Showing posts with label Commonage Implementation Committee. Show all posts
Showing posts with label Commonage Implementation Committee. Show all posts

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.


http://agriculture.gov.ie/media/migration/farmingschemesandpayments/glas/AGuidecompletionGLASCommonagePlan.pdf

Wednesday, 3 June 2015

Further Applications for Commonage Advisor Positions.




The most recent listing of applications for Commonage advisor positions shows that advisors have applied for a further 44 commonages, bringing the total to 308.

The latest list includes sites in Waterford and Wexford for the first time. The County with the greatest increase is Donegal with 14 applications. Galway continues to be very strong with a further 12 applications. The rate of increase in Mayo has slowed to just an additional 4 commonages in the last week. Cavan, Sligo, Leitrim and Tipperary also show modest increases in numbers. The current position is shown on the table below.

County
No. of Commonages
% of National Total
Galway
117
37.99
Mayo
71
23.05
Donegal
50
16.23
Tipperary
17
5.52
Kerry
12
3.90
Leitrim
12
3.90
Cavan
8
2.60
Sligo
7
2.27
Cork
4
1.30
Wicklow
3
0.97
Waterford
3
0.97
Clare
1
0.32
Laois
1
0.32
Roscommon
1
0.32
Wexford
1
0.32
Totals
308
100.00

 

We probably should not read too much into last week’s figures coming as they were in the week that both GLAS and the BPS schemes closed.  Advisors were preoccupied with those schemes and so applications for commonage advisory positions were almost certainly depressed.  However with less than two weeks until the closing date for these applications the application rate can be expected to pick up.

This leaves us with two very obvious questions.

  1. Will the expected increase in applications be enough to cover the bulk of Commonage applicants?
  2.  What role will the Commonage Implementation Committee take in accommodating those left behind?

The answers to these questions will become clear soon enough.

Saturday, 6 December 2014

Commonage Management, the Current Position

The last few weeks have seen a flurry of activity. The EU have responded to Irelands RDP application with over 200 questions, the training courses for farm advisors have taken place, the hill farmers have had their meeting with the Minister and hill farmers have demonstrated their concerns with a mass meeting in Maam Cross and the March for Fairness in Castlebar.

We know that behind the scenes meetings between the Dept. of Agriculture and the EU Commission are ongoing. The outcome of this process of bi lateral meetings will be known within a month or so. But considerable change has already occurred, changes which are perhaps more significant than many people appreciate.

These are;

1) The scrapping of the minimum stocking rate to qualify for the Basic Payment Scheme on Commonage and marginal lands.

2) The statement issued by the IFA on the 5th of December.
"Pat Dunne said that one of the big concerns for hill farmers under the new GLAS rules was that plans might not be completed for farmers to join the scheme. IFA got a commitment from the Minister that the Commonage Implementation Committee will intervene in such cases and get Planners to do the Plan. This plan will in turn allow commonage shareholders to partake in the GLAS scheme and secure must needed support."

3) Minister Coveney's response to a parliamentary question asked by Pearse Doherty on the 4th of December where he concluded his statement with.
"I met this week with a number of farmers who expressed concerns regarding the commonage management plans.  While I have addressed certain elements of these concerns, I am reviewing their submission in the context of the threshold for environmental action which must be demonstrated in order to receive GLAS approval at EU level."*

The first point is the most significant. Up to now the Dept. of Agriculture's position was that to be eligible for payment on a commonage both the farmer and the commonage had to qualify as being eligible. In the farmers case this was by meeting a minimum stocking rates. In the case of the commonage the land had to be "farmed". Now qualification is to be based on the condition of the commonage alone. This effectively makes the Basic Payment Scheme on commonages an objectives based scheme rather than an actions based scheme. This is very significant as it means that the current situation where some farmers are "inactive" on a commonage while others manage flocks in excess of what their share might permit can continue where that is the wish of the farmers concerned. There is an informal trade off here farmer A gets his Basic Payment Scheme, Farmer B gets his payments as well but is also able to keep a viable flock. Now obviously there are difficulties where nobody farms the hill at all but I think it is unreasonable to expect direct payments to continue in these cases. Although it has to be said that even here the farmers still have a short window of opportunity to change their management and secure their payments.

