Tuesday 23 December 2014

Happy Christmas

We at yourcommonnage.ie would like to wish everyone we deal with a very happy Christmas. The last year has been challenging on the commonage front but I we look forward to 2015 being a better year for everyone involved with farming and protecting Irish commonages and the agricultural, social and natural heritage linked to that,

Happy Christmas

Thursday 18 December 2014

Minister Coveney confirms his Dept is considering the Hill Farmers 12 Point Plan.

The Minister for Agriculture, Food and the Marine in response to a Parlimentary question from Colm Keaveney T.D. has confirmed that his Department are considering the hill Farmers 12 Point Plan. The full exchange is shown below. 

Deputy Colm Keaveney asked the Minister for Agriculture, Food and the Marine his views on adopting the 12 point proposals (details supplied) for priority entry into the GLAS scheme in respect of commonage farmers that was provided to him by the hill farmers recently; the reasons for his agreement or disagreement with the proposal; and if he will make a statement on the matter. 

Minister for Agriculture, Food and the Marine (Deputy Simon Coveney): At my recent meeting with hill-farmer representatives I agreed to examine very carefully their proposal, on which much of our discussion at the meeting centred. My Department is giving the proposals detailed consideration and I will be contacting the hill-farmer representatives in due course.

Tuesday 16 December 2014

GLAS Specifications.

The draft Specifications for GLAS can be seen by following the link below. These are an early draft and I expect there will be significant changes before the scheme is approved.

/GLAS Draft Specifications 

National Reserve Conditions


The Minister for Agriculture, Food and the Marine, Simon Coveney TD, today announced the conditions of the 2015 National Reserve. The transition to the new regime of Direct Payments will include the establishment of a National Reserve using 3% of the ceiling allocated to the Basic Payment Scheme in 2015. This will provide a fund of almost €25million from which new entitlements will be allocated to successful applicants.

The Minister said; “I am keenly aware of the limited resources available in the National Reserve over the five years of the Scheme. My aim is to ensure that these resources are targeted specifically at those who have a proven interest in pursuing a full time career in agriculture but who require assistance in establishing themselves in the Direct Payments system. At the same time I am mindful of the risk of excluding those who may engage in limited off-farm employment as a means of supplementing their agricultural income”. Priority under the National Reserve will be given to those who meet the definition of ‘young farmer’ and ‘new entrant to farming’. Successful applicants will receive an allocation of entitlements based on the eligible land declared on their 2015 Basic Payment Scheme application at a value equal to the national average value of entitlements in the year of application. Successful applicants who already hold entitlements which are below the national average value will receive a top-up whereby the value of those entitlements will be increased to the national average value. 

Sunday 14 December 2014

Irish RDP Application will not be approved in 2014.

Irelands RDP application will not be approved before the end of the year. A press release from the EU Commission has confirmed that the first 3 RDP applications have been approved. These were from Austria, Denmark and Poland, a further 6 (from Finland, Portugal along with 4 from Germany) will be agreed before the end of the year.  
While this is disappointing, it is not surprising, considering the scale of the task faced by the EU Commission in dealing with all 118 applications.  In addition the task of rewriting large parts of the Irish RDP to address the 266 observations made by the Commission will inevitably take some time.  

At this stage getting the plan right is certainly worth a couple of months delay. There is still time to make the adjustments necessary to deliver high quality schemes to support Irish Agriculture for the rest of the decade. It is essential that those who can secure this do not waste the opportunity, it will not come again!
The full text of the EU Commission press release can be seen below.

