Wednesday 29 April 2015

GLAS Second Tranche to open in the Autumn

The Minister for Agriculture has announced that the second tranche of GLAS will open in the Autumn. Places for 10,000 farmers will be made available with start dates of Jan 1st 2016.

He has also allowed extra time for the completion of Commonage Management Plans for first tranche applicants. The closing date for this task has now been extended to August 31st instead of the previously announced date of July 3rd. This is only reflecting the common sense argument that we in and others have been expressing over the past month.

The later date will have no impact on the anticipated start date of Oct 1st for first tranche applicants. Although it is still necessary for farmers to apply for GLAS before May 22nd to make the cut for the first tranche. Applying in the first round offers a part payment for 2015 (which should cover most if not all of the initial transaction costs) and a 63 month contract as opposed to the 60 month contract available to those who join in the second tranche. The part payment for 2015 not only adds extra value to the GLAS contract but the earlier payment also offers cash flow benefits in a situation where a large part of the costs are front loaded, this could be of value on farms that are not in an AEOS contract. That said; the second round will be of particular interest to those farmers who may have to split parcels on their BPS applications in order to maximise their GLAS payment. New applicants and those who have recently acquired extra land would also benefit.

The short gap between the first and second tranche will have implications for those who have decided to sit out the first tranche while GLAS and the Commonage Management Plan system bed in. While it remains to be seen how many farmers will be accepted in the first round, the filling of 10,000 additional places before years end means that commonage farmers will have to reassess their own position. A repeat of what we have seen in tranche 1 with most of the places going to tier 3 applicants would be a disaster for hill farming.

Farmers should not delay seeking the services of a commonage advisor. Even if you are going to wait until the second tranche, get involved early, have your say from the start, most importantly do not wait till GLAS 2 opens for business.  It is probable that the Dept. of Agriculture will insist on CMP's for the second tranche being submitted before the end of the year. For this reason, even a September start for GLAS 2 would in all likelihood only give 3-3.5 months for the completion of commonage plans.  Time will be short and for those who leave it too late there is no guarantee that the CMP will be ready in time. Shortening days and inclement weather will slow the production of Commonage plans as the Autumn progresses. Remember also that Commonage Advisors will still face a mammoth task while also being engaged in producing new GLAS applications along with Nutrient Management Plans for first tranche applicants. They will be busy.  

Begin the process now, seek out a commonage planner, one with experience and a track record. Remember you can have one planner advise you on farm level issues while dealing with a different person on commonage issues, in fact for most people this will be the norm.

For farmers on commonages where an advisor will be appointed in the coming weeks, you will soon receive a letter from the Dept. of Agriculture informing you of the approved advisor for your hill. Even if you are not a first tranche applicant, engage with the planner early, contribute to the process from the beginning and have your say on the future management of the commonage.

For more information on the commonage management planning process call

Fergal Monaghan at (091) 738900 or (087) 2356668 or e mail

Applications for GLAS by Commonage Farmers

In response to a Parliamentary Question asked by Eamon O Cuiv T.D. the Minister for Agriculture has provided information on the number of commonage farmers in each county and on how many of these have initiated GLAS application. The data makes for interesting reading, particularly when combined with the information on applications for the GLAS Commonage Advisory role. The data below was provided by the Minister on April 23rd.

I would not pay too much attention to the information on the number of GLAS applications with actions. This does not of itself indicate that these cases will progress to a full application to the scheme. What is clear is that in the minor commonage counties the performance is very poor. No applications at all in Meath, only 4 in Kildare and 3 in Kilkenny.

In the main commonage counties, the level of interest hovers between 10 & 30% which is reasonable in the circumstances. Of greater concern is the very slow rate of applications for the commonage advisor roles. Without an advisor there will be no commonage management plan and the glas applications will fail.

The number of advisors who have expressed an interest cannot hope to deal with more than 5% of commonages in the time available. This is where the real bottleneck that threatens the schemes rollout lies. It must be addressed and soon.

The breakdown of these applications within individual commonages is not available but we can expect them to fall into 3 main categories.

