GLAS has Opened.

It was a long and tortuous journey but GLAS has finally opened. Interest from farmers has been good and advisors are registering potential applicants. The software system is better than I had expected. The criticisms voiced by some about the system are I believe a little unfair. One flaw though, is that the text message method for authorising the production of applications does not work for herd numbers with two or more names. We have brought this to the attention of the dept of agricultures attention and we are sure it will be rectified.

The big concern though is the proposed, but as yet unpublicised closing date of April 30th. This is a very shortsighted proposal. The window for applications is far too short as it is. The late start to the scheme has been bad enough, but cutting two weeks off at the tail end is a huge mistake. If this goes ahead, applications will be rushed and farmers and advisors will be placed under intolerable pressure.

Considering that the scheme has been delayed for 4 months beyond the once hoped for November start and that the full list of advisors has not yet been published, a request for May 15th closing date is not unreasonable. I would hope that all stakeholders would resist this needless shrinking of the application period.

Minister, after the long hard road that everyone, dept staff, advisors and most of all farmers have travelled to get us to this point, give the scheme a chance, extend the closing date to May 15th.

Basic Payment Scheme Opens

The on line facility allowing advisors to submit BPS applications has opened. The maps and paper applications will be forwarded to farmers over the coming weeks. This is the first really big step in the new CAP. Access to the Basic Payment Scheme, the ANC scheme and GLAS is dependent on this application. 

While the closing date on May 15th might seem a long way off there is a lot of work for farmers and advisors to get through between now and then. To ensure that everything goes smoothly, farmers should take steps to address their application as soon as possible. 

The next big step is the opening of GLAS for applications. I expect that this will be announced at the Fine Gael ard fheis on Friday or Saturday and that the terms and conditions along with the final specifications for the scheme will be published on Monday. Full details of how to apply for GLAS will be on this site within a few days. 

The opening of the GLAS Scheme is imminent.

All the indications suggest that the opening of the GLAS scheme will be announced next week. We know that the Basic Payment Scheme will open for on line applications this week and that the final Advisor Commonage Course finished last Friday (13/2/15) and the Minister for Agriculture announced in his Radio interview just over a week ago that GLAS would open within 10 days. 

It is now expected that the schemes opening will be announced at the Fine Gael Ard Fheis in Castlebar on Friday. The window for applications is very narrow, (only 84 days), in reality because of the need to complete Basic Payment Scheme applications during the same period it will effectively close much sooner than that. Farmers must move quickly. 

 Yourcommonage advisors are available to help any farmer access the scheme, not just those with commonage. We can guarantee that our prices for GLAS applications will be at least 15% cheaper than Teagasc. In addition we will offer a substantial discount on the cost of a Commonage Management Plan to farmers who had their individual GLAS application prepared by one of our advisors. For farmers with 2 or more commonages there will an additional discount on the cost of second or subsequent Commonage Management Plans. 

 Contact 

  YourCommonnonage at (091) 738900 

 Fergal Monaghan at (087) 2356668 

 or 

 Thady O Brien at (087) 2302667

Footbaths for Sheep.

Agriland have published a very interesting article on the use of Copper Sulphate or Bluestone in foot baths for treating lameness in sheep. Sheep farmers should note that as well as being of questionable value for treating this problem, Copper is a very serious pollutant particularly in aquatic environments. It is extremely toxic to invertebrates and its use in Freshwater Pearl Mussel catchments carries enormous risks. Zinc based treatments are not only more effective but they are less toxic to the both sheep and the farmer and are safer to use in sensitive environments. 

Bluestone should not be used in Texel sheep footbaths, expert warns

By Richard Halleron on February 10, 2015

Texel sheep producers should not use bluestone in foot baths, according to independent veterinary consultant Dr Fiona Lovett.

Speaking at the Teagasc National Sheep Conference in Trim, she said that copper sulphate is used extensively for this purpose in Ireland.

“Flockowners with Texel sheep should be aware of the health-related issues for this breed when using copper. There is also a heightened awareness in the UK of the environmental pollution issues relating to the use of this chemical,” she said.

Lovett also pointed out that foot bathing will have no impact whatsoever on lameness levels within sheep flocks, unless the facilities used are fit for purpose.

“Zinc and formalin are the active ingredients of choice for foot baths. Formalin should not be used at concentrations above 3%.

