Wednesday 26 August 2015

List of Commonage Advisors is Published

The Dept. of Agriculture have published the list of approved commonage advisors. Just under 1,600 commonages now have an advisor. These advisors can now start walking commonages, talking to farmers and developing plans. This is a huge step forward, commonage planning can now finally get out of the traps.
There are about another 1,000 commonages involving at least one GLAS applicant that have not yet had an advisor appointed. The bulk of these (c 800) are commonages where more than one person applied for the Commonage Advisor role, a smaller number are commonages where no advisor applied. In the case of multiple applications, the Dept. of Agriculture will have to make a decision on who to appoint. The method for selecting an advisor in such cases is as follows. First the advisor with the support of the greater number of farmers will get selected, if two or more advisors have the support of an equal number of farmers, than the advisor with the support of the farmers with the greatest number of shares will be selected. If this also results in a draw than the advisor who has the support of the farmers owning the greater number of sheep will get the nod. This will be adequate to break the deadlock in the vast bulk of cases.
In the case of commonages where no advisor has applied, the Dept. of Agriculture briefly reopened the application period and I am sure  at least some of these sites will get an advisor to apply. The remainder will have an Advisor assigned by the Dept. of Agriculture. The farmers will have no say in this process.
The Dept. of Agriculture are also writing to farmers, officially informing them of who the Commonage Advisor is. The farmers on a given commonage must sign up to this advisor, even if they had previously signed up with someone else. Inevitably this means that some farmers will have to deal with a Commonage Advisor who is not their own Farm Advisor. In some cases, farmers with multiple commonages will have to deal with a number  of different advisors. This may make the process a little more complicated but it is unavoidable. If this applies to you, than make sure the two advisors are aware that you are involved in a second commonage and ensure that commitments made in each plan do not conflict with each other.
A full list of Advisors linked to each commonage can be found by following  the link below.

Saturday 15 August 2015

Approval of Commonage Advisors

The Dept. of Agriculture have restarted the process of formally approving commonage advisors. A large number of such approvals issued by post to advisors yesterday. Our estimate is that 50-60% of applications have now been dealt with. We expect the remainder to issue in the very near future. 

Letters to the farmers in each commonage, formally notifying them of the relevant approved advisor can be expected in the coming days. It is important for farmers to note that they must sign a Commonage Authorisation Form for the approved advisor, this applies even if they had previously signed one for someone else. This is required to allow the advisor to access relevant information about the farmers stocking rates and sheep numbers, information that he or she will need to complete the Commonage Management Plan. 

This is a big step forward and along with the guidelines issued earlier in the week will now allow the production of Commonage Management Plans to begin in earnest. 

Wednesday 12 August 2015

Commonage Planning Guidelines

The Dept. of Agriculture published the guidelines for planners to use in the preparation of Commonage management Plans. These guidelines give all parties a clear indication of how the planning process will proceed. The following items are of particular interest.

1)  Methodology to be used to assess a commonage.
2)  Data that will be available to a Commonage Advisor.
3)  Role of the Commonage Implementation Committee.
4)  Format of a Commonage Management Plan.
5)  Amendments to a commonage plan.

The methodology for producing a Commonage Management Plan stresses the importance of a field based assessment of the different habitat types on the commonage. This is based on the observed condition of a large number of waymarks, distributed throughout the site. These waymarks are selected to represent the range of habitat and conditions that are found on the commonage. In aggregate, they give us an indication of the condition of the different habitats. Each waymark is scored by reference to an assessment card which rates it in respect of 6 key parameters. These are Bare Peat, Heather, Sward, Evidence of livestock grazing, Purple Moor Grass and Scrub. The system is comparable with the methodology used in the old commonage framework plans although it has greater flexibility and is easier to use.

This card was developed by ourselves here at yourcommonage working closely with Brian Dolan and Michael Martyn and builds on years of experience in assessing upland and peatland habitats. It was field tested and we are satisfied that it is fit for purpose. It provides a workable method for guiding the planning process and ensures that that plans are evidence based. It does not however cover turloughs, sand dunes,limestone pavement or dry grasslands and perhaps further work is required to develop a method for dealing with sites like these. Nevertheless we now have the tools to get to work on the bulk of Irish commonages, this is a big step forward.

In relation to data to held by the Dept. of Agriculture,, it is now clear that advisors will have access to  data on stock numbers held by those farmers who have signed a Commonage Authorisation Form. They will also be able to request the total sheep numbers held by claimants to a particular commonage. However these stock numbers are indicative only as some farmers may be involved in several commonages and there is no way of apportioning stock numbers to a specific commonage.

