Applications for GLAS by Commonage Farmers

In response to a Parliamentary Question asked by Eamon O Cuiv T.D. the Minister for Agriculture has provided information on the number of commonage farmers in each county and on how many of these have initiated GLAS application. The data makes for interesting reading, particularly when combined with the information on applications for the GLAS Commonage Advisory role. The data below was provided by the Minister on April 23rd.

I would not pay too much attention to the information on the number of GLAS applications with actions. This does not of itself indicate that these cases will progress to a full application to the scheme. What is clear is that in the minor commonage counties the performance is very poor. No applications at all in Meath, only 4 in Kildare and 3 in Kilkenny.

In the main commonage counties, the level of interest hovers between 10 & 30% which is reasonable in the circumstances. Of greater concern is the very slow rate of applications for the commonage advisor roles. Without an advisor there will be no commonage management plan and the glas applications will fail.

The number of advisors who have expressed an interest cannot hope to deal with more than 5% of commonages in the time available. This is where the real bottleneck that threatens the schemes rollout lies. It must be addressed and soon.

The breakdown of these applications within individual commonages is not available but we can expect them to fall into 3 main categories.

First, commonages with no interest at all. Secondly commonages where 1 or 2 individuals have applied and where no application has been made for the commonage advisor role and finally those with a good level of interest and where an advisor has or is in the process of applying for the commonage advisor role. The group of greatest concern are those where GLAS applications have been made by a small number of shareholders but where no commonage advisor has undertaken to prepare the plan. There is a very real danger that these farmers could face considerable difficulties. While the Dept. have said that they will be accommodated, it remains to be seen how this will be done.

What is certain though is that the July 3rd closing date for the completion of commonage management plans is not attainable and must be pushed back. The pressure to push the BPS closing date back makes the pushing back of the CMP date all the more urgent.

County	Number of GLAS applications initiate which have Commonage	Number of GLAS applications with actions and have Commonage	National number of farmers with Commonage
Carlow	42	29	172
Cavan	17	12	133
Clare	78	44	376
Cork	196	106	974
Donegal	568	416	2700
Dublin	11	2	44
Galway	414	276	2668
Kerry	417	294	1921
Kildare	4	4	62
Kilkenny	3	1	35
Laois	13	11	108
Leitrim	96	69	472
Limerick	11	5	57
Longford	8	5	58
Louth	18	10	165
Mayo	727	510	3273
Meath	0	0	12
Monaghan	0	0	3
Offaly	5	3	41
Roscommon	28	13	160
Sligo	94	61	491
Tipperary	56	23	322
Waterford	52	11	179
Westmeath	2	1	26
Wexford	17	8	105
Wicklow	47	31	319
TOTAL	2924	1945	14876

Clarity on the Land Eligibility Issue.

Over the last year there has been huge concern over the issue of eligibility of land as forage area. This is a critical point as a determination that land is ineligible not only leads to a reduced payment but can potentially lead to large penalties for over claiming.

Many commentators have advocated that the Dept. of Agriculture should make use of the provision referred to as article 4(h) within the EU regulations. This provision allows for payment on lands where heather and shrubs are predominant provided that they are grazed in accordance with established local practices. The Dept. of Agriculture position on this has been unclear until now.

The current position was outlined last week by the Minister for Agriculture in a reply to a parliamentary question from Eamon O Cuiv T.D.. In his reply the Minister has confirmed that areas containing Heather and scrub may be eligible for payment if there is evidence of agricultural activity.

This is a very important concession; it does not however mean that evidence of activity within a parcel means that the entire parcel is eligible. A common feature of many land parcels, particularly so on larger plots and on commonages is the uneven distribution of grazing pressure. Animals often preferentially graze on sweeter grass and avoid areas where the vegetation is less palatable. This pattern may be subject to change through the course of the year as stock change from one favored forage plant to another. Managing stock behavior to encourage grazing in under utilised parts of the site is a key step to ensuring continuing eligibility. 

Tirglas Advisors can give you practical advice on how this can be done in an effective and workable manner and help secure payments on as much of the parcel as possible. This is an issue that goes way beyond GLAS, The GLAS scheme is however a potentially useful mechanism to deliver the improvements that secure payments across all schemes.

 The full text of Eamon O Cuiv’s question and the reply from Minister Coveney follows.

Deputy Éamon Ó Cuív asked the Minister for Agriculture, Food and the Marine:

 "If the definition of permanent grassland for the purposes of the implementation of the basic payment schemes and greening schemes here include permanent pasture and shrubs and-or trees which can be grazed including established scrub and heather - Calluna vulgaris - in all stages of its life cycle and also land which can be grazed and which forms part of local practices where grasses and other herbaceous forage are traditionally not predominant in grazing areas, as set out in article 4 (h) of the direct payment regulations 1307/2014; and if he will make a statement on the matter".

Minister for Agriculture, Food and the Marine (Deputy Simon Coveney):
"The provision referred to under article 4 (h) of Regulation 1307/2014 for permanent grassland is 'land used to grow grasses and other herbaceous forage … it may include other species such as shrubs and or/trees which can be grazed provided the grasses remain predominant as well as where member starts so decide land which can be grazed and which forms part of local practices where grasses and other herbaceous forage are traditionally not predominant in grazing areas'.

In relation to the Basic Payment Scheme, the requirement is that each agricultural parcel declared by an applicant under this Scheme must have a farming activity on it to be eligible for payment. Such an activity, which must be appropriate to the type of land involved and which should ensure that the area currently eligible for payment remains in this state, includes grazing the land.

The areas as described, excluding established scrub and ungrazed heather will, in general terms, be eligible under the Basic Payment Scheme provided there is evidence of an agricultural activity being carried out".

Commonage Restrictions in the Twelve Bens/ Maamturks

Commonage Framework Plans

Deputy Éamon Ó Cuív asked the Minister for Agriculture, Food and the Marine if a person in County Galway who is participating in the Twelve Bins/Maam Turk Complex can amend their agri-environment option scheme plan to allow them to put their sheep back on the hill due to the fact that the Twelve Bins/Maam Turk Complex scheme is not being renewed after November; and if he will make a statement on the matter.

Minister for Agriculture, Food and the Marine (Deputy Simon Coveney): I am aware that the Twelve Bins/Maam Turk Complex Scheme, which the National Parks and Wildlife Service put in place for the purpose of regenerating these commonages, expires on 1st November, 2013. The future management of these commonage lands will now be considered in the wider context of the ongoing examination of issues relating to all Commonages. This process will involve the farmers directly managing the lands, relevant stakeholders, the farming organisations and all other interested stakeholders. The aim is to achieve a practical solution which will ensure that the farmers actively farming these lands are protected and that the land is maintained or returned to GAEC and that the requirements of the governing EU regulations are met.

There is nothing new in the Ministers reply to Deputy O Cuiv, this has been the standard line for almost a year now. However there is still no sign of any sort of an implementation plan and the mechanisms to attain the goal of keeping commonages in GAEC are still very unclear. The min/ max figures which the Department believed would deliver a solution are at best only a starting point for an implementation plan for each individual commonage. The other aspects of an implementation plan have never been published, without them the Departments commonage management plans are in disarray.

We can only hope that the draft Rural Development Plan which is expected before the end of the year will shed some light on the Department of Agriculture's intentions.