“In order to maximise the impact of foot bathing, it is important to clean the feet of sheep before they come into contact with the active chemical. This can be achieved by pre hosing  or having a pre-bath containing clean water.

“Sheep should be allowed to rest on hard standing for a few minutes after foot bathing. Simply allowing them to go back to pasture will have the effect of washing away the active foot bath chemical.”

Lameness

Lovett confirmed that foot bathing, while helping to prevent lameness in sheep, should not be regarded as a cure for footrot.

“Ewes with clinical footrot must be treated with the appropriate antibiotic. If the same ewe presents with this problem on more than two occasions, the animal should be culled from the flock as soon as she is sound.

“Footrot is an inheritable disorder. Ewes that demonstrate chronic symptoms should not be used for breeding purposes,” she said.

Lovett also pointed out that feeding points and those areas that are most trafficked by sheep are focal points for the spread of footrot infection.

“The campylobacter bacterium, responsible or footrot, cannot survive in high pH conditions. As a consequence, there is strong merit in spreading lime around feed troughs, gateways and other areas that are heavily trafficked by sheep,” she said.

AEOS, Should you transfer to GLAS now?

AEOS was introduced in 2010 as a replacement scheme for REPS.  Both in terms of its aspirations and payments it fell well short of its predecessor.  Nevertheless the scheme opened for applications in 2010, 2011 and again in 2012.  Over the three rounds of the scheme approx 26,000 farmers joined.

AEOS has now been replaced by the new GLAS scheme.  This scheme will open later this month and the Dept. of Agriculture hope to fill up to 30,000 places this year.  A further 20,000 places will become available over the following two years.  For commonage farmers who are out of contract the decision to apply in 2015 will be relatively easy.  For farmers who are still in AEOS the situation is more complicated.  They will be allowed to transfer to the new scheme in 2015 but what are the factors that farmers should consider in making this decision. I believe every farmer in this position should consider the following issues before making up their mind.

·             Transition into GLAS

·             Access to the new scheme.

·             Full term in the GLAS scheme.

·             Input into the Commonage Management Plan.

·             Costs.

Transition into GLAS

For AEOS 1 farmers, i.e. people who joined AEOS in 2010, their contracts will finish at the end of 2015.  If they transfer to GLAS this year they will be paid AEOS for 9 months and GLAS for the remaining 3 months.  They will get a full year’s payments in 2015.  If they wait until 2016 to join GLAS they will get a full year’s AEOS payment in 2015 but in 2016 they will only be paid for 3 months in GLAS.  They will have lost the opportunity to have a seamless transition from one scheme to the next.  There are transaction costs associated with joining GLAS but delaying until 2016 means that those costs will be at their highest when their payments are at their lowest.  For this group joining GLAS in 2015 ensures a seamless transition to the new scheme with no break in payments.

For farmers in AEOS 2 & 3 while the opportunity to avail of the seamless transition will be there in 2016 they should also consider the other three points.

Access to the scheme.

There are many thousands of farmers with SAC/ SPA land who are also in AEOS.  They are barred from entry to GLAS in 2015 but will be allowed to join in 2016.  There will only be 10,000 places in 2016 and it is quite possible that the demand will exceed this.  If this happens there is no guarantee that you will get in.  This means that you may miss a year’s payments.

Full Term in the Scheme.

If anyone on your commonage joins GLAS in 2015 the clock will start ticking on the Commonage Management Plan.  Later applicants will only get paid for 4 years if they join in 2016 and only 3 years if they delay until 2017.

Input into the Commonage Management Plan.

With the Commonage Management Plan in place, it is very unlikely that the initial applicants will be willing to revisit large parts of this plan to accommodate new entrants.  Farmers who join GLAS in later years will in most cases have to accept the commonage plan as it is and will have very limited capacity to contribute to it.  

Costs.

Delaying will not result in any reduction in costs, the advisor and most probably the original applicants will insist that late applicants pay at least the same price as everyone else.

