Interim Commonage Management Plans

Commonage farmers who joined either GLAS 1 or GLAS 2 made a commitment to participate in a commonage management plan. As part of their GLAS contract these farmers are required to have reached their minimum stocking level by the end of 2016. To do this, it is obvious that these farmers must know what the minimum stock requirement is. To achieve this and to facilitate the release of the the GLAS payment for 2016 the commonage advisor must prepare and submit an Interim Commonage Management Plan. 

This plan will set out the minimum stock numbers that must be held by each GLAS participant by the end of 2016. The other issues relating to maximum stock numbers and management issues such as burning, dumping, seasonal patterns of grazing, invasive species and supplementary feeding will be decided by the full set of GLAS participants (including GLAS 3 applicants) in 2017. 

The interim plan must be signed by each GLAS participant and submitted by the end of October 2016. If this is done the GLAS payment for 2016 will follow within 4- 6 weeks. If the form is not submitted no GLAS payments will issue to any of the participants. If an individual farmer fails to sign the form then no payment will be made to that farmer in 2016.

Due to the very short period of time available, this is going to be very difficult for advisors to manage. The closing date is only 13 days away, it is impossible for us or for  most other advisors to visit each farmer individually to get the interim plan signed. For this reason we are inviting farmers to come into the office to sign up to their plan. The office will be open until 8:00 pm each evening from tomorrow Wednesday October 19th until Thursday October 28th. The office will be closed on Monday October 24th to allow us to hold a clinic in Peacockes Hotel in Maam Cross.

Fergal Monaghan and Thady O Brien will be in Peacockes from 11:00 am until 9:00 pm. Unfortunately due to time constraints if you are unable to attend in Peacockes then you will have to come into Claregalway. Whether you meet us in Maam or at our offices please try to come in early in the day as we anticipate significant queues in the evenings. Payment for the Commonage Management Plan is now due. The amount outstanding must be settled before the interim plan can be signed. 

P.S. There is no need to book an appointment nor do you need to bring anything with you.

The link below will allow you to see a copy of the letter sent by the Dept. of Agriculture to individual advisors informing them of what is now required. 

https://drive.google.com/file/d/0B1U6Mi7IC789emg5RkVHVVFkS2c/view?usp=sharing

Commonages, SAC's, Farming, GLAS and the Election. Who deserves your vote ?

Tip O Neill famously said that all politics is local.  However in the debate on the commonage issue, a number of T.D’s have engaged on a level that far exceeded their own local constituency concerns.

Over the life of the last Dail, the commonage issue came to prominence on a number of occasions. The first was in 2012, the last tranche of applications were being made to the AEOS scheme and the Dept. of Agriculture had just published a desk study of minimum and maximum stocking levels for each commonage.  The inconsistencies and errors, both in the figures and in the manner proposed for their implementation provoked a storm of protest. This led directly to the Oireachtas Agriculture Committee’s decision in 2013 to consider the issue in detail and to consult with a range of stakeholders. Their report was balanced and fair and while not a solution to the current problems, it certainly demonstrated that some politicians at least were ready and willing to engage with the topic and focused on developing a long term solution. Andrew Doyle (Fine Gael, Wicklow) and Eamonn O Cuiv (Fianna Fail, Galway West) deserve particular credit in this regard.

In the summer of 2014, the Dept. of Agriculture’s vision for the treatment of commonages in GLAS became apparent. The proposals revolved around 80% plus participation in a collective agreement prior to joining the scheme, the use of the previously published min/ max figures and joint responsibility for non compliance. These proposals were a cause of great concern and thousands of hill farmers attended mass meetings in Westport, Maam Cross and in Donegal. Many felt that these proposals were being presented to farmers as a fait accompli and that farmers concerns were being ignored. A rolling picket by hill farmers at the Taoiseach’s Constituency Office followed. The deadlock was only broken when Minister Coveney agreed that the Commonage Implementation Committee should meet with a delegation representing  the hill farmers. The lead up to this was brokered by a third party but the key political intermediary was Sean Kyne (Fine Gael, Galway West). The time for a solution was already very short, without his intervention it would have been shorter still.