If Pat Dunne is correct the second point is also very significant.  Think about it "if a group of farmers could not get an advisor to produce a commonage management plan that the CIC (Commonage Implementation Committee) would intervene and get planners to do the plan".  This can only mean that the CIC will appoint a planner to such a commonage.  Everyone accepts that it would be preferable if the farmers could get an advisor of their choice to do the plan. But equally we have to accept that this may not always be achievable and that there will be a need for directing available planning resources to where they are needed.  This role can only be filled by the Dept. of Agriculture.  If what the IFA are claiming is true then the Dept. of Agriculture are effectively agreeing to Point 6 of the Hill Farmers 12 point plan.

"The central clearing house will allocate an available advisor from a pool of trained advisors who operate in that geographical area. Where farmers have nominated an advisor, the clearing house will where possible appoint that advisor to the case. This system will prioritise planning resources to commonages with farmer support for the process. The advisor will work with the farmers in that commonage to develop a commonage management plan."

This is a big concession as it expands the Dept. of Agriculture role (through the CIC) in the commonage management planning process. In effect it has them adopting the leadership role in the process that we have always advocated. It could lead to further positive developments regarding training of advisors and planning standards.

Now I accept that the last point is a bit vague and we will have to wait and see what the Minister actually means but it is significant that he is considering their submission in the context of gaining GLAS approval at EU level.  The negotiations in Brussels will lead to more changes and I believe they will lead to a better scheme. Farmers and Planners will not get all of what they want but there is progress, slow and painful perhaps but progress nonetheless.















*The submission referred to  is  a reference to the Hill Farmers 12 Point plan based on the proposal made in the Case Studies document published by the EFNCP and written by Fergal Monaghan, James Moran and Michael Martyn.

Saturday, 20 September 2014

Confirmation of the Settlement between the Dept of Agriculture and the Hill Farmers. .


There have been significant development on the commonage front over the past few weeks. With the Dail sitting again after the summer holidays it is not surprising that several T.D.s have raised the issue in the chamber.

Of particular interest is the response by Minister Coveney to  Deputy Brendan Griffins question on the issue of the collective agreement. The response by Minister Coveney puts on record what Departmental policy is and confirms the settlement with the hill farmers.

The full text of Deputy Griffins question and the Minister's response is given below.

Deputy Brendan Griffin asked the Minister for Agriculture, Food and the Marine his views on the concerns of commonage farmers in respect of the 50% consent requirement for participation in GLAS, if he will address those concerns; and if he will make a statement on the matter.  


Minister for Agriculture, Food and the Marine (Deputy Simon Coveney):  I have listened very carefully to the concerns of commonage farmers and I recognise that these concerns are real. Over the course of the consultation process on the new Rural Development Programme, which extended for a year and half, we have adapted and rebalanced our proposals for commonages quite significantly in the light of those concerns. A Commonage farmer shall apply individually for GLAS declaring that s/he is complying with the GLAS Commonage Management Plan (CMP). The CMP is to be submitted by an advisor i.e. one advisor and one plan per commonage.


 Where DAFM identifies that the 50% level of active shareholders cannot be reached the matter will be referred to the Commonage Implementation Committee for consideration and recommendation.

I think it is particularly important to point out that the 50% requirement is based on active farmers only, i.e. those actually grazing the commonage. To give an example, if there are 20 shareholders on a commonage, and 15 are claiming shares under the Single Payment Scheme, but only 10 of those are actively grazing the land at present, the 50% requirement to trigger priority access to GLAS is just 5 farmers.


I do not believe that a minimum participation requirement based on this model is insurmountable but where real difficulties are being encountered the farmers concerned can approach the Commonage Implementation Committee for assistance. I have also arranged for a series of public meetings at key locations nationwide so that farmers will have an opportunity for themselves to talk to officials from my Department and raise the issues that continue to give them concern. In the last few weeks, I think we have brought a good deal of clarity to the situation and I believe that there is a lot of common ground between what I have proposed and what hill-farmers themselves would like to see in place for their own commonages.

The key points to note in the Ministers response are:

1) GLAS applications are individual applications. This is a vital step forward as individual  applications lead to individual contracts.  This effectively removes any risk of collective punishment and was one of the hill farmers key demands.  

2) Confirmation that the participation of dormant shareholders is not required.