First three Rural Development Programmes get green light

Brussels, 12 December 2014
The European Commission has today approved the first three of 118 Rural Development Programmes (RDPs) aimed at improving the competitiveness of the EU farming sector, caring for the countryside and climate, and strengthening the economic and social fabric of rural communities in the period until 2020. Operating at either national or regional level, the 118 multi-annual programmes are backed by EUR 95.6 billion of total EU funding over the period 2014-2020 through the European Agricultural Fund for Rural Development (EAFRD) and will draw in additional national, regional and private finance. In addition to today’s programmes – the national RDPs for DenmarkPoland and Austria – a further 6 programme[1] will be adopted before the end of the year, meaning that programmes worth more than 20 billion EURO will have been cleared.
Agriculture and Rural Development Commissioner Phil Hogan said:
  • "Our rural areas – with the farm sector and the many other types of business which are based there – give us jobs, opportunities for rest and recreation, natural beauty, and pleasant places in which to live and work. But they need help to unlock their full potential. The next generation of Rural Development programmes is about to deliver that help. Today we have approved the first 3, with a further 6 to follow next week – accounting for roughly 22% of Rural Development spending from the EU budget. We estimate that programmes covering approaching one third of the funding will be cleared by Easter.
  • One of the great strengths of our Rural Development concept is that we have 6 core priorities, but it is up to each Member State or region to design programmes which suit their situation. And we see good examples of this today where the Polish programme is aiming to create more than 22 000 jobs, provide investment support to roughly 200 000 farms and to establish some 1 800 producer groups.
  • In Denmark, we see particular emphasis given to fostering innovation, with the objective of creating almost 1000 "green jobs", moves to double the area of organic farming, and investing in environmentally-friendly farming practices.
  • In Austria, there is particular priority given to environment and climate concerns, with a target of more than 80% of agricultural land managed to protect and enhance biodiversity, and training opportunities for more than 600 000 farmers, whilst around half the rural population should benefit from improved services such as high-speed broadband.
  • As I have seen in my native Ireland, a modern and dynamic agriculture sector can provide a motor for economic growth and jobs, especially in rural areas. In their Rural Development Programmes backed by EU funds, Member States and regions have the right key to unlock that potential.”
Rural Development is the so-called 2nd Pillar of the Common Agricultural Policy, providing Member States with an envelope of EU funding to manage nationally or regionally under multi-annual, co-funded programmes. In total, 118 programmes are foreseen in all 28 Member States.
number of RDPs by country
The new Rural Development Regulation for the 2014-2020 period addresses six economic, environmental and social priorities, and programmes contain clear targets setting out what is to be achieved. Moreover, in order to coordinate actions better and maximise synergies with the other European Structural & Investment Funds (ESIF), a Partnership Agreement has been agreed with each Member State highlighting its broad strategy for EU-funded structural investment.
[1] The following plans are due for adoption before the end of 2014: Finland (mainland); PortugalContinente; and 4 from Germany (the National Framework, the German Rural Network and the regional programmes for Sachsen, and Sachsen-Anhalt)

Wednesday 10 December 2014

Sheep Census

The Dept. of Agriculture have announced the date for 2014 Sheep Census. Full details are given below. 

SHEEP & GOAT CENSUS 2014 Over 43,000 flock owners, registered as keepers of sheep and goats on the Department of Agriculture, Food & Marine’s database, will this week receive the Sheep and Goat Census 2014. Completing and returning the census is a legal obligation. 

As well as fulfilling this requirement, the yearly sheep and goat census is the record retained by the Department of Agriculture, Food and the Marine, as to the number of sheep on each holding. This information forms the basis of quantifying sheep numbers in the country on a particular date. More importantly, for flock owners, it is also central in declaring that required stocking rates have been maintained and facilitates the drawing down of payments under schemes such as the Single Payment Scheme, Disadvantaged Area Scheme, REPS, AEOS and the Grassland Sheep Scheme. 

The information is also used during farm/flock inspections. The inspector will have details of the census returns submitted for the holding in the last four or five years and will use this information as the basis for identifying if the animal records have been adequately maintained. This year the Department has selected Sunday 14 December 2014 as the census date. 

The onus remains with the flock owner to make sure that the completed census forms reach the Department on time. It should be noted that the only acceptable proof of postage is Registered or Express post receipts and all forms must be returned to Government Buildings, Portlaoise, Co Laois. A postal certificate is no longer acceptable as proof of postage. Flock owners are also advised of the option to submit forms online.

Saturday 6 December 2014

Commonage Management, the Current Position

The last few weeks have seen a flurry of activity. The EU have responded to Irelands RDP application with over 200 questions, the training courses for farm advisors have taken place, the hill farmers have had their meeting with the Minister and hill farmers have demonstrated their concerns with a mass meeting in Maam Cross and the March for Fairness in Castlebar.

We know that behind the scenes meetings between the Dept. of Agriculture and the EU Commission are ongoing. The outcome of this process of bi lateral meetings will be known within a month or so. But considerable change has already occurred, changes which are perhaps more significant than many people appreciate.

