Monday 24 February 2014

Dormancy Rates on Irish Commonages

Analysis of 2012 LPIS data showing commonages and Herd No.'s declaring commonage shares.

County          Area        Ref Area            No.                       Herd               % of                Dormancy
                                                                   of                          No's           Commonage             Rate
                                                           Commonage                with              claimed
                                                           Land Parcels         Commonage
Carlow           2550.90         2417.58        35                          183                  66.04                    33.96
Cavan             4804.44        4708.52         67                          137                  55.67                    44.33
Clare               5040.61       4412.51         190                         376                 70.65                     29.35
Cork             20100.09      17466.26        552                          909                 68.92                    31.08
Donegal       74559.86      70729.13       1278                       2571                 63.62                     26.38
Dublin           2320.07         2273.91         11                           40                   40.66                    59.34
Galway        67670.65       61413.00       1389                      2713                 59.63                     40.37
Kerry.           65462.76       60793.98        843                      1935                 71.26                     28.74
Kildare          1586.48          1292.59        13                           35                   53.76                    46.24
Kilkenny         538.65           517.06           9                           33                   87.68                    12.32
Laois             1898.33         1130.25          31                          97                   44.59                    55.41
Leitrim        12701.55       12561.77         172                       484                   68.23                    31.77
Limerick       2235.26          2178.56         26                         65                    42.71                    57.29
Longford         401.79            371.86         23                         60                   72.37                     27.63
Louth             2901.01          2775.21        27                        153                   35.81                     64.19
Mayo         107743.37      103712.59     1431                      3297                  62.33                     37.67
Meath.               96.49              93.40          4                         12                    38.96                     61.04
Monaghan.        14.11                0.90          2                           2                      1.96                     98.04
Offaly              407.68            342.81         23                        37                    64.14                     35.86
Roscommon  1393.89          1308.61         86                       151                   53.49                     44.51
Sligo            12779.36        12218.45       207                       454                   69.43                     30.57
Tipperary     11714.23       11257.31        131                       319                   70.48                    29.52
Waterford      9418.01         9236.48         63                        181                    65.26                    34.74
Westmeath      165.61               93.55       12                         22                     63.32                    26.68
Wexford        2758.77           2625.55       31                        108                    60.24                    39.76
Wicklow      24714.36        24255.76       137                       341                    50.72                    49.28

TOTAL    435978.32       410187.60      6793                   14632                   63.30                   36.70

Adapted from NPWS Submission on CAP reform May 2013.

The table above shows the area of commonage in each county along with the number of shareholders declaring commonage shares in 2012. Interestingly this table gives us detailed information on the % of commonage land claimed and this allows us to determine the extent of dormant shares on a county basis. We can see that the National Average of 63.3% of commonage area claimed in 2012 masks a large variation from county to county. Of the main commonage counties the % claimed was as low as 50.72% in Wicklow rising to a high of 71.26% in Kerry.

This analysis suggests that the dormancy rate on a national level is 36.7%. Leaving aside Monaghan where the very small areas involved contribute to an atypical dormancy rate the county with the highest dormancy rate is Louth with 64.19% of commonage land unclaimed. Considering the large amount of commonage land particularly in the Cooley peninsula this is surprising and will be locally problematic. At the other end of the spectrum the dormancy rate in Kilkenny is 12.32% and in Kerry, an important commonage county it is only 28.74%.

Obviously within each county there would also be considerable variation as the usage pattern on each commonage would vary. What is clear however is that the dormancy issue will be a significant factor in developing commonage management structures throughout the country. This requires clarification on how the qualified majority required for setting up a grazing association can be met. If the 80% referred to in the draft proposals refers to total shareholders then we have a big problem, as no county has 80% or more shares declared. If the qualified majority is 80% of the shareholders declaring commonage on their SPS return then this issue is eased somewhat.

The Dept. of Agriculture should clarify not only how the qualified majority is to be calculated but also how farmers on commonages with large dormancy rates are going to be compensated for the extra difficulties that they face. In particular how shareholders who are required to maintain all of the area in GAEC, yet between them may only be eligible for payments on 60% or less of the reference area. Surely there is a case here for making these farmers eligible for GLAS+ payments.

Monday 10 February 2014

Invitation to make submissions on draft RDP.

The Dept. of Agriculture are seeking written submissions on the recently published draft paper for the Rural Development Programme 2014-2020.

In relation to commonages the specific issues in the draft paper are;

1) The requirement for 80% of shareholders in a commonage to form a grazing association in order to  apply for the GLAS scheme.
2) The payment ceiling and administrative issues under GLAS.
3) The convergence of low value entitlements towards a minimum of 60% of the national average value.
4) The merging of the payments under the sheep grassland scheme into the a farmers entitlements under the basic payment scheme.

