Saturday 30 August 2014

Lobbying Politicians on the Commonage issue.

We have received a number of requests regarding lobbying of TD's on resolving the commonage issue. As a response to this I have collated the e-mail addresses for all of the T.D's in the main commonage counties and listed them below. The contact details for other T.D.'s can be found on the Oireachtas website In general they take the form of Christian name all in lower case letters with no spaces.

Mr. Pádraig Mac Lochlainn Constituency: Donegal North-East Party: Sinn Féin (2011)

Mr. Charlie McConalogue Constituency: Donegal North-East Party: Fianna Fáil (2011)

Mr. Joe McHugh Constituency: Donegal North-East Party: Fine Gael (2011)

Mr. Pearse Doherty Constituency: Donegal South-West Party: Sinn Féin (2011)  

Mr. Dinny McGinley Constituency: Donegal South-West Party: Fine Gael (2011)

Mr. Thomas Pringle Constituency: Donegal South-West Party: Independent

Mr. Michael Colreavy Constituency: Sligo Leitrim North Party: Sinn Féin (2011)

Mr. Tony McLoughlin Constituency: Sligo Leitrim North Party: Fine Gael (2011)

Mr. John Perry Constituency: Sligo Leitrim North Party: Fine Gael (2011)

Mr. Frank Feighan Constituency: Roscommon Leitrim South Party: Fine Gael (2011)

Mr. Luke 'Ming' Flanagan (No longer a TD as he was elected to the European Parliament). Constituency: Roscommon Leitrim South Party: Independent

Mr. Denis Naughten Constituency: Roscommon Leitrim South Party: Independent

Mr. Dara Calleary Constituency: Mayo Party: Fianna Fáil (2011)

Mr. Enda Kenny Constituency: Mayo Party: Fine Gael (2011)

Ms. Michelle Mulherin Constituency: Mayo Party: Fine Gael (2011)

Mr. John O'Mahony Constituency: Mayo Party: Fine Gael (2011)

Mr. Michael Ring Constituency: Mayo Party: Fine Gael (2011)

Mr. Noel Grealish Constituency: Galway West Party: Independent

Mr. Seán Kyne Constituency: Galway West Party: Fine Gael (2011)

Mr. Derek Nolan Constituency: Galway West Party: The Labour Party (2011)

Mr. Éamon Ó Cuív Constituency: Galway West Party: Fianna Fáil (2011)

Mr. Brian Walsh Constituency: Galway West Party: Fine Gael (2011) brian.walsh@oireachtas

Mr. Ciaran Cannon Constituency: Galway East Party: Fine Gael (2011)

Mr. Paul J Connaughton Constituency: Galway East Party: Fine Gael (2011)

Mr. Colm Keaveney Constituency: Galway East Party: Fianna Fáil (2011)

Mr. Michael P. Kitt Constituency: Galway East Party: Fianna Fáil (2011)

Mr. Jimmy Deenihan Constituency: Kerry North Limerick West Party: Fine Gael (2011)

Mr. Martin Ferris Constituency: Kerry North Limerick West Party: Sinn Féin (2011)

Mr. Arthur Spring Constituency: Kerry North Limerick West Party: The Labour Party (2011)

Mr. Tom Fleming Constituency: Kerry South Party: Independent

Mr. Brendan Griffin Constituency: Kerry South Party: Fine Gael (2011)

Mr. Michael Healy-Rae Constituency: Kerry South Party:

Mr. Jim Daly Constituency: Cork South-West Party: Fine Gael (2011)

Mr. Noel Harrington Constituency: Cork South-West Party: Fine Gael (2011)

Mr. Michael McCarthy Constituency: Cork South-West Party: The Labour Party (2011)

Mr. Paudie Coffey Constituency: Waterford Party: Fine Gael (2011)

Ms. Ciara Conway Constituency: Waterford Party: The Labour Party (2011)

Mr. John Deasy Constituency: Waterford Party: Fine Gael (2011)

Mr. John Halligan Constituency: Waterford Party: Independent

Mr. Tom Hayes Constituency: Tipperary South Party: Fine Gael (2011)