First, commonages with no interest at all. Secondly commonages where 1 or 2 individuals have applied and where no application has been made for the commonage advisor role and finally those with a good level of interest and where an advisor has or is in the process of applying for the commonage advisor role. The group of greatest concern are those where GLAS applications have been made by a small number of shareholders but where no commonage advisor has undertaken to prepare the plan. There is a very real danger that these farmers could face considerable difficulties. While the Dept. have said that they will be accommodated, it remains to be seen how this will be done.

What is certain though is that the July 3rd closing date for the completion of commonage management plans is not attainable and must be pushed back. The pressure to push the BPS closing date back makes the pushing back of the CMP date all the more urgent.

Number of GLAS applications initiate which have CommonageNumber of GLAS applications with actions and have CommonageNational number of farmers with Commonage

Dept of Agricultures new Land Eligibility Booklet

The Dept. of Agriculture have published the long awaited guidelines on what constitutes "eligible" land. This document will be posted out to every farmer in the coming weeks. In addition a series of information meetings will be held for farm advisors over the next week. The first of these is tomorrow night in Carrick on Shannon.

I will reserve judgement until after that meeting but I am certain that many advisors will be very irate that the issue of defining eligible land has been left so late in the process. This is of particular concern as many of the BPS applications already made will have to be re-examined to determine if an amendment is required. Expect to hear calls for application closing dates to be pushed back as far as mid June. We will have to wait and see how the Dept. of Agriculture react to this.

A copy of the booklet can be downloaded by following the link below.

Saturday 25 April 2015

Application rate for approval as commonage advisors is very slow.

As of today, April 25th there are only 101 Applications pending for the Commonage Advisor role. This must be a big concern for the Dept. of Agriculture and for the 2,500- 3,000 commonage farmers who have applied for GLAS. If the GLAS Commonage Management Plan is not submitted by July 3rd, then the GLAS applications made by the farmers involved will fail. To remedy the situation, action from all parties is required now. The Dept. of Agriculture must push out the closing date for Commonage Management Plans considerably. But advisors and farmers too, must look carefully at their own position and act immediately on those aspects of the process that they are in a position to influence.  

To fully appreciate what is going on it might be useful to look at the pattern of applications to date by county and by advisor. Geographically 42 applications have been made for commonages in Co. Galway, 33 in Mayo and only 26 in the rest of the country. No applications at all have been made for commonages in Sligo, Tipperary, Waterford and Cork all big commonage counties. Only 2 in Wicklow (both by yourcommonage) and just 4 in Kerry. In total applications for the advisor role have been made for commonages in just 7 out of the 25 commonage counties (Monaghan has virtually no commonage).

As regards the planners involved, planners account for 31 out of the 101 on the list. Michael Martyn has applied for a further 25 and Brian Dolan from Donegal and John Staunton from Letterfrack another 12 each. These 4 planning agencies between them have made 80 out of the 101 applications. Another 9 planners account for the remaining 21 commonages. While I am certain that other planners are working on applications and that the number of planners in the process will grow, it will not grow dramatically. Commonage work is demanding and requires a level of understanding of the dynamics of upland farming, that can only come from experience, as a result the pool of potential planners is inevitably quite small.   Most of the people with the level of interest and experience required have probably already applied for approvals and are on the applications pending list.  It is no accident that the two largest agencies in terms of applications, that is and Michael Martyn have been involved with commonage framework planning, commonage monitoring, farm advisory work, policy development and research for nearly 20 years. These people have made a personal investment in the issue and have the commitment to make it work for the farmers.

The implications of this for farmers are dramatic; no commonage advisor by May 22nd or no commonage plan by July 3rd and they will not get into GLAS. To prevent this happening, advisors, especially those who do not wish to get involved in commonage work should put their own commercial rivalries to one side and facilitate the appointment of a commonage advisor. If they do not they are letting their own clients down and in the long run undermining their own position. Farmers too must take more responsibility for engaging a commonage advisor, sure it is a big decision and ideally they would have more time to consider it, but the reality is that if they do not make that call well before May 22nd their GLAS applications will fail and the planning fees that they have already paid out will be for nothing. If their GLAS advisor has not or will not apply for the role they must take the initiative and ask someone who will. In my assessment the planners who have already stepped up to the plate are the ones with the interest and drive to make this process work. If you need a commonage advisor, the current applications pending list published by the Dept. of Agriculture is the place to look.