Discussion

Considering the turmoil over the last 6 months on the whole GLAS commonage issue and in spite of recent progress, some AEOS farmers may be tempted to adopt a wait and see approach to GLAS and hold off their applications until 2016.  They may also feel that completing another year or two in AEOS and then joining GLAS secures their payments for six or seven years rather than the five available by joining GLAS now.  While this analysis appears logical it does not take into account the negative impacts of delaying entry into GLAS.  It is based on several assumptions which may or may not be valid.  These include;

1.       That they will be able to access GLAS in 2016 or 2017.

2.       That they will have the same opportunity to contribute to the Commonage Management Plan as early entrants.

3.       That there will be no agri-environment scheme in the next  round of the CAP.

There may be situations in some commonages where there are very small numbers of shareholders, all of whom are in AEOS 2 or 3 and where everyone decides to hold off on applying for the scheme until 2016 or 2017.  In theory this would give them an extra 2 years AEOS followed by 5 years in GLAS.  This may seem like a good idea but it is not without risk. Look back to when REPS 4 was introduced; the farmers who left REPS 3 early to join that scheme were the winners.  The people who stayed on in REPS 3 with the hope of getting 5 years in each scheme missed the boat completely.

I appreciate that for some people there may be issues in respect of the costs associated with entry into GLAS, a determination on this can only be made by the farmer himself and I do not pretend to be able to advise on this.  The decision to join GLAS is one that each farmer has to make for themselves. Personally I believe that joining GLAS in 2015 is the best option.  It virtually guarantees entry for commonage farmers and gives them the opportunity to contribute to the development of the commonage management plan.  Delaying the application until 2016 puts off the transaction costs for another year but for AEOS 1 farmers it will cost them 9 months payments (up to €3,750) and they will still face the same costs the following year.  For all commonage farmers waiting until 2016 or 2017 carries the risk that they will not get in at all and the near certainty that they will get a reduced term in GLAS and have little or no input into the Commonage Management Plan. 

To borrow a phrase from popular economics, waiting until 2016 is just kicking the can down the road.  It does not solve anything and quite possibly creates new problems. 

Clarity on the Land Eligibility Issue.

Over the last year there has been huge concern over the issue of eligibility of land as forage area. This is a critical point as a determination that land is ineligible not only leads to a reduced payment but can potentially lead to large penalties for over claiming.

Many commentators have advocated that the Dept. of Agriculture should make use of the provision referred to as article 4(h) within the EU regulations. This provision allows for payment on lands where heather and shrubs are predominant provided that they are grazed in accordance with established local practices. The Dept. of Agriculture position on this has been unclear until now.

The current position was outlined last week by the Minister for Agriculture in a reply to a parliamentary question from Eamon O Cuiv T.D.. In his reply the Minister has confirmed that areas containing Heather and scrub may be eligible for payment if there is evidence of agricultural activity.

This is a very important concession; it does not however mean that evidence of activity within a parcel means that the entire parcel is eligible. A common feature of many land parcels, particularly so on larger plots and on commonages is the uneven distribution of grazing pressure. Animals often preferentially graze on sweeter grass and avoid areas where the vegetation is less palatable. This pattern may be subject to change through the course of the year as stock change from one favored forage plant to another. Managing stock behavior to encourage grazing in under utilised parts of the site is a key step to ensuring continuing eligibility. 

Tirglas Advisors can give you practical advice on how this can be done in an effective and workable manner and help secure payments on as much of the parcel as possible. This is an issue that goes way beyond GLAS, The GLAS scheme is however a potentially useful mechanism to deliver the improvements that secure payments across all schemes.

 The full text of Eamon O Cuiv’s question and the reply from Minister Coveney follows.

Deputy Éamon Ó Cuív asked the Minister for Agriculture, Food and the Marine:

 "If the definition of permanent grassland for the purposes of the implementation of the basic payment schemes and greening schemes here include permanent pasture and shrubs and-or trees which can be grazed including established scrub and heather - Calluna vulgaris - in all stages of its life cycle and also land which can be grazed and which forms part of local practices where grasses and other herbaceous forage are traditionally not predominant in grazing areas, as set out in article 4 (h) of the direct payment regulations 1307/2014; and if he will make a statement on the matter".

Minister for Agriculture, Food and the Marine (Deputy Simon Coveney):
"The provision referred to under article 4 (h) of Regulation 1307/2014 for permanent grassland is 'land used to grow grasses and other herbaceous forage … it may include other species such as shrubs and or/trees which can be grazed provided the grasses remain predominant as well as where member starts so decide land which can be grazed and which forms part of local practices where grasses and other herbaceous forage are traditionally not predominant in grazing areas'.

In relation to the Basic Payment Scheme, the requirement is that each agricultural parcel declared by an applicant under this Scheme must have a farming activity on it to be eligible for payment. Such an activity, which must be appropriate to the type of land involved and which should ensure that the area currently eligible for payment remains in this state, includes grazing the land.