Mr. Seamus Healy Constituency: Tipperary South Party: Workers and Unemployed Action Group South-Tipperary

Mr. Mattie McGrath Constituency: Tipperary South Party: Independent

Mr. Noel J Coonan Constituency: Tipperary North Party: Fine Gael (2011)

Mr. Alan Kelly Constituency: Tipperary North Party: The Labour Party (2011)

Mr. Michael Lowry Constituency: Tipperary North Party: Independent michael.lowry@oireachtas

Mr. Stephen Donnelly Constituency: Wicklow Party: Independent

Mr. Andrew Doyle Constituency: Wicklow Party: Fine Gael (2011)

Ms. Anne Ferris Constituency: Wicklow Party: The Labour Party (2011)

Mr. Simon Harris Constituency: Wicklow Party: Fine Gael (2011)

Mr. Billy Godfrey Timmins Constituency: Wicklow Party: Independent

Mr. Gerry Adams Constituency: Louth Party: Sinn Féin (2011)

Mr. Peter Fitzpatrick Constituency: Louth Party: Fine Gael (2011)

Mr. Séamus Kirk Constituency: Louth Party: Fianna Fáil (2011)

Mr. Gerald Nash Constituency: Louth Party: The Labour Party (2011)

Mr. Fergus O'Dowd Constituency: Louth Party: Fine Gael (2011)

Sunday 24 August 2014

How do we bridge the gap between the Dept. of Agricultures position and that of the Hill Farmers?

Let us analyse the key issues of concern for each party.

Dept of Agriculture, Food and the Marine.
The Dept of Agriculture does not believe that a contract with an individual can deliver, as actions of third parties can impact on the condition of the commonage. They see 50% support for a management agreement as the minimum required to ensure appropriate management, they would hope that greater support will be possible and that the level of buy in can be built on in future years.

Hill Farmers.
The Hill Farmers are very concerned about collective responsibility and the potential for this to lead to collective punishment. They are concerned about the requirement for a management agreement with 50% support as a pre requisite for entry into GLAS and they are worried that eligibility for the Basic Payment Scheme could be based on the current min/ max figures. They know that it will be impossible for management agreement to be drawn up on all but the simplest of cases to permit entry into GLAS in 2015 and fear that for all practical purposes many of them would be excluded anyway even if agreement was possible. Likewise they are concerned that the use of the min / max figures for assessing eligibility for the Basic Payment Scheme will leave many farmers without any entitlement to payment under pillar 1 as well.

How can we progress from here?
While the two positions appear poles apart, the problem may not be as big as many fear.   Clearly the requirement for agreements as requirement to join GLAS is a non starter. There are not enough interested planners available and no model exists for how such agreements could be delivered, the support from farmers is non-existent and the time available is far too short.   But now let’s look at how relatively minor changes might bring both parties to something that perhaps everyone could work with. To start let’s focus on the points that neither side would dispute.

• A one size fits all approach will not work.
• A co-operative approach to commonage management is needed. Only the farmers can deliver this.

Now, take the heat out of the debate, first change the language, drop the term “collective”. It has uneasy echoes of Stalinist Russia and raises fears of collective punishment; in any case the term itself has now become part of the problem. Second be realistic about the time frames required and be honest about what is achievable over the term of this round of the CAP. Now for a solution in 5 short paragraphs.

1) Let farmers join GLAS on the basis of a Declaration of intent to work with a specialist planner to develop a commonage management plan by 2017. This plan balances the needs and requirements of each farmer with the management requirements for the commonage. There is no need for any minimum % agreement, the plan will apply to all farmers, the agreement required is to work with the planner in developing a bespoke solution for that commonage. In any case engaging with the process offers huge advantages for the farmer. Potentially it allows his commitment to be outside the min/ max range provided of course that it fits in with the needs for appropriate stocking on the commonage.