The current list of applications pending can be seen by following the link below.

Friday 24 April 2015

Upcoming radio broadcast

Fergal Monaghan from will be taking part in a discussion on RTE radio's Countrywide program tomorrow morning. He will be discussing the recent wildfires with Lorcan O Toole of the Golden Eagle Trust and IFA representative Pat Dunne. The program begins at 8 am tomorrow morning.

Saturday 11 April 2015


 Land Eligibility, Vegetation Succession and the Law of Unintended Consequences.

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The recent fires in Killarney National Park, in the Slieve Aughties and elsewhere have been very dramatic. Without doubt they have had a very negative impact on wildlife with nesting birds in particular badly affected. Tackling fires costs a great deal of money, it diverts Fire Brigade and Defence Force assets with consequent impacts on the provision of cover elsewhere, property is put at risk and potentially lives are endangered. It is almost certain that these fires were started by people, whether intentionally or accidentally, perhaps for a specific purpose such as clearing gorse, perhaps just reckless arson. Irrespective of the immediate cause we have to look further back to understand the factors contributing to these unfortunate events.

Fire fighters often refer to the fire triangle. These are the three components that make a fire possible. They are Fuel, Oxygen and Heat. All three are needed. As Oxygen from the atmosphere is readily available, it is the other two components that we should focus on. Heat is initially provided by whoever lights the fire, the reasons for such action vary from the irresponsible through to the reckless and indeed criminal. While this point receives a lot of attention, I would argue that it is the other component that is fuel that is more critical. The supply of large quantities of fuel, mostly dead vegetation such as Purple Moor Grass or highly flammable plants such as Gorse is a reflection of past and present management. The accumulation of fuel did not occur overnight, it built up over time on sites where soil types and climate are suitable for these species and where management encourages their proliferation.

In Ireland, agriculture has shaped the landscape. Many farmers have commented to me about how trees and shrubs are a much more significant part of the landscape then they were in the past, some have shown me old photographs to back up their argument. While in the past, the use of available timber as a fuel, for fencing or for the manufacture of tools or furniture obviously impacted on the level of tree cover, it was the impact of grazing animals that has had the greatest effect. The scale of this impact is not just related to stock numbers but perhaps just as importantly to their management. In turn both numbers and management have been influenced by market demands and by Agricultural policy at national and EU level.

The impact on sheep numbers, first by the introduction of ewe premium payments and later by compulsory destocking has been well documented. But the breaking of the link between production and payments that was brought in with the introduction of the Single Payment Scheme has been just as significant. Political and economic considerations at a global level led to this policy shift. A decision to stop subsidising EU food production, in part motivated by a desire to open up markets in other parts of the world for European Services and Manufactured goods has had unintended and perhaps unforeseen consequences. The impact on land management, vegetation succession and the risk of fire is one of them.

If sheep were not needed to draw down payments then the only incentives remaining are tradition (which will only bring you so far) and market demands. With the margins on hill sheep very tight and often, if we were honest about it negative, it was inevitable that numbers would fall as farmers adapted to the new regime. This exacerbated the impact of the compulsory destocking which preceded it.

Sheep numbers are significant but their management is also important. The traditional hill sheep year seen animals on the hill for most of the year, brought down only for lambing, shearing, and tupping. Numbers on the hill typically peaked in late summer/ autumn and were at their lowest in the spring. In many areas this ages old routine is changing. In the Nephins and in parts of Connemara, out wintering on the hill was restricted as part of a Government mandated restoration program. In Co. Wicklow many of the remaining farmers are voluntarily bringing their sheep off the hill in the winter. This shift in the seasonal aspect of grazing has had an impact on vegetation, imperceptible at first but over a 5-10 year timeframe quite dramatic. Heather in particular has benefitted from this shift. Browsing of heather by sheep is at its greatest when other forage is scarce, i.e. in the winter. Removing sheep in the winter gives heather a real chance to prosper. This was the intention on the degraded commonages in the Nephins and the Maamturks/ Twelve Bens. In Wicklow, it was a consequence of changing farming practices, hard winters and a shrinking (and aging) farming population.

