Mr. Gerry Gunning:

I will be brief. We estimate a large proportion of our farmers, approximately 15,000 of them, claim commonage under various EU schemes which covers 6.5%, or approximately 3,500 ha, of the declared area for single farm payment. This land is in various counties, mainly in the west but also in Wicklow, Waterford, south Tipperary, the Cooley Peninsula and other areas. The farmers involved have a high dependence on direct payments which are a crucial element of farm income in these areas. We estimate a high proportion of farmers on commonages are on farm assist and are highly dependent on the social supports which have been in place and are now under threat. As Mr. Bryan has outlined, destocking has led to undergrazing in certain areas, and departmental inspections have led to areas being reduced. As a result, farmers have lost out on payments.

About 60% of commonages are in Natura areas. Where land is designated restrictions are incurred but that is not just about farming. It could affect other developments such as wind farming. Many of these areas are restricted. Therefore, farmers are limited in what they can do.

Cutbacks in budgets over the past four years have had a devastating effect. For example, REPS 4 was closed in 2009, REPS payments have been cut and AEOS 3 has commenced but it is much more limited than AEOS 1 and 2. The number of hectares eligible for the disadvantaged area scheme was also cut and had a devastating effect on commonage farmers because the average sized farm is larger. The farm assist disregards were cut and abolished and the suckler cow welfare scheme was also ended in the most recent budget.

With regard to farm income, the Teagasc national farm survey shows that the average family income from hill farms for 2011, which are the last available figures, was €15,441. The direct payment amounted to €16,468 so represents 106% of family farm income. Therefore, farmers are more than 100% dependent on direct payments. Obviously the figure depends on circumstances, the figure is much higher for some farmers while for others it is slightly lower. The 2012 figures are not available yet but they will be published over the next number of months. We expect the figures to be worse because prices have decreased but costs have increased substantially. The cutbacks in schemes have had a major impact in the context of hill farming.

With regard to stocking levels, the president has referred to discussions. We have highlighted certain concerns about the commonage framework plans. We have a problem with the collective agreement and we have told the Department that it would not work. There is also a question about the figures that have appeared in the Irish Farmers' Journal. Farmers have examined them and shown that some farmers would have to reduce their sheep numbers even if the land needs them. Sheep are the only mechanism that can properly manage these areas.

We have indicated a proper timeframe for whatever changes occur in stocking levels. Farmers should not be penalised while the timeframe is in place because it takes time to introduce such measures. We have suggested a wider range between the minimum and maximum. New entrants should also be catered for in the new stocking calculation, we need an annual review of the figures and we must ensure that they are correct.

There is also an issue about sheep breeds. It has been indicated that only pure mountain breeds would be allowed. Obviously there is a lot of movement on farms, particularly with cross-breeding of sheep and the same applies to cattle. The Department indicated early that cattle would not be allowed but some farmers still have cattle in the hill areas.

Finally, there is the burning issue which is critical. The legislation dictated that in two days' time farmers cannot burn their hill areas. That provision must be widened. In the North the burning date is in mid-April but here it is 1 March. That means that farmers in the North can burn and control their hills for the next six weeks. For Border areas like the Cuilcagh Mountains of west Cavan the stipulation means that farmers can burn on one side of the Border but south of the Border they cannot burn after two more days have elapsed.

The new stocking regime should be implemented now. The upland agri-environment scheme should also allow farmers to engage in a management plan. In order to get the scheme moving we suggest that a consultative committee with an independent chairman be established. Even though we have discussed the matter for the past 12 months it has not moved along. We understand that the new stocking levels and management of the hills will be a central feature of the scheme. We also need an appeals system because sometimes agreement cannot be reached on stocking levels.

With regard to CAP reform, yesterday an Irish Presidency proposal on co-efficiency for hill land regarding eligibility for the single farm payment was announced. We feel that proposal is unacceptable and that objective criteria is a better way forward because payment would be made to active producers that are not catered for in the proposal. We need a strong Pillar II funding mechanism. We also need supports for the areas of natural handicap, which will be the new name for the less favoured areas, and the upland environmental management scheme which has already been mentioned.

Cutbacks in funding has been one of the greatest problems for hill farmers. We need certainty of funding for Pillar II and the 2014-20 rural development plan. We must also have specific support for rural development, environment and disadvantaged areas schemes or areas of natural handicap.

In conclusion, the review must involve consultation, a new environmental scheme, and a strong disadvantaged areas scheme, or areas facing natural or specific constraints or ANCs, as they will be called. The Irish Presidency must ensure that payments to commonage farmers recognise active farmers and the contribution that farmers make to the environment. A management plan is required for each commonage area. Anybody, and any politician, have realised that the rules and regulations do not work and that farmers must be consulted. That is the end of the presentation.