While there were setbacks after this, engagement with farmers and advisors continued. The proposals for commonages in GLAS were steadily modified; the 80% agreement was reduced to 50% and later abolished. The Commonage Management Plans were to be based on the actual condition of the site and the min/ max figures were reduced to the status of guidelines only. GLAS applications were permitted in advance of agreement on a Commonage plan, the proposal for joint responsibility for non-compliance related to stocking levels was withdrawn and the time for developing plans was extended until autumn 2016. The scheme we have today is by no means perfect but is it far better than what was proposed in the summer of 2014. The meeting between the CIC and the hill farmers and the talks that led to that meeting were the turning point in this process.

Throughout the last Dail, a number of T.D.’s made use of Parliamentary Questions to get clarifications on policy developments from the Minister. Indeed for a period this was the main source of information for all stakeholders. The list of T.D.’s who did this includes, in no particular order Pearse Doherty (Sinn Fein), Brendan Griffin (Fine Gael), Dara Calleary (Fianna Fail), Tony McLoughlin (Fine Gael), Joe McHugh (Fine Gael), Martin Ferris (Sinn Fein), Michael Healy Rae (Independent), and Michael Fitzmaurice (Independent). Although once again Eamonn O Cuiv and Sean Kyne deserve special mention.  

Should all of this influence a commonage farmers vote on Friday?

The decision on who to vote for obviously includes a lot more than just a candidate’s record on agriculture. But that said, if commonage farmers want agricultural policy to develop in a manner that recognizes their unique contribution, they must have friendly voices in the Dail chamber and next Friday is their chance to achieve this. Hopefully some of those who have demonstrated the greatest interest will be in positions of influence in the next Dail. Having a person with a real understanding of the subject as Minister for Agriculture, as a Minister of State, on the Oireachtas Agriculture Committee or as an Opposition spokesperson would be a real help. Needless to say, the essential first step is to get them elected.

The next Government, (if it serves its full term) will have to deal with the mid- term review of the Common Agricultural Policy and crucially with the formulation of the next Rural Development Programme (2021- 2027). It will preside over the implementation of the current RDP and the design of the next one. The election of T.D.'s with a proven interest in the management of commonages and designated land will really matter. Although what has happened over the last 5 years is important, what is really crucial is the direction that the incoming Government will take on these issues in the years to come. If we want real progress, we have to give politicians with an understanding of farming on commonages and on marginal and designated lands a strong mandate. Only you can do that.    

Going back to Tip O Neill, all politics is local and in our system, the margin between success and failure at the polls can be very narrow. Every vote does count, have your say on Friday or someone else will speak for you.  

Don't Forget Your Sheep Census Return

The Sheep census return must submitted to the Dept. of Agriculture by January 29th. If you are registered with Agfood you can make the return on line or alternatively your farm advisor can do this for you. The census is a record of the number of sheep and goats on the farm on the 13th of December. If it is not submitted it may create difficulties later in the year in establishing your eligibility for the ANC scheme. You should also not e that making the census return is a GLAS requirement for sheep farmers with commonage.

Commonage Management Planning- Update

The Dept of Agriculture have appointed advisors to 2238 commonages.  These people are now in the process of developing management plans for their respective commonages.  These plans will be evidence based and specific to the particular commonage.  In many cases advisors will have already walked the commonage, in the majority this work will have to be carried out over the next 7 or 8 months. The actual preparation and submission of a plan will be done using an on line system. The software for this has not yet been made available to advisors. For this reason no plans have prepared to date.

The closing date has been pushed back until well into 2016, while no date has been published yet, it is expected that this will be in August or September. While this may seem a long way off an enormous amount of work has to be done in the interim. Not only does a plan have to be developed for the 2238 commonages referred to above, further commonages will be added to the list as new farmers apply for GLAS 3. The completion of these plans will be a mammoth undertaking and advisors and farmers will need every day to get the task completed.