The role of the Commonage Implementation Committee has been clarified and it will now serve to adjudicate on requests by advisors for derogations from the normal rules of the scheme. In this regard they will consider requests from advisors for reductions in the minimum stock numbers to be held both by individuals and in some cases for the whole commonage. This is of particular relevance to situations where existing stable flocks would have faced cuts to allow for stock to be held by previously inactive farmers entering GLAS. In these situations, the guidelines now provide for new applicants to contribute as little as 50% of their share of the commonage. This coupled with a widening of the gap between the minimum and maximum stocking rates (up to 20% above or below the calculated sustainable stock number)will minimise the impact on existing flocks and still allow for previously inactive shareholders to participate. Provision has also been made for situations where due to a high level of dormancy or poor uptake of the scheme locally it proves impossible for the participating farmers to meet the commonage minimum. It is also possible for advisors to make allowance for stock held by non participants when they are calculating sustainable stock numbers for a commonage. These are big steps forward and deal with most of the commonly expressed concerns by stakeholders.

The layout of a Commonage Management Plan has been published although on line submissions will not be possible for another 3-4 weeks. It is clear that the Commonage Management Plan will be capable of amendment, not only to allow for new applicants in later tranches of GLAs but also to redistribute the grazing commitments among participating farmers. This is potentially very valuable as we can be certain that the circumstances of individuals will change, perhaps in a manner that prevents them from reaching commitments previously made in good faith. The ability of the shareholders to respond to this and to redistribute stocking commitments allows them to adapt to changing circumstances. It makes the plan workable.

On a personal note, I believe that the guidelines published yesterday address most of the practical concerns held by farmers and advisors. The scheme is not without faults but we can now be assured that plans will be evidence based, will incorporate the concerns of farmers and will be flexible enough to cope not only with varying circumstances but also in respect of future events. We have a massive task ahead, it will take time and there will no doubt be challenges ahead, but the job now is to get commonages assessed, develop agreements between farmers and get payments issued. It has been a long journey, but the scheme we have now is far better then what we were presented with a year ago. The efforts of farmers, in particular the Irish Natura and Hill Farmers Association and some advisors has I believe paid off. It must also be accepted that the Dept. of Agriculture were open to reasoned arguments, they were willing to accept suggestions and recommendations from stakeholders and these guidelines demonstrate this. The contribution of some politicians to the debate, in particular Sean Kyne T.D., Eamonn O Cuiv T.D. and Marian Harkin MEP must also be acknowledged.

P.S. Two final steps remain, the Dept. of Agriculture must publish the full list of approved advisors and write to the farmers involved as soon as possible. Secondly the software for submitting a plan must be finalised, tested by advisors and rolled out as soon as is practical.

Thursday 6 August 2015

Commonage Guidelines to be issued to Planners.

The Dept of Agriculture will be issuing guidelines to planners in the very near future. This will allow the assessment of commonages to begin in earnest. These guidelines will also provide guidance on how advisors can deal with exceptional cases and details on the role of the Commonage Implementation Committee. To the Dept of Agriculture's credit, the guidelines have addressed many of the concerns that planners and farmers have raised over the last year.

While planning can now begin on those commonages with an advisor (approx 20%), work on the remainder will have to wait until an advisor is officially appointed. The indications are that this will be at least another couple of weeks. There are several hundred commonages where no advisor has applied for the role, these are currently being notified to advisors to see if any of them will be taken up. If this is not successful the Dept will appoint advisors. This process is expected to take until at least the end of August.

While the deadline has been put back to Oct 31st, there is no chance of 2,600 commonage management plans being completed by that date. GLAS will reopen in October, when this happens advisor effort will be diverted to that scheme. By the time GLAS closes in late November, the evenings will have closed in, the chances of bad weather will be greater and progress on fieldwork will slow to a crawl.

Many advisors have underestimated the scale of the work involved, the tasks relating to fieldwork, i.e. assessing eligibility, mapping dumping and encroachments onto a commonage are time consuming and require a thorough and time consuming site investigations. For safety reasons, advisors would be mad to work alone at high altitudes or isolated sites. Coping with this doubles the labour requirement, something which many appear to have omitted from their calculations. Planning agencies dependent on recently recruited graduates will face a mammoth task in equipping, training and organising a large field campaign. I doubt if they really appreciate the difficulties they will face. Anecdotal evidence suggests that some planners, including some very large operations believed that commonage agreements could be achieved as a desktop exercise without the need for any fieldwork. If any advisors are still of this opinion, they need to change tack quick and start planning a fieldwork campaign and follow up engagements with farmers as a matter of urgency.

My advice to advisors, be properly equipped, don't work alone, take the weather into account. To farmers, remember that the Commonage a Management Plan does not just apply to tranche 1 applicants. If you are considering joining GLAS in the future, get in touch with the Commonage advisor to see how they intend to proceed. When you meet the advisor to discuss the plan, insist on seeing the evidence on which they are basing their recommendations, do not be fobbed off by someone telling you that the Dept. of Agricultures figures are fine. Remember it is your payments that are dependent on this plan, make sure it is right.  To the Dept of Agriculture, get letters out to farmers with the formal approval of advisors as soon as possible.

Finally on a positive note, let us put the trials of the last year behind up, the scheme as now proposed is much improved. The rollout is a huge task, many advisors and Dept officials are only starting to appreciate the scale and complexity of what is needed. It will be challenging but we will get through it, there will be issues along the way but at least we will be underway.