The areas as described, excluding established scrub and ungrazed heather will, in general terms, be eligible under the Basic Payment Scheme provided there is evidence of an agricultural activity being carried out".

GLAS, almost there.

With the opening of GLAS only a matter of weeks away it is appropriate to look at how far the commonage aspects of the scheme have developed from the initial proposals made last summer.

The initial proposals were for 80% of the farmers on commonage to nominate an advisor. This person would then develop a Commonage Management Plan. This plan would also serve as a joint application for the commonage. Individual applications to draw down payment on privately owned land could only be made subsequent to this joint application.  

Farmers and advisors throughout the West and Northwest were very critical of these proposals.  They saw them as placing barriers to entry that would serve to keep many if not most commonage farmers out of the scheme.

Foremost among the concerns were;

1. The qualified majority of 80% required to initiate an application.
2. The joint application leading to a joint contract and the possibility of collective liability.
3. The status of the min/ max numbers published by the Dept. of Agriculture for each commonage.
4. How eligibility for Pillar I payments would be dealt with, in particular would this require a minimum stocking rate and if so at what level ?
5. The lack of detail as to what a commonage management plan would contain.
6. The timescale for developing Commonage Management Plans.
7. The issue of the cost of developing the Commonage Management Plan, for farmers particularly those with multiple commonages this was a very real issue.  For advisors the perceived difficulties regarding getting paid at all on commonages with very large numbers of shareholders was a matter of serious concern.
   
   Since then, the scheme has evolved considerably. If we deal with each of the points listed above we can see the scale of the progress to date.  

1. The qualified majority of 80% was reduced first to 50%, then to 50% of the active farmers and finally reduced to a target rather than a requirement. 
2. The Commonage Management Plan is no longer a joint application; it is no longer a prerequisite for entering GLAS. Farmers can now apply as individuals and subsequently develop a commonage management plan with the other farmers who have decided to join the scheme. This is very significant as it means that each farmer will have his own GLAS contract, there will be no collective liability.
3. The min/ max numbers are now guidelines; alternative figures can be submitted by an advisor if he can support this on a scientific basis.
4. The Dept. of Agriculture subsequently introduced a minimum stocking rate of 0.1 LU/Ha for eligibility for the Basic Payment Scheme; this has now been scrapped under pressure from the EU Commission.
5. The content of the Commonage Management Plans has been clarified at training courses for farm advisors.  Farm Advisors are now in a position to properly assess the work required, the time commitments and the cost of delivery.
6. This issue of the timescale for developing the Commonage Management Plans is still unclear. The official line is that the Minister is still considering it but privately advisors have been told that Commonage Plans can be developed after the GLAS closing date. This approach is now unavoidable considering that GLAS must close by May 15th at the latest.  
7. The costs of the commonage management plan will still have to be borne by the farmer; attempts at getting the Dept. of Agriculture to pay advisors directly have been unsuccessful.

While not everything is as we would like it, there have been huge gains and it would be churlish to deny this. In particular the scrapping of the 50/80% as a requirement to join the scheme and allowing each farmer to join as an individual has been a huge step forward.

These gains have been thanks largely to a concerted, but very level headed and disciplined campaign led by the farmers themselves (Colm O Donnell and Brendan Joyce deserve particular credit) with the support of some farm advisors (including Brian Dolan and Liam McKinney in Donegal, John McDonagh in Mayo, Michael Martyn in Offaly and dare I say ourselves in Galway). The positive role played by certain politicians should also be acknowledged, notably Sean Kyne T.D. and Eamon O Cuiv T.D., both of whom repeatedly raised the issues involved with the Minister, with the Dept. and in the Dail.  Marian Harkins part in bringing these matters to the attention of the EU Commission was also instrumental in delivering improvements to the scheme.  There has been a lot of progress and I expect when the final specifications and the terms and conditions are published there will be more.

Very soon the ball will be in the farmer’s court, each individual will have to decide whether to join the scheme or not. They should take heart from the gains that have been made but also note that the creeping issue of ineligibility for commonages which are not being farmed adequately has not gone away.

P.S.        I know that for some people the issue of sticking with AEOS for the moment will be tempting, the pluses and minuses of this approach are complex and will be different for each individual; I hope to deal with these in the next week.