3) A commitment that even where less than 50% of active farmers in a commonage apply for GLAS that  active farmers are not necessarily excluded from the scheme. While adjudication on individual cases is being left to the Commonage Implementation Committee, it is in no ones interest to exclude active farmers and where valid reasons exist I am confident that GLAS approval will follow.

Concerns have been raised by some in the IFA about the one plan one planner requirement for the Commonage Management Plan, I believe these are unfounded. It is clear that if there are multiple plans in operation, than effectively there is no plan.  Multiple plans for the same commonage is a recipe for chaos and serves no ones interests. It follows that if there is to be one plan there can only be one planner.

My understanding is that the active farmers will select a commonage planner to help prepare their Commonage Management Plan. This choice should not obligate them to select that planner for their individual GLAS applications, although they would be free to do so if they wish. The GLAS plan will refer to the Commonage Management Plan just as REPS plans referred to the old Commonage Framework Plans. There is nothing new in this, except that now instead of having a plan imposed on them, the active farmers will have an opportunity to contribute to the development of a workable plan themselves.

This is new ground for planners as well, I believe it will lead to a degree of specialisation, with some planners choosing to focus on this issue, as we have and others more on filling the need for individual GLAS applications and support. If this leads to the efficient delivery of workable plans it will benefit farmers as well.






Monday, 15 September 2014

Commonage Crisis


The Dept. of Agriculture appear unmoved from their opening position regarding the need for collective agreements as a requirement for joining GLAS.  All concerned should now be aware that we are very close to a point of no return, immediate and meaningful engagement between the farmers and the Dept. of Agriculture must take place in the coming days if we are to avoid doing permanent damage to hill farming.  

It is not ideal, but the work that should have been carried out over the last two years must now be completed in two weeks or less.  If it is not, GLAS risks complete failure in hill areas.
  • For the farmers this could mean a complete loss of agri-environment payments in the current round of the CAP.  If this happens how many will be there for the next CAP?
  • For the state, key objectives of the RDP would be unattainable. The programme could effectively fail before it begins. This is an appalling vista and would have far reaching consequences.
  • For farm advisors in the west, failure will destroy their business model. Investments in increasing capacity to deal with GLAS planning in commonage areas have already been put on hold and many planners, increasingly nervous about the volatility in the sector are already looking for alternatives.
All parties should recognise that while they have their own priorities, their fates are linked. They should appreciate the effect of the current situation on the morale, not just of their own sector but on the other parties as well and the risk of undesired reactions that this creates.

Everyone must accept that there will be no imposed solution, there will be no point where one group can declare victory. If an agreement is not reached that all parties can accept then GLAS will fail and the consequences will impact on everyone.

The situation demands cool heads, an ability to compromise and prompt action. The stakes have never been higher.

Thursday, 4 September 2014

Simple Solution to the 50% agreement problem.

 

It would seem that the main issue dividing the two sides is the issue of the 50%+ of farmers signing up to a commonage plan as prerequisite to joining GLAS. Perhaps the way around this is in the contents of the proposed commonage plan itself. To date the Dept. of Agriculture have not committed to what a commonage plan would look like, it is still a blank canvas and so its design can give both sides room to manoeuvre.

Suggested Commonage Plan.

 Commonage Plan
Year 1 The farmers on this commonage will in conjunction with a specialist planner develop a grazing strategy for the commonage.
Years 2-5 The farmers on this commonage will implement the grazing strategy developed in year 1."

I think this would meet most of the farmers needs and allow the Dept. of Agriculture to proceed with the requirement for a 50% threshold for participation in GLAS. It also allows a year for the grazing strategy to be finalised and avoids the risks associated with a rushed plan prior to GLAS applications.  

Monday, 18 August 2014

Min/ Max Figures for Commonage

A lot of time has passed since the Dept. of Agriculture originally posted the min/ max figures for individual commonages. The figures at the time attracted quite a bit of controversy with many farmers considering them inappropriate to their commonage. The figures have been taken down off the Dept. of Agriculture site since then and seem to have largely faded from the public discussion of the commonage issue. However we have had numerous requests in recent weeks for this information. We will provide it for any commonage on request. Please e mail any requests to yourcommonage@gmail.com


This is important for a number of reasons, the first is that the min/ max figures are  very likely to form part of the Dept. of Agriculture's position on what constitutes the minimum level of grazing required to keep a commonage in GAEC, a necessary requirement for payment under the new Basic Payment Scheme. The min /max figures are also likely to be the default values for any commonage agreement as part of the new GLAS scheme. There are several important factors that commonage farmers should note in respect of these values. These are;


1)  The figures relate to the commonage parcel, not to the individual farmer. Whether the Dept. of Agriculture will use them for calculating the minimum level of use for individual farmers to qualify for the Basic Payment Scheme is still unclear.  However such a scenario is very likely as the Dept. of Agriculture have no real alternative in place.