The dramatic reduction in cattle numbers on the hills has also had an impact on vegetation and on the accumulation of fuel and the consequent risk of fire. Many factors have contributed to this. As with sheep, the breaking of the link between payments and production has had an impact. Changing market demands have also been instrumental; in the past many farmers kept young cattle into their second or even third year but the market now demands younger beef (in part a legacy of BSE) and this means that calves are sold off at a young age for finishing on specialist farms. The better price offered by finishing farmers for continental calves has led to a move towards these breeds. As a result the herd in most commonage areas now consists almost entirely of suckler cows (normally continental breeds). On many farms these are rarely if ever put on the hill. The reasons for this are varied but include concerns about cows having enough milk to rear a good calf, safety concerns connected with running a bull and time constraints due to the demands of off farm employment. In many cases it also has to be said that concerns about the fencing of watercourses for REPS were the last straw for cattle on the hill. The age old traditional system of utilising summer grazing on the hill, while conserving hay on the enclosed lands has collapsed. Inevitably this change in management has led to changes in vegetation. The principal beneficiary being Purple Moor Grass, a species that is only palatable for 2-3 months in early- mid-summer (when traditional cattle grazing on the hill was at its peak). Without grazing the Moor grass proliferates, inappropriate burning only increasing its dominance. Ironically the dead leaf litter from this plant is highly flammable and it is one of the main fuels for the fires that we see every spring. This should serve as a reminder if anyone needed one of the link between grazing patterns and wildfires.

The traditional farming systems have been replaced. Continental cattle kept on the enclosed land all year round, fed in winter on imported feed, paid for by money from area based schemes are now the norm. In extreme cases, the only contribution that the commonage is making to the farm is by facilitating the drawing down of payments to finance farming on the enclosed land. On sheep farms, while commonage usage is better, stock numbers have fallen and in many cases the remaining animals are brought down for the winter, even housed in sheds part paid for by grants. In many cases these changes have been at the behest of the state itself. In others, economic and demographic factors have been involved. But in all cases the vegetation on the hill has in one way or another been affected.  

We can see that changes on the commonage are consequences of changes in management and in many cases that these changes in management occurred in response to changes in agricultural policy. The result is that Purple Moor Grass, Gorse and rank Heather take over the commonages and the risk of fires increases. What we are now witnessing is another policy shift and we can be certain that in time this too will impact on management and subsequently on the vegetation. In many cases this shift will accelerate the process of abandonment, while in others it may have the potential to check it. The impact will vary from site to site but what we can be sure of is that this policy shift will have consequences and that some of these may be negative.

The case of the risk of wildfires is a dramatic example of this.  The link between accumulation of fuel and land eligibility is stark. Almost by definition the accumulation of large amounts of highly flammable leaf litter, tall heather or gorse indicates low grazing pressure. Ideally this would be addressed by grazing management alone but in many cases, fear about continued eligibility can lead to a temptation for a quick fix. Staving off the threat of ineligibility can lead to desperate attempts to restore the land to a grazeable condition by setting fires. But controlled burning is demanding in terms of the skills and labour required and in many cases these resources are just not available. All too often the result is that fires get out of hand and what started out with a limited objective results in an inferno that engulfs a hillside. On the other hand we must acknowledge that an ineligibility finding on a commonage could destabilise the finances on multiple farms and lead to reduced grazing and increased fire risk.

A response born out of desperation is not what is needed now. What we require is a much more measured response and a recognition that while a certain amount of resources are needed that the most important requirements are time and an understanding of the processes at work from all involved. In this context the July 3rd deadline for the production of commonage management plans is a key concern. If these plans are rushed and inadequate the potential of GLAS as a policy instrument to deliver real improvements in upland management may be fatally undermined. Of even greater concern is the possibility that lands could be found to be ineligible before there is a vegetation response to planned management changes.

I am not pretending that we can or should even try to turn the clock back, but rather that if we are to succeed we must address the drivers that have brought farming in upland areas to such an unstable and vulnerable condition. We are not going to achieve this by relying on a carrot/ stick approach alone. Obviously we need a balance of incentives, like GLAS and sanctions such as land ineligibility but we also need to put in place a framework that addresses the real issues and makes progress possible.    