What does a farmer have to do now? Farmers should ensure that they are involved in the process that they engage with the commonage advisor and make sure that he or she is aware of current practices on the hill and any constraints that they as farmers may be operating under. In particular farmers should ensure that the minimum eligible area is appropriate and that if the advisor proposes a reduction that you understand the reason for it. The stock numbers are a vital component of the plan, you should ask to see the evidence justifying the advisors recommendation, do not be fobbed off with any suggestion that these are the Dept. of Agricultures figures, they may be but they still have to justifiable based on the evidence collected on the ground. Above all make sure that the fieldwork has actually been carried out. While this may seem a strange piece of advice, everyone should be aware that there is a very real risk that some advisors may be tempted to omit this vital task and rely on the Dept. of Agricultures figures alone.  Do not let this happen to you, the advisor is working on your behalf, he should have no difficulty explaining to you the basis for the recommendations that he is proposing.

Approval of Commonage Advisors

The Dept. of Agriculture have restarted the process of formally approving commonage advisors. A large number of such approvals issued by post to advisors yesterday. Our estimate is that 50-60% of applications have now been dealt with. We expect the remainder to issue in the very near future. 

Letters to the farmers in each commonage, formally notifying them of the relevant approved advisor can be expected in the coming days. It is important for farmers to note that they must sign a Commonage Authorisation Form for the approved advisor, this applies even if they had previously signed one for someone else. This is required to allow the advisor to access relevant information about the farmers stocking rates and sheep numbers, information that he or she will need to complete the Commonage Management Plan. 

This is a big step forward and along with the guidelines issued earlier in the week will now allow the production of Commonage Management Plans to begin in earnest. 

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

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.

Application rate for approval as commonage advisors is very slow.

As of today, April 25th there are only 101 Applications pending for the Commonage Advisor role. This must be a big concern for the Dept. of Agriculture and for the 2,500- 3,000 commonage farmers who have applied for GLAS. If the GLAS Commonage Management Plan is not submitted by July 3rd, then the GLAS applications made by the farmers involved will fail. To remedy the situation, action from all parties is required now. The Dept. of Agriculture must push out the closing date for Commonage Management Plans considerably. But advisors and farmers too, must look carefully at their own position and act immediately on those aspects of the process that they are in a position to influence.  

To fully appreciate what is going on it might be useful to look at the pattern of applications to date by county and by advisor. Geographically 42 applications have been made for commonages in Co. Galway, 33 in Mayo and only 26 in the rest of the country. No applications at all have been made for commonages in Sligo, Tipperary, Waterford and Cork all big commonage counties. Only 2 in Wicklow (both by yourcommonage) and just 4 in Kerry. In total applications for the advisor role have been made for commonages in just 7 out of the 25 commonage counties (Monaghan has virtually no commonage).

As regards the planners involved, Yourcommonage.ie planners account for 31 out of the 101 on the list. Michael Martyn has applied for a further 25 and Brian Dolan from Donegal and John Staunton from Letterfrack another 12 each. These 4 planning agencies between them have made 80 out of the 101 applications. Another 9 planners account for the remaining 21 commonages. While I am certain that other planners are working on applications and that the number of planners in the process will grow, it will not grow dramatically. Commonage work is demanding and requires a level of understanding of the dynamics of upland farming, that can only come from experience, as a result the pool of potential planners is inevitably quite small.   Most of the people with the level of interest and experience required have probably already applied for approvals and are on the applications pending list.  It is no accident that the two largest agencies in terms of applications, that is Yourcommonage.ie and Michael Martyn have been involved with commonage framework planning, commonage monitoring, farm advisory work, policy development and research for nearly 20 years. These people have made a personal investment in the issue and have the commitment to make it work for the farmers.