2) If it is decided to use these figures for calculating the minimum level of use for the Basic Payment   Scheme then how the issue of dormant shareholders is going to be addressed is as yet unknown. If the figures are simply divided among active farmers in accordance with their share of the commonage, then in most commonages the overall minimum figure for the commonage will not be attained. This is an outcome which is unlikely to be acceptable to the EU Commission. If the required stock numbers are apportioned between the active shareholders, i.e. ignoring dormant shares altogether, there is a danger that in some cases the stock numbers required by individual shareholders may be unsupportable taking the farm unit as a whole into consideration. This is not a desirable outcome for either party.

3) It is possible that the Dept of Agriculture will settle on an overall stocking rate for the farm as a qualification mechanism. However this too is fraught with difficulty, on farms with a high proportion of enclosed land to commonage, particularly where this is of relatively good quality it is unlikely that there would be a problem.  However on farms with a very high ratio of commonage land to enclosed land or where the enclosed land is of very poor quality the risk of serious difficulties is very high. The issue here is not the figure chosen, both the 0.05 LU/Ha advocated by the Hill Farmers for Action group and the 0.15 LU/ Ha currently used for the DAS scheme will not be universally applicable, the difficulty rather is with any method which applies a one size fits all approach to all commonages.

What I believe is more likely is that the Dept. of Agriculture will choose a method, probably based on one of the possibilities listed above and then allow deviations from that on individual commonages and for individual farmers on the basis that there is a GLAS contract in place.  This would be similar to the approach taken many times in the past. While such an approach offers a certain amount of flexibility, it does face one huge challenge and that is that is probably already too late in the day to implement.

There is every likelihood that GLAS will not open till January 2015, the application window will only be 4 months at best and this will include the first application period for the Basic Payment Scheme. The time available for planners to produce a scientific assessment of the commonage and develop an agreement that farmers can buy into and produce GLAS applications for individual farmers is very short.  The temptation for many planners to ignore commonage and focus on farmers with enclosed land only is huge. There are three main reasons for this. First most planners are unfamiliar with commonages and the habitats and farming patterns involved. Second preparing GLAS applications for farmers with no commonage is relatively straightforward, particularly when the planner had dealt with those farmers in REPS and was familiar with their farm. Dealing with this group generates an immediate income stream for the planner and will be very tempting.  Finally if there are up to 30,000 places in GLAS in the first year, it is clear that many farmers who do not qualify for priority entry to GLAS have only one chance to get into GLAS and that is in year 1.  These farmers and their planners know this and they will take advantage of the window of opportunity that is presented.  Ironically in all probability large numbers of these farmers will get accepted into GLAS in 2015 while most commonage farmers will not.

What can be done about this at this stage. There are two practical measure that farmers can and should take immediately. These are to assess the appropriateness of the min/ max figures for their commonage and if necessary get a commonage planner to prepare alternatives based on a scientific  assessment of the commonage. We at yourcommonage will assist anyone with this but remember that time is short, once GLAS opens the opportunity to have you commonage re-assessed will effectively  be closed until after the first GLAS application period closes. Secondly farmers and their representatives should lobby for a change to the proposed GLAS measure which demands a final agreement on the commonage prior to applying for GLAS.  Remember that for practical reasons a nutrient management plan does not have to be prepared at the time of application, it can be done after the application is approved but prior to payment. Treating the much more complex of issue of a commonage plan in the same manner is the least that farmers deserve.
 



Wednesday, 30 July 2014

New Commonage Implementation Commitee to meet shortly.