These are;

1) The scrapping of the minimum stocking rate to qualify for the Basic Payment Scheme on Commonage and marginal lands.

2) The statement issued by the IFA on the 5th of December.
"Pat Dunne said that one of the big concerns for hill farmers under the new GLAS rules was that plans might not be completed for farmers to join the scheme. IFA got a commitment from the Minister that the Commonage Implementation Committee will intervene in such cases and get Planners to do the Plan. This plan will in turn allow commonage shareholders to partake in the GLAS scheme and secure must needed support."

3) Minister Coveney's response to a parliamentary question asked by Pearse Doherty on the 4th of December where he concluded his statement with.
"I met this week with a number of farmers who expressed concerns regarding the commonage management plans.  While I have addressed certain elements of these concerns, I am reviewing their submission in the context of the threshold for environmental action which must be demonstrated in order to receive GLAS approval at EU level."*

The first point is the most significant. Up to now the Dept. of Agriculture's position was that to be eligible for payment on a commonage both the farmer and the commonage had to qualify as being eligible. In the farmers case this was by meeting a minimum stocking rates. In the case of the commonage the land had to be "farmed". Now qualification is to be based on the condition of the commonage alone. This effectively makes the Basic Payment Scheme on commonages an objectives based scheme rather than an actions based scheme. This is very significant as it means that the current situation where some farmers are "inactive" on a commonage while others manage flocks in excess of what their share might permit can continue where that is the wish of the farmers concerned. There is an informal trade off here farmer A gets his Basic Payment Scheme, Farmer B gets his payments as well but is also able to keep a viable flock. Now obviously there are difficulties where nobody farms the hill at all but I think it is unreasonable to expect direct payments to continue in these cases. Although it has to be said that even here the farmers still have a short window of opportunity to change their management and secure their payments.

If Pat Dunne is correct the second point is also very significant.  Think about it "if a group of farmers could not get an advisor to produce a commonage management plan that the CIC (Commonage Implementation Committee) would intervene and get planners to do the plan".  This can only mean that the CIC will appoint a planner to such a commonage.  Everyone accepts that it would be preferable if the farmers could get an advisor of their choice to do the plan. But equally we have to accept that this may not always be achievable and that there will be a need for directing available planning resources to where they are needed.  This role can only be filled by the Dept. of Agriculture.  If what the IFA are claiming is true then the Dept. of Agriculture are effectively agreeing to Point 6 of the Hill Farmers 12 point plan.

"The central clearing house will allocate an available advisor from a pool of trained advisors who operate in that geographical area. Where farmers have nominated an advisor, the clearing house will where possible appoint that advisor to the case. This system will prioritise planning resources to commonages with farmer support for the process. The advisor will work with the farmers in that commonage to develop a commonage management plan."

This is a big concession as it expands the Dept. of Agriculture role (through the CIC) in the commonage management planning process. In effect it has them adopting the leadership role in the process that we have always advocated. It could lead to further positive developments regarding training of advisors and planning standards.

Now I accept that the last point is a bit vague and we will have to wait and see what the Minister actually means but it is significant that he is considering their submission in the context of gaining GLAS approval at EU level.  The negotiations in Brussels will lead to more changes and I believe they will lead to a better scheme. Farmers and Planners will not get all of what they want but there is progress, slow and painful perhaps but progress nonetheless.

*The submission referred to  is  a reference to the Hill Farmers 12 Point plan based on the proposal made in the Case Studies document published by the EFNCP and written by Fergal Monaghan, James Moran and Michael Martyn.

The 266 Questions

The issue of how commonages should be dealt with under the various direct payment schemes is once again centre stage. The problem has if anything got more complex since the EU Commission responded to Irelands RDP application. The Commission has raised 266 questions with the Irish Authorities regarding the application lodged last July. Some of these are minor points that can easily be clarified and many have no impact on the commonage issue.  However there are several that strike right at the heart of the Dept. of Agricultures strategy for the next RDP and have a particular relevance for commonages.

