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?

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