2) Once the Commonage Plan is drawn up, it becomes binding on all the farmers. It is part of their contract and if a farmer fails to abide by his commitment, he gets penalised for non-compliance. There is nothing new in this; we had commonage framework plans in the past that applied to all shareholders but where the responsibility for compliance remained with the individual. What is proposed merely replaces a CFP imposed from above with a Commonage Plan developed with the participation of the farmers themselves, surely a much more democratic process.

3) Apply min/max figures developed in the commonage plan in accordance with the size of an individual’s shareholding to farmers who do not engage with the process. Obviously non engagement would represent non compliance and perhaps could incur a penalty. I am certain however that the flexibilities offered by engaging with the development of a tailored commonage plan will be preferred by most farmers to a crude breakdown of min/max figures.

4) Eligibility for the Basic Payment Scheme on land that is naturally maintained in a condition suitable for grazing is dependent on a minimum level of use. This minimum level of use is decided by each member state and to my knowledge in Ireland is as yet undecided. Whatever level is eventually decided on, I think everyone accepts that a transition period will be required. During this transition period demonstrating use of the commonage at any level should be considered good enough. After that if the farmer complies with the new commonage plan he should by definition be considered as demonstrating a minimum level of use. For farmers who opt to stay out of GLAS, a stocking rate of perhaps 0.5 times the rate prescribed in the commonage plan could be required as a minimum level of use. This would link the minimum rate to a level appropriate to the commonage in question, but at a level below what is required for pillar 2 schemes like GLAS.

5) The cost of developing the Commonage Plan must be acknowledged by both sides, in reality the only way of doing this is for the commonage planner to be paid directly by the state. This was the case with the Commonage Framework plans and remains the only feasible delivery mechanism. Developing plans will be a huge undertaking but in the context of the amount of money that will potentially be involved (in paying GLAS, ANC and BPS on commonage farms) the cost will be very small beer. Nevertheless to proceed without making provision for the investment required in Commonage planning would be reckless indeed. Payments direct to planners are already included in the RDP for knowledge transfer, with a little imagination this issue could be accommodated as well.

The Dept get buy in to a joint management programme from the shareholders with a stocking commitment appropriate to the commonage. The farmers get access to GLAS based on a workable commonage plan without any suggestion of them being penalised for the sins of others.
Now that wasn’t so hard was it?

Friday 22 August 2014

Hill Farmers Meeting in Westport

On Wednesday August 20th over 1,700 farmers attended a public meeting in the Knockranny Hotel in Westport. The meeting called by the Concerned Hill Farmers Action Group was a triumph of organisation and a credit to the promoters. The huge turnout demonstrates that hill farmers have very real concerns about aspects of the draft RDP currently being considered by the EU Commission.

The Hill Farmers Action Group clearly have a mandate and quite rightly expect to have direct negotiations with the Dept. of Agriculture. It is a pity for all concerned that the consultations which must surely happen soon did not occur a year ago, that said if real engagement takes place even at this stage it has to be seen as a positive development. Negotiations will not be easy and the backdrop of a clock ticking down to the opening of the various RDP funded schemes will only add to the pressure. Many of the speakers for the Hill Farmers Action Group, in particular Brendan Joyce and Colm O Donnell spoke eloquently of their concerns and obviously have a deep understanding of the practicalities of the farmers position. I have no doubt that they would be able to articulate these in any forum and will be formidable negotiators. They will likely achieve some progress towards achieving their objectives, although bringing their supporters to accept the inevitable compromises could be the biggest challenge of all.

One thing that is certain is that the meeting in Westport and its consequences cannot be ignored. The Commonage Implementation Committees will have their work cut out for them. The engagement with farmers towards building a future that all stakeholders can buy into will be very challenging indeed.

