The new CAP applies convergence to all entitlements, this will cause all low value entitlements to rise to a minimum level of €149 per Ha by 2019.  This is a very important development and its significance should not be underestimated by anyone.  Pillar 2 payments are capped, GLAS at €5,000, (GLAS+ at €7,000). Payments on commonage land in GLAS will be made at a rate of €120/ Ha.  The new ANC (Areas facing Natural Constraints) will also be capped at around the €3,400 level.  There is however effectively no cap to the value of payments under the Basic Payment Scheme and for farmers with large shares in commonage it will become more significant than either of the two pillar 2 schemes.

The criteria to qualify for the Basic Payment Scheme will be to be actively farming it.  Farmers who up to now declared their commonage share, but never actually used it, will cease to be eligible for payment on it unless they change their farming system in 2015.  Overall these farmers probably account for approx. 50% of the 15,000 farmers currently declaring commonage on their SPS applications.  In some areas, e.g. South Connemara, the figure is likely to be much higher.  The reasons for inactivity are numerous, but they include the age of applicant, off farm employment, farm enterprise incompatible with commonage use, open boundaries to commonage and many more. The options for these farmers are limited, the best choice is probably to lease the commonage share and the associated entitlements to an active shareholder, other options include developing a shepherding arrangement with an active farmer. The Dept of Agriculture have suggested that farmers who are unable to establish a minimum level of activity on the commonage could declare a claimed area of 0 ha for the marginal land parcels in 2015. While this would in most cases protect the payment under the Basic Payment Scheme in 2015 it would entail giving up on much of the benefits offered by the convergence of payments in the BPS scheme.  This would happen, not just because of the greater initial value of the new entitlements but more significantly because of the smaller number of entitlements that would issue in 2015.

The impact of this change will vary from commonage to commonage, it's effect may be at its most severe I places like South Connemara, in West Donegal and on the Kerry peninsulas the population is concentrated on a coastal strip, many of the holdings are scattered, often in a string of small parcels from the sea to the hill.  The small parcels do not favour large scale sheep farming and the culture of farming has traditionally been largely cattle based. In the past, small numbers of cattle could be housed or out-wintered on the enclosed lands.  In the summer months most of the animals could be put to the hill and a hay crop saved on some of the fields.  More recently, the increasing age profile of the farming community, reduced availability of labour, the unsuitability of agri-contractors equipment for small parcels and poor summers have all contributed to a reduction in hay production.  Winter feed is now often purchased from outside the area and paid for with the money from direct payments.  This change along with encouragement of winter housing facilitated a shift in stock types, old traditional breeds like the Hereford, Aberdeen Angus and Shorthorn were largely replaced by continental breeds in particular the Charolais and the Limousin.  The new breeds were less suited to the hill and consequently less and less use was made of upland grazing.

Ironically in an age when direct payments make up the bulk of the farms income, it was often the commonage that was bringing in the money and the land that was actively farmed supported the loss making livestock. This system is now under serious threat and the impacts locally will be very significant.  Without the direct payments from the forage area on the hill, the farm could be loss making and the purchase of fodder for overwintering stock may no longer be viable.  While the new RDP does offer an increase in the level of direct payments available farmers will have to give considerable attention to how they ensure that they qualify for these supports.

The Dept. of Agriculture had settled on a minimum stocking rate to determine eligibility for the Basic Payment Scheme. This had been set at 1 ewe to 1.5 Ha with a facility for lower levels where this necessary for environmental reasons. This approach has now been scrapped as it contravenes WTO rules on subsidising production. What mechanism will replace it is as yet unclear.

The min/ max figures will serve as a guide for stocking levels in the GLAS scheme.  The process of calculating min/ max figures is not without flaws and in the largely blanket bog commonages of South Connemara the figures would appear to be excessively high. Even more important is that sustainable farming on the commonage cannot be divorced from the enclosed land supporting it. The farm or group of farms using a commonage have to be looked at in their entirety. It is clearly a nonsense to suggest that the minimum level of stock to be put on a commonage by a farmer should be 200 ewes when the farm only has 10 acres enclosed. Obviously there is no across the board solution to these issues, they will have to be pointed out on an individual commonage basis as part of an appeal to the new Commonage Implementation Committee.

Farmers both individually and as a group must explore the implications of all of this for themselves.  a key point to remember is that the requirements for GLAS have to be in excess of the minimum required for the Basic Payment Scheme and will be identified as part of the commonage management planning process. We expect the final specifications and the terms an Conditions for GLAS will be published in the last week of January with the scheme to open on or around February 1st. There is a lot at stake for every farmer with commonage. If you want to get a commonage specialist to explain the issues involved to the farmers on your commonage please contact us at 091 738900 or e mail us at yourcommonage@gmail.com. You can still keep you existing planner for GLAS and Basic Payment Scheme Applications and get a specialist to help you protect your commonage interests.

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