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.

AEOS, Should you transfer to GLAS now?

AEOS was introduced in 2010 as a replacement scheme for REPS.  Both in terms of its aspirations and payments it fell well short of its predecessor.  Nevertheless the scheme opened for applications in 2010, 2011 and again in 2012.  Over the three rounds of the scheme approx 26,000 farmers joined.

AEOS has now been replaced by the new GLAS scheme.  This scheme will open later this month and the Dept. of Agriculture hope to fill up to 30,000 places this year.  A further 20,000 places will become available over the following two years.  For commonage farmers who are out of contract the decision to apply in 2015 will be relatively easy.  For farmers who are still in AEOS the situation is more complicated.  They will be allowed to transfer to the new scheme in 2015 but what are the factors that farmers should consider in making this decision. I believe every farmer in this position should consider the following issues before making up their mind.

·             Transition into GLAS

·             Access to the new scheme.

·             Full term in the GLAS scheme.

·             Input into the Commonage Management Plan.

·             Costs.

Transition into GLAS

For AEOS 1 farmers, i.e. people who joined AEOS in 2010, their contracts will finish at the end of 2015.  If they transfer to GLAS this year they will be paid AEOS for 9 months and GLAS for the remaining 3 months.  They will get a full year’s payments in 2015.  If they wait until 2016 to join GLAS they will get a full year’s AEOS payment in 2015 but in 2016 they will only be paid for 3 months in GLAS.  They will have lost the opportunity to have a seamless transition from one scheme to the next.  There are transaction costs associated with joining GLAS but delaying until 2016 means that those costs will be at their highest when their payments are at their lowest.  For this group joining GLAS in 2015 ensures a seamless transition to the new scheme with no break in payments.

For farmers in AEOS 2 & 3 while the opportunity to avail of the seamless transition will be there in 2016 they should also consider the other three points.

Access to the scheme.

There are many thousands of farmers with SAC/ SPA land who are also in AEOS.  They are barred from entry to GLAS in 2015 but will be allowed to join in 2016.  There will only be 10,000 places in 2016 and it is quite possible that the demand will exceed this.  If this happens there is no guarantee that you will get in.  This means that you may miss a year’s payments.

Full Term in the Scheme.

If anyone on your commonage joins GLAS in 2015 the clock will start ticking on the Commonage Management Plan.  Later applicants will only get paid for 4 years if they join in 2016 and only 3 years if they delay until 2017.

Input into the Commonage Management Plan.

With the Commonage Management Plan in place, it is very unlikely that the initial applicants will be willing to revisit large parts of this plan to accommodate new entrants.  Farmers who join GLAS in later years will in most cases have to accept the commonage plan as it is and will have very limited capacity to contribute to it.  

Costs.

Delaying will not result in any reduction in costs, the advisor and most probably the original applicants will insist that late applicants pay at least the same price as everyone else.

Discussion

Considering the turmoil over the last 6 months on the whole GLAS commonage issue and in spite of recent progress, some AEOS farmers may be tempted to adopt a wait and see approach to GLAS and hold off their applications until 2016.  They may also feel that completing another year or two in AEOS and then joining GLAS secures their payments for six or seven years rather than the five available by joining GLAS now.  While this analysis appears logical it does not take into account the negative impacts of delaying entry into GLAS.  It is based on several assumptions which may or may not be valid.  These include;

1.       That they will be able to access GLAS in 2016 or 2017.

2.       That they will have the same opportunity to contribute to the Commonage Management Plan as early entrants.

3.       That there will be no agri-environment scheme in the next  round of the CAP.

There may be situations in some commonages where there are very small numbers of shareholders, all of whom are in AEOS 2 or 3 and where everyone decides to hold off on applying for the scheme until 2016 or 2017.  In theory this would give them an extra 2 years AEOS followed by 5 years in GLAS.  This may seem like a good idea but it is not without risk. Look back to when REPS 4 was introduced; the farmers who left REPS 3 early to join that scheme were the winners.  The people who stayed on in REPS 3 with the hope of getting 5 years in each scheme missed the boat completely.

I appreciate that for some people there may be issues in respect of the costs associated with entry into GLAS, a determination on this can only be made by the farmer himself and I do not pretend to be able to advise on this.  The decision to join GLAS is one that each farmer has to make for themselves. Personally I believe that joining GLAS in 2015 is the best option.  It virtually guarantees entry for commonage farmers and gives them the opportunity to contribute to the development of the commonage management plan.  Delaying the application until 2016 puts off the transaction costs for another year but for AEOS 1 farmers it will cost them 9 months payments (up to €3,750) and they will still face the same costs the following year.  For all commonage farmers waiting until 2016 or 2017 carries the risk that they will not get in at all and the near certainty that they will get a reduced term in GLAS and have little or no input into the Commonage Management Plan. 

To borrow a phrase from popular economics, waiting until 2016 is just kicking the can down the road.  It does not solve anything and quite possibly creates new problems.