Seán Kyne (Galway West, Fine Gael) | Oireachtas source

What we have seen in the past is that many commonages were reduced either because of the visibility of scrub from satellite and inspections or undergrazing or non-agricultural activities, with the reduction of the forage areas. This happened this year in Castledaly. I know that Deputy Ó Cuív would have tabled a question on that. Other Members would have been involved in other commonages, such as Keelderry last year. There is a concern about the consequences of this. Obviously there is a penalty for farmers, which is one part, and it is serious for the farmers, but there is also the impact of the reduction from 95% to 45%, which is effectively half the available land for grazing. In theory this means that the number of animals put to the commonage has to be halved. If one is halving the number of animals that are to be allowed on the commonage, it will have the effect of causing more undergrazing and more ineligible areas. Most of the commonages in the country are designated special areas of conservation and special protection areas. The requirements under the EU directives on birds and habitats is that we have to maintain these commonages in proper health and status for the reasons they were designated, for example, the habitat for bird species. If one reduces the number of animals by virtue of reducing the forage area, one is impacting on the status of the commonages. Do the officials believe, as has been suggested by others, that this could lead to Ireland being in breach of EU directives on birds and habitats? This must be given serious consideration in the run=up to the next single payment session.
Dr. David Scallan, who presented a paper recently on preventing the loss of valuable agricultural and environmental habitats, states:

Effectively, current eligibility rules for agricultural payments are forcing many farmers to remove environmentally valuable farmed habitats or abandon high nature value farmland. As a result, farm habitats that host lots of wildlife (in particular some excellent woodcock and pheasant habitat) and provide shelter whilst allowing grazing for farm animals are at risk of being cleared for fear of financial penalties. This will result in a loss of biodiversity, farm productivity and landscape variety, all key characteristics of rural Ireland that European legislation is supposed to protect or enhance.

This is serious. He also states:

In very simple terms, whole swathes of land, particularly in the west of Ireland, are being red-lined as ineligible for payments. The signal from the Commission therefore appears to be that biodiverse landscapes need to be eliminated or farmers will suffer severe multi-annual cuts to their single payment. This feeds the perception that the only solution will be to bulldoze, burn ... or remove any tree, bush, gorse or other species, which does not conform to the Commission approach, which might be perceived as aiming to homogenise land use and farming practices across the European Union.

This is Dr. Scallan's view of the impact of removing scrub and the reduction of forage areas. It is his view that due to the size of the commonages and the impact of the decisions that have been made by the Department, an appropriate assessment would be required due to the likelihood of a significant effect of the designated sites, in particular in light of the precautionary principle. I would appreciate if the officials could comment on these points.