Monday 18 August 2014

Min/ Max Figures for Commonage

A lot of time has passed since the Dept. of Agriculture originally posted the min/ max figures for individual commonages. The figures at the time attracted quite a bit of controversy with many farmers considering them inappropriate to their commonage. The figures have been taken down off the Dept. of Agriculture site since then and seem to have largely faded from the public discussion of the commonage issue. However we have had numerous requests in recent weeks for this information. We will provide it for any commonage on request. Please e mail any requests to

This is important for a number of reasons, the first is that the min/ max figures are  very likely to form part of the Dept. of Agriculture's position on what constitutes the minimum level of grazing required to keep a commonage in GAEC, a necessary requirement for payment under the new Basic Payment Scheme. The min /max figures are also likely to be the default values for any commonage agreement as part of the new GLAS scheme. There are several important factors that commonage farmers should note in respect of these values. These are;

1)  The figures relate to the commonage parcel, not to the individual farmer. Whether the Dept. of Agriculture will use them for calculating the minimum level of use for individual farmers to qualify for the Basic Payment Scheme is still unclear.  However such a scenario is very likely as the Dept. of Agriculture have no real alternative in place.

2) If it is decided to use these figures for calculating the minimum level of use for the Basic Payment   Scheme then how the issue of dormant shareholders is going to be addressed is as yet unknown. If the figures are simply divided among active farmers in accordance with their share of the commonage, then in most commonages the overall minimum figure for the commonage will not be attained. This is an outcome which is unlikely to be acceptable to the EU Commission. If the required stock numbers are apportioned between the active shareholders, i.e. ignoring dormant shares altogether, there is a danger that in some cases the stock numbers required by individual shareholders may be unsupportable taking the farm unit as a whole into consideration. This is not a desirable outcome for either party.

3) It is possible that the Dept of Agriculture will settle on an overall stocking rate for the farm as a qualification mechanism. However this too is fraught with difficulty, on farms with a high proportion of enclosed land to commonage, particularly where this is of relatively good quality it is unlikely that there would be a problem.  However on farms with a very high ratio of commonage land to enclosed land or where the enclosed land is of very poor quality the risk of serious difficulties is very high. The issue here is not the figure chosen, both the 0.05 LU/Ha advocated by the Hill Farmers for Action group and the 0.15 LU/ Ha currently used for the DAS scheme will not be universally applicable, the difficulty rather is with any method which applies a one size fits all approach to all commonages.

What I believe is more likely is that the Dept. of Agriculture will choose a method, probably based on one of the possibilities listed above and then allow deviations from that on individual commonages and for individual farmers on the basis that there is a GLAS contract in place.  This would be similar to the approach taken many times in the past. While such an approach offers a certain amount of flexibility, it does face one huge challenge and that is that is probably already too late in the day to implement.

There is every likelihood that GLAS will not open till January 2015, the application window will only be 4 months at best and this will include the first application period for the Basic Payment Scheme. The time available for planners to produce a scientific assessment of the commonage and develop an agreement that farmers can buy into and produce GLAS applications for individual farmers is very short.  The temptation for many planners to ignore commonage and focus on farmers with enclosed land only is huge. There are three main reasons for this. First most planners are unfamiliar with commonages and the habitats and farming patterns involved. Second preparing GLAS applications for farmers with no commonage is relatively straightforward, particularly when the planner had dealt with those farmers in REPS and was familiar with their farm. Dealing with this group generates an immediate income stream for the planner and will be very tempting.  Finally if there are up to 30,000 places in GLAS in the first year, it is clear that many farmers who do not qualify for priority entry to GLAS have only one chance to get into GLAS and that is in year 1.  These farmers and their planners know this and they will take advantage of the window of opportunity that is presented.  Ironically in all probability large numbers of these farmers will get accepted into GLAS in 2015 while most commonage farmers will not.

What can be done about this at this stage. There are two practical measure that farmers can and should take immediately. These are to assess the appropriateness of the min/ max figures for their commonage and if necessary get a commonage planner to prepare alternatives based on a scientific  assessment of the commonage. We at yourcommonage will assist anyone with this but remember that time is short, once GLAS opens the opportunity to have you commonage re-assessed will effectively  be closed until after the first GLAS application period closes. Secondly farmers and their representatives should lobby for a change to the proposed GLAS measure which demands a final agreement on the commonage prior to applying for GLAS.  Remember that for practical reasons a nutrient management plan does not have to be prepared at the time of application, it can be done after the application is approved but prior to payment. Treating the much more complex of issue of a commonage plan in the same manner is the least that farmers deserve.