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.

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