These are;

14) The Irish authorities are asked to clarify the role of the Food Harvest 2020 strategy in relation to the strategy of this rural development programme. It seems that a number of needs are derived directly from Food Harvest 2020 instead of coming out of the ex-ante evaluation, the SWOT analysis and the needs assessment of this programme. The RDP has to be based on the established EU objectives and priorities and an analysis of the specific needs in Ireland. The Irish authorities are invited to set out how the RDP will align its strategic choices with these objectives. Food Harvest 2020 cannot be at the centre of the RDP's strategy. Especially the statement in section that the GLAS scheme has been designed to mitigate the environmental impacts of Food Harvest 2020 raises concerns and needs explanation. In addition, Food Harvest 2020 seems to have a strong focus on production and export increase. Considerations about expanding export volumes do not have a place in a rural development programme, and all rural development measures have to be in line with international obligations under the WTO Agreement.
 40) Also under opportunities the creation of new habitats and the protection of blanket bog and upland commonage are mentioned. These do not seem to have been taken up in the programme. The Irish authorities are asked to justify this, especially as the peatland situation is also recognised as a threat.

134) The Irish authorities are asked to provide much more information concerning the logic, the objectives and the content of the commitments. This is necessary in order to make an analysis of the types of operations possible, notwithstanding some relevant information provided in Annex 2. Without seeing the details of the description of types of operations it is also impossible to assess the premia amounts proposed.

141) Which rules concerning land eligibility are adopted for this measure? Agricultural land, to be defined by the Member State for this measure, does not need to be limited to UAA.

149) What is the reason for specifically targeting commonages and for the required 50% minimum participation in a commonage plan?

In short the EU is questioning the use of the RDP as an instrument to further the objectives of Food Harvest 2020 and is pointing out the incompatibility of certain proposals that are contrary to WTO (World Trade Organisation) rules.  This is relevant to commonages because it effectively rules out the proposed minimum stocking rate of 0.1 LU/ Ha on marginal lands previously needed in order to qualify for the Basic Payment Scheme. 

As regards GLAS the Commission go onto question the measures or options within GLAS (which is not surprising as many of themhave clearly not been thought out), for example why the Hen Harrier measure does nothing to recognise the value in the preservation of habitat types other than rushy grassland (a relatively low value habitat).  Even worse the measure does not even allow for the conservation of hay or silage within Hen Harrier SPA’s. In short the measure is agriculturally impractical and of little conservation value. It is no wonder that the EU is confused.
Not only are such lands of considerable conservation value but they are also represent an enormous store of Carbon.  For a scheme that sees itself as “low Carbon” ignoring the role of peatlands in locking away Carbon is puzzling. If bogs or heaths are damaged, overgrazed, drained or cut much of this Carbon can be lost to the atmosphere. If they are well managed the bogs remain as a sink for atmospheric Carbon.  In short a bog that is well managed can help address the greenhouse gas issue, a bog that is inappropriately managed contributes to the problem by releasing CO2 as the peat dries out and breaks down. While considerable funds are available to keep organic Carbon locked away in grassland soils, e.g. €314/ Ha available under the Low Input Permanent Pasture Measure, no provision is made for achieving the same goals on peatlands. This is surprising as the amount of Carbon at stake on blanket bog on a per Ha basis) far exceeds that on most permanent pastures.  Furthermore well managed peatlands can store vast quantities of water, helping to regulate water flow, reduce the risk of downstream flooding and thus helping to make the catchment as a whole more resilient to the negative impacts of climate change

They also wonder why the option of making payments under an agri environmental scheme on lands that are not considered as UAA is not being taken up. They certainly have a point here, surely farmers protecting valuable habitats like limestone pavement or long established Ash Hazel scrub should be rewarded for doing so. There seems to be a fixation with scrub in some parts of the Dept. of Agriculture. I remember a senior official recently stating that scrub is not habitat, he may have a point in respect of encroaching Gorse or Blackthorn but Juniper scrub and established Ash Hazel scrub are valuable habitats and worthy of payment under any agri-environment scheme.  
Finally the EU Commission query why there is a 50% requirement for commonages. Surely if a plan is worth having or if certain tasks are worth carrying out then they are of value irrespective of the level of support.

A series of bilateral meetings between the Dept. of Agriculture and the EU Commission to discuss the queries raised by the Commission are taking place this month. The first of these has already taken place. While I am not privy to what goes on at these meetings and I know that the Dept. of Agriculture still appear quite confident, changes to the RDP are inevitable. We know that the 0.1 LU/ Ha on marginal lands is gone; there will be more changes yet. Hopefully the proposed scheme will develop further and many of the current weaknesses will be addressed in the very near future.