The implications of this for farmers are dramatic; no commonage advisor by May 22nd or no commonage plan by July 3rd and they will not get into GLAS. To prevent this happening, advisors, especially those who do not wish to get involved in commonage work should put their own commercial rivalries to one side and facilitate the appointment of a commonage advisor. If they do not they are letting their own clients down and in the long run undermining their own position. Farmers too must take more responsibility for engaging a commonage advisor, sure it is a big decision and ideally they would have more time to consider it, but the reality is that if they do not make that call well before May 22nd their GLAS applications will fail and the planning fees that they have already paid out will be for nothing. If their GLAS advisor has not or will not apply for the role they must take the initiative and ask someone who will. In my assessment the planners who have already stepped up to the plate are the ones with the interest and drive to make this process work. If you need a commonage advisor, the current applications pending list published by the Dept. of Agriculture is the place to look.

The current list of applications pending can be seen by following the link below.

http://www.agriculture.gov.ie/media/migration/farmingschemesandpayments/glas/AppointmentsPendingCommonageAdvisors220415.xlsx

GLAS Teething Problems

Teething problems for the GLAS application process have become apparent in recent days. Of particular concern is the reduced period for the completion of the Commonage Management Plans. The current position is that these have to be in place by July 3rd. What happens if this does not happen is not yet clear but I presume that the individual applications from the farmers affected would fail. While these people will be accommodated in the second tranche of applications, their payments will inevitably be delayed. 

On private land many commentators have identified the issues regarding claiming payments for linear features like stonewalls on divided land parcels. This is completely illogical but an equally serious issue is the suggestion that not to allow payment under the Low Input Permanent Pasture option on land that contains any heather. This will have serious consequences for farmers with privately owned upland grassland plots. Interestingly this ban on heather within LIPP parcels is not in either the scheme specifications or in the terms and conditions documents, rather it is in the answers to commonly asked questions published on the Dept. of Agriculture's website. perhaps there is still potential for movement on this. Farmers and Planners alike should keep the pressure up on the Dept to correct this blatantly unfair anomaly. 

On a practical level, the operation of the on line mapping system used for preparing GLAS applications is quite slow, particularly for linear features such as stonewalls. While our broadband is quite good, I fear that advisors in areas where the broadband access is poor will be in for an infuriating procedure. Watch out for your advisor going bald or grey over the next few months.

For farmers intending to apply for the scheme, get in touch with an advisor as soon as you can. Do not expect that you will be able to get an application prepared in the last weeks of April, it will not happen. The commonage planning process will not begin until mid May but farmers should begin planning for it now. In particular, if it is at all feasible discuss the issue of the choice of commonage planner with other shareholders. The ideal solution here is that you get an advisor of your choice. While the Dept. of Agriculture will appoint some one if agreement among shareholders is not possible, this is very much a sub optimal outcome. Decide on someone and approach them now to check their availability, you may well find that as time passes the ability of advisors to commit to a commonage plan may diminish. 

In spite of the difficulties, remember that GLAS does present significant opportunities not only in terms of payments but also as a mechanism to address management issues and to help safeguard payments from the Basic Payment Scheme and the Areas facing Natural Constraints Scheme. Most of all keep the faith. 

Sheep Census

The Dept. of Agriculture have announced the date for 2014 Sheep Census. Full details are given below. 

SHEEP & GOAT CENSUS 2014 Over 43,000 flock owners, registered as keepers of sheep and goats on the Department of Agriculture, Food & Marine’s database, will this week receive the Sheep and Goat Census 2014. Completing and returning the census is a legal obligation. 

As well as fulfilling this requirement, the yearly sheep and goat census is the record retained by the Department of Agriculture, Food and the Marine, as to the number of sheep on each holding. This information forms the basis of quantifying sheep numbers in the country on a particular date. More importantly, for flock owners, it is also central in declaring that required stocking rates have been maintained and facilitates the drawing down of payments under schemes such as the Single Payment Scheme, Disadvantaged Area Scheme, REPS, AEOS and the Grassland Sheep Scheme. 

The information is also used during farm/flock inspections. The inspector will have details of the census returns submitted for the holding in the last four or five years and will use this information as the basis for identifying if the animal records have been adequately maintained. This year the Department has selected Sunday 14 December 2014 as the census date. 

