Minister Coveney to address Oireachtas Commoittee on Agriculture.

The Minister for Agriculture Simon Coveney will address the Oireachtas Committee on the RDP tomorrow at 2 o clock. A significant announcement on the Commonage issue is expected. Full details will be on yourcommonage over the coming days.

GLAS, the New Agri-Environment Scheme

The Minister for Agriculture, Simon Coveney announced the details of the new GLAS scheme last week.  Further information was included in the Rural Development Programme sent to Brussels, (this document has been published on the Dept. of Agricultures Website, a link is provided below).  There are small, but significant changes from the previous proposals and while there is no fine detail on the options within the scheme, the structure appears more workable than that described in previous drafts.

The payment rates for the different components of the scheme are shown in the table below.  While it is not certain, I believe that the rates for Chough, Corncrake, Geese and Swans and Hen Harrier will only be available on lands designated as Special Protection Areas for these species.  Information on these can be found on the NPWS website. As regards the measures for Grey Partridge, this will probably be limited to the Lough Boora area in Co. Offaly, although it is possible that a site in North Co. Dublin may also be included.  The payment rates for Grey Partridge appear confusing as there is no area payment, only a linear one.  This is because that option will require the planting of lines of Kale within tillage fields, the payment of €2.10/ m is per m of Kale planted.  It is potentially a very generous payment for eligible farmers.  The option for Twite will probably also be restricted to a small area, the Mullet peninsula in Co. Mayo is the most likely but small areas in Sligo and Donegal may be considered as well.

 

Annex 2 GLAS Actions Payment Rates

Action                                              € per metre/year   € per ha/year    € per unit/year      € per m3/year

Arable Grass Margins

1. 3 metre margin                                    €0.35

2. 4 metre margin                                    €0.50

3. 6 metre margin                                    €0.70

Bat Boxes                                                                                                    €13

Bird Boxes                                                                                                    €6

Conservation of Solitary Bees

1. Box                                                                                                            €6

2. Sand                                                                                                         €45

Conservation of Farmland Birds

1. Breeding Waders                                                                €366

2. Chough Farm Scheme                                                        €365

3. Corncrake                                                                           €364

4. Geese and Swans                                                                €205

5. Grey Partridge                                    €2.10

6. Hen Harrier                                                                         €370

7. Twite A: Semi Natural/Semi Improved Grassland

Field Management Option                                                      €375

8.Twite B Improved Grassland
Field Management Option                    €1.50

Commonages - Collective Agreement                                   €120

Conservation of Private Natura Sites                                     €79

Coppicing of Hedgerows                      €2.20

Environmental Management of Fallow Land                        €750

Green Cover Establishment from a sown crop                      €155

Laying of Hedgerows                            €3.70

Low Emission Slurry Spreading (per m3 per year)                                                                    €1.20

Low Input Permanent Pasture                                               €314

Minimum Tillage TBC

Native Wild Flower Margin                  €1.40

Planting New Hedgerows TBC

Protection of Archaeological Sites

1. Tillage Option                                                                                         €146

b. Grassland Option                                                                                    €120

Protection of Water

Courses from Bovines                          €1.50

Rare Breeds (per L.U)                                                                                 €200

Riparian Margins

1. 3 metre margin                                 €0.90

2. 6 metre margin                                 €1.20

3. 10 metre margin                               €1.60

4. 30 metre margin                               €3.60

Small Woodland Establishment                                                               €0.90

Traditional Stone Wall Maintenance                                                       €0.70

Traditional Hay Meadow                                                      €315

Traditional Orchards                                                                                €23.50

Wild Bird Cover                                                                    €900

Commonage Issues

As regards Commonage, the situation is clearer than it had been.  Thankfully the Dept. of Agriculture have removed the 80% agreement requirement.  It has been replaced by a requirement for agreement from a simple majority of either active shareholders or from a group of shareholders holding more than 50% of the land.  This is a huge improvement and while there may still be local difficulties it is to be hoped that the soon to be established Implementation Committee will be able to recommend derogations where particular problems prove intractable.  The increase in payment for commonage from €75 to €120 per Hectare is also to be welcomed.
 

We can expect negotiations between the Dept. of Agriculture and the EU Commission to take a number of months.  During that period, work on developing the specifications for the scheme will proceed.  The specifications and the terms and conditions will contain the small print and fine details of how the scheme will operate, they may prove to be of greater significance to farmers than the broad brush strokes of the RDP application.
 

As regards commonage and GLAS we now know the payment rates, we know the minimum threshold for agreement among shareholders and we know that there can be only one GLAS planner for a commonage.   The issues that are not so clear include the following;

• Having one GLAS planner for a commonage makes sense, as it is obvious that there can only be one grazing plan for the commonage.  However the implications of this at farm level could be problematic. Do the Dept of Agriculture want one planner to write a commonage plan and go on to produce the GLAS applications for all the individual farmers or will that commonage plan be made available to other planners who then incorporate it into individual GLAS applications?

