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 email@example.com
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.