Kerry: 54,000ha; Donegal: 51,000 ha; Galway: 45,000 ha). Commonage lands include both upland and lowland grazing habitats. However, these lands have been used mainly for the maintenance of sheep flocks. Cattle are also grazed in some commonages as are other animals such as the Kerry Bog Ponies.

The experience to-date since the Single Farm Payment was introduced in 2005 is that there is a growing problem of commonage land being abandoned by farmers. This is not good for the environment, as these areas lose the specific characteristics as natural habitats for flora and fauna. In addition, the creeping ineligibility of these lands under the Single Payment Scheme and other Direct Payment Schemes poses a significant risk to the State in view of the risk of financial corrections being imposed by the European Commission. There was also a need to replace the now outdated and no longer valid Commonage Grazing De-stocking Plans, which were drawn up in the late 1990s to deal with the then over-grazing problem arising from the level of sheep maintained on the hills to maximise farmers' payments under the coupled Ewe Premium Scheme. While overgrazing is still an issue in some known areas, the main problem facing us is the under-grazing of commonages. A variety of reasons have led to a problem with under-grazing:

•Introduction of decoupled payments (SPS) in 2005.
•Age profile of farmers with commonage lands.
•Low market returns – resulting in reduced livestock numbers.
•More attractive returns from off-farm income during the Celtic Tiger era.

Reason for Review

There was an opinion that a number of commonages throughout the country were now reaching a situation where they were undergrazed.
•Sheep prices had improved and there is a renewed demand to increase hill sheep numbers.
•Off-farm employment has decreased significantly with a resultant increased interest by the
younger farmers.
•Requirement under EU Regulations to manage the hills in such a manner as to be
maintained in Good Agriculture Environment Conditions (GAEC).
•Danger of burning where undergrazed has become an issue in recent years.

The objective of the current review of commonages is to ensure:

•That the lands are maintained in Good Agricultural and Environmental Condition (GAEC).
•That the sustainable stocking of all commonage land is achieved.
•Those sheep farmers who may have been destocked in the original CFP can once again increase
sheep numbers subject to NPWS stocking rates for each of the commonages.
•Within a number of years all commonages will continue to be maintained in GAEC, are being
sustainably managed and farmed and are contributing both locally and nationally in terms of the
environment, tourism and biodiversity.

During 2012, DAFM in conjunction with the National Parks and Wildlife Service (NPWS) engaged with all the main farm organisations on setting out a roadmap to ensure that the approx 400,000 hectares of commonage claimed annually by farmers on their SPS continued to remain eligible for Department Scheme Payments. This was in the context of the National Parks and Wildlife Service updating the stocking levels for all commonages which had a CFP. This involved setting an overall total minimum and total maximum stocking level in ewe equivalents (EE) for each commonage to ensure that the commonage was sustainably grazed and to ensure that it remained eligible for Department Scheme payments. The overall total minimum and maximum EE translates into an individual minimum and maximum based on the number of shares and claimants on the commonage.
The main differences from previous CFP are:

  • The minimum/maximum only applies to the commonage. There is no link with privately owned lands.
  • The historic link with ewe premium quota numbers is broken.

Future Schemes

Future agri-environmental schemes offer the opportunity for claimants with commonage land to receive slightly higher payments than a non – commonage farmer where the land is collectively managed. While not all claimants on the commonage would have to be signed up to the collective management plan, it is proposed a baseline of in the region of 60 – 70% participation would be reasonable. While details on a new agri-environmental scheme within the next RDP have yet to be
finalised, higher payments for commonage land managed with a collective management plan offers an opportunity for active claimants to increase their EE numbers on the commonage over and above their individual minimum and maximum levels once they are within the total minimum and maximum figures for the commonage and are managed in accordance with the collective plan drawn up by the claimants on the commonage.


While naturally, there will be reservations from both farmers and farm organisations on any
approach towards collective management of commonages as it also means collective responsibility for all actions carried out on the commonage, the alternative is that commonages in some cases continue to be undergrazed. The risk of undergrazing over multiple years is that eventually these commonages will not be considered to be maintained in GAEC ruling them out of Department scheme payments. The Department will be allowing a lead in time to allow farmers to adjust their EE numbers to comply with each claimant's individual minimum and maximum EE figures within the context of the total minimum and maximum EE for the commonage.


The whole purpose of collective management of commonages is to ensure that these commonages continue to remain eligible for Department scheme payments for the benefits of the claimants on the commonages. Taking all of these matters into account, it is the Department's 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. 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. It will not be an easy task but it is achievable if we all work in a co-operative basis.

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