Who said What, about the RDP Consultation Paper.

The closing date for making submissions on the recently published RDP draft consultation period was the 19th of February. Since then some of the most influential stakeholders have published their submissions publically. Links to the submissions made by the IFA, the ICSA and the Agricultural Consultants Association are given here. While all of these groups commented on the entirety of the proposals I will attempt to paraphrase their position on the commonage issues.

The Agricultural Consultants Association (ACA) believe that the present proposals for a requirement for a collective agreement on for commonage lands is not workable as prerequisite for admission to an agri-environment scheme. They believe that this concept can only be achieved if it is enforced as part of the Single Payment Scheme/ Basic Payment Scheme. They suggest that min/ max figures for each commonage as already calculated should be used. Interestingly the ACA also suggest that the initial application to GLAS should be a very simple screening statement which could be prepared at minimal cost. The Dept. of Agriculture could then select which applicants will be accepted and give them and their advisors 6 months to prepare a more comprehensive plan.

The ICSA feel that the collective agreement requirement is very problematic and cite the issue of dormant and inactive shareholders as a significant issue and that they feel it will be very difficult to make this work.

The IFA are opposed to the collective agreement concept and feel that the stock carrying capacity should be assessed by the farmers planner. They also state that a clear agreement with farmers on stocking levels must be set out in parallel with the GLAS scheme.

There are positives and negatives in the ideas put forward by the three groups referred to above, the initial screening application concept made by the ACA is particularly interesting, it seems to be modelled on the system developed by NPWS for selection of farms for the NPWS Farm Plan Scheme but it could be very useful in the GLAS context. It would reduce the initial outlay by the farmer to a minimum and ensure that the bulk of the costs would not be faced until approval in principle was given. It would also allow appropriate plans to be drawn up by the farmer and his advisor rather than repeating the errors of AEOS by forcing applications to be prepared in a very tight timeframe. The disadvantage with this approach is that given the experience with AEOS, it is difficult to see the Dept. of Agriculture processing the screening applications fast enough to allow a reasonable window of opportunity for plan preparation, submission, approval and issuing of payments later in 2015. The ACA suggestion that the min/ max figures be used in GLAS plans ignores the issue of dormant and inactive shareholders. If approx. 1/3 of shares are dormant then merely splitting the min/ max figure for the commonage in accordance with the individual farmers shareholding is not a solution. On a typical commonage with 30% dormancy rate, even if all of the remaining shareholders kept the maximum number of stock permitted, the total would still fall below the minimum for the commonage.

The ICSA are correct in pointing out the dormancy issue as an impediment to progress. The IFA proposal that a clear agreement with farmers on stocking levels must be set out in parallel with the GLAS scheme could be seen as a request for further negotiations on how commonage stocking levels should be arrived at, this is an essential step and should be taken up by the Dept of Agriculture. Their other idea however;that stocking levels should be assessed by the farmers advisor is unworkable and I cannot see it being accepted by the Dept. of Agriculture. Consider this, if there is only a 3 month window for preparing applications, farm advisors will not be spending it assessing vegetation on mountains and so no such assessments will actually be carried out. In any case the number of farm advisors with the required experience and skills base for doing this work is very small. A serious flaw in this approach is that it does not deal with the obvious difficulty of different advisors working on the same commonage coming up with completely different answers as to what is an appropriate stoking level.

Unfortunately none of the submissions comment on two of the most important problems, i.e. time and money. The grazing agreement concept in its current form will not work because no implementation plan has been proposed, nobody knows what a grazing agreement is meant to achieve, what it will contain, how it will be drawn up or who will pay the associated transaction costs. In fact the concept has not been advanced at all since the Oireachtas Committee on Agriculture hearings a year ago.

The focus of the Dept. of Agriculture, Farm Advisors and Farmers is now firmly on the 2014 Single Payment Scheme Applications and on its successor the new Basic Payment Scheme. As a result there is unlikely to be any progress until at least June. Even if an agreement between the parties could be achieved in June/ July that would leave only 2-3 months to draw up and agree grazing agreements on 4-5000 commonages. Considering the experience in England with a similar approach, where grazing agreements can take upto a year to put in place, there is no way that agreements on any but the simplest of cases can be put in place in the time available. This means that no meaningful progress can be achieved before GLAS opens in October and so the vast bulk of commonage farmers will be excluded from the first round of the scheme. This will leave a sour taste with many and would not augur well for success in 2016.

I hope that the consultations that take place over the coming weeks will lead to an acceptable solution on the commonage issue and in fact I feel that there are some grounds for optimism. If the min/ max figures were used and allocated to farmers in accordance with their shareholding, we would have a starting point. This could be followed up by a further allocation of the stock nominally applied to dormant shareholders, by agreement between the shareholders or in accordance with the shareholding where agreement is not forthcoming. The ACA suggestion of screening applications should be taken up and the Dept. of Agriculture should ensure that they can deliver on the processing of such screening applications. The IFA's offer for negotiations on stocking agreements in parallel with the roll out of GLAS should be accepted and these negotiations should commence immediately. If that happened there would still be an opportunity to finalise agreements at commonage level by July 2015 and allow such agreements to be incorporated into a workable plan.

What is essential though is that no more time is wasted, progress on commonage stocking levels must be achieved very quickly, the Dept. of Agriculture cannot delay any longer.

Agricultural Consultants Association

http://www.google.ie/url?sa=t&rct=j&q=&esrc=s&frm=1&source=web&cd=1&cad=rja&ved=0CCwQFjAA&url=http%3A%2F%2Faca.ie%2Fwp-content%2Fuploads%2F2014%2F03%2FACA-RDP-Consultation-Paper-Submission.pdf&ei=HsoVU4DPNaPY7Ab3poDoCw&usg=AFQjCNFyZ2A819fF9KzyhF09AvwQrJ15Fg&sig2=Bh8yJryGg_A8Gnr3vE6xQQ&bvm=bv.62286460,d.ZGU


IFA

http://www.google.ie/url?sa=t&rct=j&q=&esrc=s&frm=1&source=web&cd=1&cad=rja&ved=0CCoQFjAA&url=http%3A%2F%2Fwww.ifa.ie%2FLinkClick.aspx%3Ffileticket%3DDoCHMzVcFic%253D%26tabid%3D649&ei=VMsVU6K0DsXY7AbGnYCYAQ&usg=AFQjCNGyb3ih4NLk9CQP3bhR2YdiZ9diAw&sig2=W7hfaxAbu6BbPfjLY6OctQ&bvm=bv.62286460,d.ZGU


ICSA

http://www.google.ie/url?sa=t&rct=j&q=&esrc=s&frm=1&source=web&cd=3&cad=rja&ved=0CD0QFjAC&url=http%3A%2F%2Ficsaireland.ie%2Fpolicy%2Fpolicy-submissions%2F445-icsa-submission-on-the-rural-development-programme-2014-2020-consultation-paper&ei=LcsVU6zBLq2S7AbOoIGwCg&usg=AFQjCNHVtLaC3JeuR1pFGmfjVEhjsWAPBg&sig2=hHJQYhW9Q8HFm5bKF_ryew&bvm=bv.62286460,d.ZGU


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