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.
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;
- The qualified majority of 80% required to initiate an application.
- The joint application leading to a joint contract and the possibility of collective liability.
- The status of the min/ max numbers published by the Dept. of Agriculture for each commonage.
- 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 ?
- The lack of detail as to what a commonage management plan would contain.
- The timescale for developing Commonage Management Plans.
- 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.
- 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.
- 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.
- The min/ max numbers are now guidelines; alternative figures can be submitted by an advisor if he can support this on a scientific basis.
- 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.
- 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.
- 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.
- 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.
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