How can this be done? GLAS is potentially a good start, but it is only a start and will not solve the many challenges that we face by itself.  I am not despondent about this, I believe there is potential and there is reason to be hopeful for the future. My experience suggests that farmers and the Dept. of Agriculture can work together to achieve a solution on most but probably not on all commonages. Such a solution could include;

  1. An appreciation by all sides that these issues are multi-facetted and that to address them we need a thorough understanding of the contributory factors at national and farm and land parcel level.
  2. A recognition that vegetation changes occur over time and in response to changes in management. The present problems did not develop overnight and will not be resolved in a short time.
  3. Support for the GLAS scheme by allowing sufficient time for the development of commonage management plans. The present closing date of July 3rd is not deliverable.
  4. A fair and transparent standard for assessing land eligibility including an evidence based and objective decision making process for determining land eligibility.
  5. To accept that evidence of reasonable and sustained progress towards optimal vegetation cover should be adequate in the short to medium term to ensure land eligibility.
  6. The provision of a properly financed training system for farmers and specialist contractors on the science and practical delivery of controlled burning as a management technique. Resources must be found within the RDP to deliver this.
  7. The use of some of the funds available under the targeted outputs measure to operate a more finely focussed scheme on selected commonages. This could serve to develop a template for more widespread action in the next round of the CAP.
  8. The provision of specialist training to advisors using the funding available for Continuous Professional Development to build expertise on hill farming, upland vegetation and the impact of management.
  9. The provision of specialist support to advisors and hill farmers to deal with particularly complex issues. This could involve an extension of the role of the Commonage Implementation Committee.
  10. A holistic approach to upland management that includes other state actors such as the NPWS and Local Authorities. This is of particular importance where sectional concerns about issues like drainage, fencing or controlled burning threaten to undermine the progress that everyone professes to want.

Photograph is from the Defence Forces twitter account.

Saturday 4 April 2015

The Truth about GLAS participation and Land Eligibility

Inevitably, when something new is introduced people can be reluctant to embrace it, the sceptic in us all can be tempted to believe the worst. Humans nature as it is, some people for their own reasons will wish to knock any new system.  Rumours take on a life of their own, mistruths are spread about and very soon the ordinary man is bombarded with all sorts of tales about what the new system is for and what it means for him. This is as true about GLAS and the commonage plans as it is about any other new approach to regulating agriculture.

In the case of GLAS, the situation has not been helped by the ham fisted approach taken by the Dept. of Agriculture to informing farmers about the new scheme and its relationship with the land eligibility issue. In my experience from talking to farmers, advisors, journalists and Dept. of Agriculture officials, the biggest source of confusion is in respect of the connection between the land eligibility issue and GLAS participation. Many farmers genuinely fear the implications of the Department of Agricultures position that lands that are not being farmed are ineligible for payment. They fear that participating in GLAS increases the risk of inspections and hence the risk of unfarmed lands being detected. In the case of commonage, many inactive shareholders feel that if other farmers in their commonage participate in GLAS that this will draw attention on them and threaten their payments. For this reason they are often tempted to try and dissuade others from participating in the scheme.

While these concerns are understandable, they are based on the assumption that GLAS participation creates this risk, the truth is that not farming the commonage creates the risk. Staying out of GLAS or attempting to dissuade others from joining does not negate this, in fact sticking the head in the sand makes the farmers situation even more vulnerable. The reason for this is simple, the remote sensing technology now available to the Dept. has completely changed the rules of the game.

Sophisticated image analysis and risk profiling techniques now give the Department of Agriculture a capability that is way ahead of the old inspection systems (which relied solely on site visits). For the Dept. this is a mixed blessing, it gives them much greater capability but this in turn can lead to much greater demands from EU auditors regarding the inspection process. For the farmer, it means that keeping the head down offers no protection.

Using the high quality satellite imagery now available, the Dept. of Agriculture have or very soon will have the ability to detect vegetation types indicative of low farming activity. They can cross match this with known cattle and sheep numbers from the relevant herd numbers and rapidly build up a risk profile for individual farms and commonages. This can and likely will be used in the selection process for inspections and subsequently in the process of verifying eligibility for payment. This process will take place as part of the Department of Agriculture responsibility for administering the Basic Payment Scheme and is independent of GLAS.

