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 yourcommonage@gmail.com

Invitation to make Submissions.

http://agriculture.gov.ie/media/migration/ruralenvironment/ruraldevelopment/ruraldevelopmentprogramme2014-2020/InvitesubmissionsRDPConsultationPaper21012014.pdf

Draft Paper on RDP

http://agriculture.gov.ie/media/migration/press/pressreleases/2014/DraftConsultation%20DocRDP14%20Jan.pdf

Editors Notes

http://agriculture.gov.ie/media/migration/press/pressreleases/2014/NOTESFOREDITORS140114.doc