• When will the process of producing commonage plans commence?

• Will commonage plans have to be complete before individual farmers apply for GLAS or can they be incorporated later?

• Will the Dept. of Agriculture permit commonage plans or GLAS applications to be amended later in the contract period?

These are serious issues, the Dept. of Agriculture's collective approach to commonage management is a radical change and its successful implementation demands time and flexibility if it is to be successful. Insisting on one planner producing the individual GLAS applications is a risky step, the choice of planner is potentially a cause of disagreement at a very early stage in the process.  However it is also a strategy that will come under huge pressure in the case of farmers who have shares in multiple commonages.  For example, a client of ours has shares in eight different commonages, any requirement to have all the farmers (who wish to join GLAS) in all eight of those commonages to pick the same planner is unlikely to succeed and would most likely exclude this farmer from the scheme.  His absence would then threaten the prospects of the farmers in all eight commonages reaching the 50% threshold.  This is a senseless and pointless risk for all concerned, yes one planner should produce the grazing plan and facilitate agreements among shareholders, but individual farmers should then be free to choose their own planner to produce a GLAS application for their farm, an application which would of course incorporate the commonage plan.

As regards when the work on producing grazing plans should commence, everyone should appreciate that this will be a huge undertaking, involving possibly up to 4,500 commonage parcels and 7-8,000 farmers.   The Dept. of Agricultures target is to get approx. 150,000 Ha of commonage under GLAS contracts, this is very ambitious and will not happen overnight.  It is a huge task and it will take a considerable amount of time.  Remember the Commonage Framework Plans took over 6 years to produce and the planners in that process did not have the added challenge of trying to achieve agreement among farmers to contend with.

The process should not be rushed, but the time has come to tell stakeholders, what the Dept. of Agriculture expect from a collective agreement.   Decisions on how much time will be available to produce such plans and on how advisors will be trained to do this work are required as a matter of urgency.  These should be among the first items on the implementation Committee's agenda.  There is a considerable risk that training advisors will be left until the RDP comes into force in January 2015, i.e. when funding for CPD (Continuous Professional Development) come on line.  This would be a disastrous development for commonage farmers, as by then advisors will be fully focussed on producing GLAS applications (albeit for non-commonage clients).  The result would be a poor uptake by advisors and very poor entry rates into the scheme by commonage farmers in 2015.

Time constraints also demand that the period for completing commonage plans and getting agreement on same be extended beyond the closing date for applications.  As a minimum the issue must be treated in a similar manner to the Nutrient Management Plans, i.e. let a farmer join the scheme subject to the completion of the commonage plan and agreement on same before the first payment issues.  The issue of flexibility is also very important, the inability to amend AEOS applications was a major failing in that scheme.  It must not be repeated in GLAS. In commonage situations, no agreement can be considered as being permanent, changes in the circumstances of individual farmers will affect the operation of the agreements.  To be of value the agreements must be flexible enough to cope with these changes.  In particular farmers must be free to amend their agreement to deal with;

• Accession or withdrawal of participating farmers.

• Changes on individual farms necessitated by change of ownership, poor health, changing farm enterprises.

• To correct for negative but unforeseen impacts of aspects of the original agreement.

While facilitating amendments may make the management of the scheme more complex for the Dept. of Agriculture, a failure to allow for this will lead to the progressive unwinding of agreements and will undermine and discredit the scheme itself.

A lot of progress has been made and both sides of the debate are to be congratulated on getting us to this point. But time is short and any loss of momentum will have consequences for commonage farmers getting into GLAS in 2015.  The Commonage Implementation Committee must be put in place and must go to work immediately.  Training of planners on the production of commonage plans and an information campaign for farmers should commence as soon as is practical.  There is much to do and there still is time, if it is not wasted.


http://www.agriculture.gov.ie/media/migration/ruralenvironment/ruraldevelopment/ruraldevelopmentprogramme2014-2020/RDPFinaldraft03072014.pdf

Submission on the SEA of the Rural Develpment Programme.

Fergal Monaghan of YourCommonage along with James Moran (Sligo IT), Brendan Dunford (BurrenLIFE), Patrick McGurn (AranLIFE) and Michael Martyn (Martyn Agri-Environmental Consultants) made a submission on the Strategic Environmental Assessment of the proposed RDP application. In respect of commonages we proposed that commonage associations if the farmers wished to set up one should be eligible to apply for a GLAS payment in its own right. Such a payment would be in addition to the payments made to the farmers through their individual GLAS contracts and would cover measures that can only be delivered by the group, e.g. production of a sustainable management plan, control of Molinia, fencing etc. This approach would not be compulsory but should be available as an option to farmers in all commonages. We believe that it would offer all stakeholders in the process a mechanism for delivering good commonage governance. Just as importantly it would offer all sides a way out of their current entrenched positions and deliver a workable solution for Commonages with the GLAS scheme. An extract of the portion of the submission relating to commonages is shown below.