The only way of addressing this issue is to tackle it head on, keeping your head down and hoping that it will go away will not achieve anything. Even if you are not in a position to participate in a commonage management plan, the fact that your neighbours are, can only improve the commonage and reduce the risk to your BPS and ANC payments. GLAS does not protect against land being disallowed but it does encourage and help finance an approach to commonage management that might. Not participating in GLAS offers nothing at all except a constant dread of inspection.

Wednesday 1 April 2015

GLAS Deadline extended to May 22nd

The Minister for Agriculture Simon Coveney T.D. has announced that the closing date for GLAS applications will be extended to May 22nd and that for the Basic Payment Scheme to May 29th. The statement was made in response to a parliamentary question by Eamonn O Cuiv T.D.  This extension is very welcome and moves the process of preparing applications for a significant number of farmers to something approaching a viable timeframe. For farmers in commonage areas the extension must be accompanied by moving the date for completion of commonage management plans back to at least the end of July.

As it stands the window of opportunity between the closure of the Basic Payment scheme and the latest date for lodging commonage management plans is now only 5 weeks. 

I know that in our practice every member of staff has been on a six day week for the last 2 months, most working 10-11 hours a day, this is not sustainable for another 3 months. If Commonage Plans are to be completed in quantity and of adequate quality as much time as can possibly be granted must be made available. These time constraints apply to every farm advisory service provider in commonage areas and without some relaxation the first tranche of GLAS will not reach its goals, without more time, tier 1 prioritisation for commonage farmers will count for very little.  Advisors and farmers need extra time to prepare CMP's. While I appreciate that the Dept. of Agriculture need a certain amount of time to look over the plans received, this task cannot be equated with walking up to 4,500 commonages and negotiating agreement between close on 15,000 farmers.

If extra time is not granted CMP's will in many cases be rushed, less scrupulous advisors will force through the guideline min/max figures because they lack the time and perhaps the expertise to assess and scientifically justify more appropriate figures. As a result many farmers risk getting landed with an unsuitable plan. Others face the near certainty of their GLAS application failing because no CMP is submitted. An extra three weeks will not solve the problem but it will get thousands of commonage farmers over the line who would otherwise be left behind. It is the least they deserve and it is entirely within the Ministers gift.

An excerpt from the Ministers statement in the Dail follows.  

"I acknowledge the importance of the role of agricultural advisers in GLAS, the green low-carbon agri-environment scheme. Their professional expertise and experience are vital to the preparation of reliable GLAS applications that fully comply with regulatory and scheme requirements. That is why I have made it mandatory for all GLAS applications to be submitted by an approved GLAS adviser.
The negotiations with the European Commission on the scheme's details were long and protracted, which is why the earliest date I could open it was 23 February 2015. The original deadline set for submission of applications was 30 April. Admittedly, this was tight but there was no real opportunity to extend this without impinging upon the deadline for direct payment applications generally, a deadline fixed for many years by regulation as 15 May.
However, I have been working closely with the European Commission to get this regulatory deadline extended and I am delighted we have achieved some flexibility on this front. While we do not yet have the Commission's proposal, it is my intention to extend the GLAS deadline to 22 May, if possible, which will provide significantly more time to submit applications for this first tranche of GLAS.
To date, I am pleased a total of 9,119 applications have been created on the GLAS online application system. We are almost at the 10,000 mark and there is still quite some time to go. It is possible to push the basic payment and GLAS deadline back to the middle of June but there would be consequences to that. I am determined to get our basic payments out to farmers at the earliest possible date in mid-October. If we push the applications dates back, then the processing becomes much more difficult with the time available. I am also anxious that there would be at least a week separation between when the GLAS deadline and the basic payment closes. We do not want them all coming in on the same deadline with farmers who leave it to the last minute trying to get all their basic payment and GLAS applications in on the same day. We do not want our backs up against the wall but to have a little bit of breathing space, which is why it is the end of May for the basic payment scheme and a week earlier, 22 May, for GLAS applications. There is some flexibility with these dates but I would like us to achieve our deadlines by these dates too."