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 8.2.4.2 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.