The onus remains with the flock owner to make sure that the completed census forms reach the Department on time. It should be noted that the only acceptable proof of postage is Registered or Express post receipts and all forms must be returned to Government Buildings, Portlaoise, Co Laois. A postal certificate is no longer acceptable as proof of postage. Flock owners are also advised of the option to submit forms online.

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.

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.  

GLAS and Commonage Management, Latest Developments.

The last round of consultation for the new RDP has closed and we expect the Dept. of Agriculture, Food and the Marine to make their application to Brussels by the end of the month. I hope that the details of the application will be published as soon as possible after they have been sent to the EU Commission.

As regards GLAS, I do not expect there will be significant changes from the structure proposed by the Dept. What we can hope for it that the process of filling in the information gaps that have contributed to the unease felt by many will pick up speed. However one key issue has been clarified in recent days, this is the method for calculating the qualified majority required for priority entry to the scheme. Minister Coveney has confirmed that the 50/ 80% required will be from the set of farmers currently declaring a share on the commonage and not from the total set of shareholders. This is an important development as a requirement for majority support of total shareholders would in many cases have been absolutely impossible. It is unfortunate that this issue was not dealt with many months ago as it could have eased some of the concerns of many commonage shareholders.

Commonage Negotiations.

In response to a question from Sean Kyne TD the Minister for Agriculture descried the progress to date on negotiations between the farm organisations, his Department and the NPWS. This is a welcome development and it is to be hoped that an agreement can be reached in time to allow commonage farmers to enter GLAS in the Autumn. The full test of the exchange between Sean Kyne TD and the Minister is shown below.

Deputy Seán Kyne asked the Minister for Agriculture, Food and the Marine Information on Simon Coveney Zoom on Simon Coveney the negotiations that have taken place between his Department and the Department of Arts, Heritage and the Gaeltacht regarding the implementation of the commonage review; if liaison committees are proposed for the shareholders of each commonage in conjunction with his Department, the National Parks and Wildlife Service and farm organisations; the timescale for the implementation; if he acknowledges that every commonage requires a different plan; and if he will make a statement on the matter. [13946/14]

Deputy Seán Kyne: Will the Minister outline the negotiations that have taken place between his Department and the Department of Arts, Heritage and the Gaeltacht on the implementation of the commonage review? Have liaison committees been set up for discussions between the shareholders in each commonage in conjunction with his Department, the National Parks and Wildlife Service and farm organisations?

Deputy Simon Coveney: This is an ongoing process about which I spoken to the Deputy on several occasions. This is a sensitive issue as there are thousands of commonages across the country. We have a new commonage framework programme that needs to be implemented in partnership with the farmers in question and the National Parks and Wildlife Service which has a role to ensure commonages are farmed appropriately. If they are overgrazed, stocking rates should be reduced, while if they are undergrazed, which is the case in respect of much commonage land, stocking rates need to be increased. The complication arises if multiple farmers are farming the same commonage as one then has to get agreement from a majority of them. If necessary, we will go commonage by commonage and sit down at local meetings to bring people on board with the scheme. Farmers will not receive an instruction on the programme from me by letter and it will not be introduced by enforcement. We have had 18 months of discussions to see how best we can do this with farming organisations and the Department of Arts, Heritage and the Gaeltacht to introduce the programme in as sensible and practical as a way to get the right result both for farmers and the environment. The Deputy will see a partnership between farming organisations and my Department to get it right.

Deputy Seán Kyne: When will the liaison with farmers start? There is concern among the farmers in question in advance of next year about the GLAS, green low-carbon agri-environment scheme, and stocking rates. I appreciate the Minister's letter last week to allow farmers to qualify for the disadvantaged areas scheme within certain environmentally restricted schemes in Connemara and County Mayo. There are concerns, however, in commonage areas as to when the discussions will take place and when a solution will be finally implemented in order that the farmers in question will know where they are going.