The Minister for Agriculture has announced that the new Commonage Implementation Committee will meet for the first time in the near future.  This is a positive development as it is clear that the Committee has a lot to do and it is important that it begins its work very soon.  In particular they need to manage the introduction of the new max/ min figures.  These figures will require many farmers to adjust their stock numbers.  Farmers must be able to take these into  account when deciding on the number of ewes to be culled and how many hoggets' to be kept.  If the min/ max figures are not published before the Autumn sales, farmers will be forced to make key decision in the dark. This would unnecessarily frustrate the process of increasing flock sizes and would be a bad start to a period of transition.  It is in no ones interest that this should happen.



The full text of the Department of Agricultures Press Release is shown below.



"The Minister for Agriculture, Food and the Marine, Simon Coveney TD, announced today that all members of the new Commonage Implementation Committee have now been appointed and the Committee will announce its first meeting date shortly.

The Committee is chaired by Joe Healy, a livestock farmer from Galway and former President of Macra na Feirme, and former Chairman of Athenry Mart. He will be assisted by two senior Department officials with specific experience in this field and two technical experts, one from the Department of Arts, Heritage and the Gaeltacht and one from Teagasc. Also appointed to the Committee is Andy McGarrigle, former Head of the Department’s SPS Entitlement Division, who retired earlier this year.

The new Committee has two main terms of reference:

• To examine cases where there is disagreement by shareholders over proposed minimum/maximum stocking levels for commonages;

• To assist with instances where difficulties emerge in securing the necessary 50% agreement amongst active shareholders for participation in the new GLAS agri-environmental scheme




Commenting today, Minister Coveney said that his priority had been to get this Committee up-and running without delay. "I am very aware of the concern amongst commonage shareholders about these new proposals and I want to ensure that we iron-out any remaining issues in good time, with an eye to next year’s Single Farm Payment and applications for the new GLAS scheme. I believe this new Committee will play a key role in resolving specific issues at individual commonage level."



Friday, 18 July 2014

Commonage Review and Right of Appeal.

 Commonage Framework Plans


Eamonn O Cuiv TD has asked the Minister for Agriculture in a parliamentary question when will the commonage reviews be completed. The Ministers response suggests that this is imminent and that commonage farmers will soon receive a letter from the Dept. of Agriculture showing the maximum and minimum figures for their commonage.  The Minister has also pointed out that farmers will have the right to submit alternative figures based on an assessment by a professional planner. A transcript of this exchange is shown below.
 
Deputy Éamon Ó Cuív asked the Minister for Agriculture, Food and the Marine When the commonage reviews promised will be completed; the compensation that will be paid to farmers in the meantime for compulsory destocking of livestock from commonages; the reason that arbitrary destocking limits are being imposed on commonages without any up to date evidence of their need; the reason for the delay in publishing up to date commonage framework plans; and if he will make a statement on the matter.


 
 

Wednesday, 9 July 2014

Chairman of Commonage Implementation Committee Appointed.



The Minister for Agriculture, Food and the Marine has appointed Joe Healy as chairman of the Commonage Implementation Committee. This is a positive development and hopefully will lead to progress in developing the commonage management issue for the benefit of all stakeholders.
The full text of the Dept. of Agricultures press release is shown below.
105/14 09 July 2014




COVENEY APPOINTS JOE HEALY AS CHAIRMAN OF
COMMONAGE IMPLEMENTATION COMMITTEE


The Minister for Agriculture Food and the Marine, Simon Coveney TD announced today that he has appointed Mr Joe Healy as Chairman of the newly formed Commonage Implementation Committee. Mr Healy is a livestock farmer from Galway. He is former President of Macra na Feirme and former Chairman of Athenry Mart.

"When I met the farming organisations last week about the Rural Development Programme, I said I would appoint the chairman and get this new Commonage Implementation Committee up and running without delay. I am very pleased that Joe Healy has agreed to act as chairman and I believe he will bring a wealth of experience and energy to this role."

Mr Healy will be assisted on the committee by senior officials from the Department of Agriculture Food and the Marine and two technical experts, one nominated by Teagasc and one nominated by the Department of Arts Heritage and the Gaeltacht.
The Implementation Committee will have a role under pillar 1 in examining cases where there may be disagreement over the allocation of minimum-maximum figures to individual farmers. It will also have a role under pillar 2 where there may be difficulty in getting the minimum 50% of active shareholders signed up to a GLAS Commonage Plan.
ENDS