Unfortunately a lot of the fine print is still unclear. Farmers should note that the impact of these proposals will largely be determined by the regulations in the RDP and operating programmes that will be submitted to the EU Commission later in the Spring. This is your last chance to have a meaningful input into the design of these regulations. For this reason I would urge anyone who has a suggestion to make a submission before the closing date of Feb 19th 2014.

In connection with the issues listed above I believe that all commonage farmers should give careful consideration to the following points;

1) The requirement for 80% of shareholders in a commonage to form a grazing association in order to apply for the GLAS scheme.

       Is 80% to high?
  • Would lowering the threshold to 70% make an agreement more achievable? or would leaving out a large minority prevent any agreement from achieving its objectives, i.e. ensuring land remains in GAEC and eligible for payments?
  • How should dormant shareholders (shareholders who do not farm at all or do not declare commonage on their SPS return)be dealt with?
  • How should inactive shareholders(farmers who declare the commonage share on their SPS but do not utilise the commonage)be treated?
  • What issues should a grazing agreement include?
  • What issues should not be part of a grazing agreement?
  • How should the transaction costs for developing an agreement be met?
  • Should they be paid by the farmers?
  • Should they be paid for out of the funds available for knowledge transfer?
  • How much time should be available to develop commonage agreements? Note: Similar agreements in England have been found to take up to a year to put in place. This issue requires careful consideration as the current proposal is to have an agreement in place before applying for GLAS. This creates a risk that that most commonage farmers will not get into GLAS until 2016.
  • Should applications be allowed prior to agreement, provided agreements are in place prior to payment?
2) The payment ceiling and administrative issues under GLAS.
  • Is the proposed payment ceiling of €5,000 adequate?
  • How should eligibility for the GLAS+ supplement be determined? Should farmers with very large areas of commonage be eligible?
  • Should active shareholders in commonages with a high dormancy rate be eligible?
  • Should farmers with commonage in Freshwater Pearl Mussel catchments where additional measures are likely to be required be eligible for the top up?
  • Should amendments to GLAS plans be allowed?
  • Considering that commonage agreements may require on going tweaking to deal with future developments and issues unforeseen when the original agreement was drawn up this may be a vital requirement for effective operation of any scheme. For this reason is it important that grazing agreements and GLAS plans can be amended?
3) The convergence of low value entitlements towards a minimum of 60% of the national average value by 2019.
  • Payments on lands "kept naturally in a state suitable for grazing" will be dependent on maintaining a certain minimum level of activity.
  • This issue has not yet been addressed but in many ways is the most important of all. If handled inappropriately it could exclude thousands of commonage farmers. It deserves careful attention by all concerned.
  • How should a minimum level of activity be defined? Should it be a minimum stocking rate? How can such a definition be applied to a very diverse set of commonages?
4) The merging of the payments under the sheep grassland scheme into the a farmers entitlements under the basic payment scheme.
  • While this will give an initial boost to payments, for most farmers this benefit will be lost by 2019 as the value of entitlements converge.
  • Should the grassland sheep payment be retained as it is?
  • Or is the Minister correct when he says that the payment if not subsumed into the basic payment scheme might be lost completely?
You can download the draft paper through the links on this page.

Think about the issues involved and make a submission if you can. You can also leave a comment on this site or send us an e-mail to

Invitation to make Submissions.

Draft Paper on RDP

Editors Notes

Wednesday 5 February 2014

2013 Sheep Census

Remember to get them all counted and census in by Feb 14th.

2013 Sheep Census: Minister Coveney Announces Two-Week Extension to Closing Date for Submission: New Closing Date Friday, 14 February.

The Minister for Agriculture, Food and the Marine, Simon Coveney, TD, today announced a two-week extension to the closing date for submission of the 2013 Sheep Census. 'I have decided to extend the closing date in order to give farmers sufficient time to complete and return the Census' the Minister said, noting that there is a legal requirement on all flock owners to complete and return the Census form. 'It's essential that farmers take time to fully and accurately complete the Census, as failure to do so may prevent the ordering of sheep tags or lead to cross compliance penalties and, indeed, could affect certain Scheme applications' the Minister said, adding 'Therefore, while the closing date for receipt of completed forms had initially been fixed for Friday, 31 January, I have decided to extend this by a further two weeks, to Friday, 14 February. I must emphasise, however, that there is no scope to extend this date further'.
The Dept. of Agriculture have still not defined what they mean by "a minimum level of activity" for a farmer to be eligible for the new Basic Payment Scheme on marginal land. However it is very likely that this will include a minimum stocking rate and on mountain commonage evidence that mountain breeds of sheep or cattle suitable for the hill such as Aberdeen Angus, Kerry's or Galloways are on the holding.
In any case failure to get the census in on time will create no end of problems with demonstrating eligibility for the 2014 dis-advantaged area scheme, so if you have not done so already get the census return in as soon as you can.

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