Deputy Simon Coveney: The important point is that the European Commission sees progress in this area. There has been progress as the liaison process is under way, but there will be difficult commonage areas that will require local public meetings to be held. We are planning that structure with the farming organisations in order that it can be rolled out over time. Implementation of the new commonage framework proposals will not happen overnight, as the Commission will understand. Most of the commonages will sort themselves out, but there will be potential problem areas in the Deputy's county which will have to be dealt with sensitively

Commonage process to commence soon.

Sean Kyne TD along with Eamon O Cuiv TD and Andrew Doyle TD have taken a keen interest in progressing the commonage issue. They and a small number of other Deputies have been pressing the Minister for Agriculture on numerous occasions for an indication as to the long term plan towards addressing the commonage issue. Unfortunately the flow of real information as to the Dept. of Agricultures plans has been painfully slow. However in response to a recent question from Sean Kyne the Minister for Agriculture has revealed in more detail than we have seen up to now, how he sees the situation progressing over the coming months.

"Sean Kyne (Galway West, Fine Gael): To ask the Minister for Agriculture, Food and the Marine when liaison committees will be set up in commonage areas as agreed by him with representatives of farm organisations from Galway and Mayo in 2012 in view of the concerns regarding commonage stocking rates, farmer exiting REP scheme 4, the conclusion of the 12 Bens Scheme and the absence of compensation for special areas of conservation and Natura designations to many farmers in 2014 and if he will make a statement on the matter,

Simon Coveney (Minister, Department of Agriculture, the Marine and Food; Cork South Central, Fine Gael).

The CAP Reform package which I negotiated contains elements which could impact on those farming commonage lands. However, I am awaiting the adoption of EU Commission delegated acts; it is expected that discussion on these delegated acts will be concluded before year-end.
The issue of stocking levels on Commonages and the approach necessary to address what is recognised as a very complex matter which requires a very detailed action plan to cover the various issues, is one which has received widespread coverage.

The report of the Oireachtas Joint Committee on Agriculture is a valuable contribution to the ongoing debate regarding the issues surrounding commonage lands, the views of the various stakeholders having being sought and considered by the Committee. As I have indicated previously, while it is generally accepted that this is a very complex matter and requires a very detailed action plan to cover the various issues, I intend in the near future to set out proposals on how these matters will be progressed. My firm intention is that the process will be fully inclusive and that all stakeholders, particularly farmers and their representatives will be central to the process.

Commonage lands form an important part of the farming enterprises of many farmers, particularly along the West Coast. They also form an important part of the local environment from the point of view of bio-diversity, wildlife, amenities and economic returns e.g. tourism. However, there is a substantial risk of land abandonment as under-grazing becomes more of a problem. Under-grazing leads to an increase in ineligible land under Direct Aid and Agri-Environment Schemes and leads to risk of financial corrections being imposed by EU Commission. It is vital, therefore, to maintain the commonages in GAEC (Good Agricultural and Environmental Condition), or where there is under-grazing, to return the habitat to GAEC.

Taking all of these matters into account, it is my stated aim is to ensure that a practical solution is reached, which will ensure that the current farmers actively farming these lands are protected, that the land is maintained or returned to GAEC and that the requirements of the governing EU Regulations are met. In my view, this can best be achieved by working with the farmers directly managing the lands, relevant State Agencies, the farming organisations and all other interested stakeholders. With regard to the specific recommendations of the Committee contained in their Report, I can confirm that these will be included among the range of issues to be addressed in the process that will shortly be commenced by my Department."

If as is anticipated the delegated acts (technical issues delegated by the Council of Minister and the European Parliament to the Commission) are adopted before the end of the year and the draft RDP is finalised then everything will be in place to allow for the design of a workable solution to the commonage issue. The Joint Committee on Agriculture, the Upland Working Group and others have made positive contributions as to how this can be done. It is a positive development that the Minister for Agriculture has confirmed that the process of developing a new approach to commonage management will commence soon. Hopefully real progress will be seen over the next six weeks.