 

In the case of commonage land:

- for actions which are wholly under the control of an individual shareholder (individual stocking numbers, stock type, shepherding practices) the eligible applicant is the individual shareholder farmer through the farm application

- for any other actions the only eligible applicant is a graziers association duly constituted as a legal person and allocated a business reference number (equivalent to herd number for individual applicants). A graziers association is eligible for the full allowance of GLAS funding in its own right.

Since any application on commonage has to be underpinned by a single habitat/species assessment and commonage management plan, irrespective of whether collective measures are subsequently proposed, it will in practice be necessary for potential participants to come together to commission such an assessment and plan. It is also the case that time will not allow the completion of the management plan before the closing of the first application window. To recognise these practical issues, it will therefore be a requirement that all such applicants sign a joint declaration of intent before application, certifying that:

 

• they will apply to GLAS in relation to the commonage in the first year
• they will ensure that the overall stocking on the commonage falls within the draft max/min range for the duration of that first year
• they will have a management plan prepared and a 5 year collective agreement between themselves based on that plan drawn up before the first anniversary of the date on their AE contracts.
• each individual GLAS application will refer to the obligations set out for that shareholder or association in the collective agreement
• they will subsequently implement that agreement for the remaining 4 years, with a full review after 2 years (and annually if necessary).

We are not convinced of the need to apply fixed rules regarding the proportion of shareholders and/or of those claiming commonage forage on their SAF and/or of active graziers who need to participate in the agreement or to undertake positive management eligible for payment under this scheme. Practical questions are likely to make agreements which involve only a small proportion of active graziers or active direct payments. However, should the Department deem such thresholds to be necessary, they should be of direct payments claimants in the previous year, not of all

shareholders. A list of commonages with the number of shareholders claiming forage on each should be made available each year as soon as all SAF submissions have been processed.

 

Proposed commonage application process, step by step Before AE application Farmers individually decide they interested and one of them takes the initiative to call a meeting of shareholders Meeting, ideally attended by an advisor/Commons Development Officer to ensure full understanding of scheme in detail, its process and potential pitfalls, decides to try to secure the agreed (specified?) % of SPS-claiming shareholders (based on latest year’s claims data) signing up to declaration of intent Someone (farmer ideally, but possibly a planner) undertakes the job of getting active and claiming shareholders signed up to a declaration of intent (see above) Each farmer can then apply for AE, with the conditions being as per the declaration of intent. First year after AE application A habitat assessment and draft management plan will be drawn up by a registered planner – who may or may not subsequently prepare some or all of the GLAS applications. To recognise the extra transaction costs of drawing up and implementing such an agreement on commonage, management payment rates for commonage will be 30% higher than those for other rough grazings (Art. 28.6). Shareholders can avail themselves of the services of a Commons Development Officer to translate the habitat/species assessment and draft management plan into a workable internal agreement between the participating shareholders. Any management options which are not fully under the control of the individual applicant, can only be applied for by a properly constituted graziers’ association, which would then also be a signatory to the internal agreement along with the individual participating farmers. Once again, payments would include a 30% collaboration transaction cost top-up compared to sole occupancy farms (Art. 28.6). Free facilitation support would be available for forming this association, as would be a modest 50% grant for legal costs to draw up the necessary articles of association (Art. 35). The association must be open to any shareholder who is active and/or claiming BPS/ANC payments on the commonage. Where no such actions are deemed necessary, the lack of an association would not preclude the drawing up of an agreement and to the inclusion of commonage options in individual GLAS applications Linking to output-related locally targeted measures Any locally-targeted, output-related scheme for commonage would only be open to graziers’ associations.

Note: The declaration of intent is a mechanism to replace the 50/ 80% rule proposed by the Dept of Agriculture. The 50/ 80% rule does not offer an adequate mechanism for progress towards achieving good commonage governance. Among other things it does not have the flexibility to allow the time required to develop a sustainable management plan and an agreement based on that plan in advance of the submission of GLAS applications. These are fundamental issues that demand adequate time for consideration and delivery. By using a declaration of Intent, the farmers are not signing upto an agreement at the time of applying for GLAS, rather they are declaring that they will work towards developing an agreement between themselves during the course of their first year in GLAS. This treats the Commonage Governance issue in a manner similar to that proposed for the Nutrient Management component of GLAS applications.. It should allow for commonage agreements to be developed in an orderly manner that can win the support of a majority of active farmers.