Dr. Kevin Smyth:

I hope we will be able to cover all the comments between the two of us. We fully appreciate the difficulties with regard to commonages. They are far more complex than private land. There are difficulties because people must have collective activity and management. It means that people have to work together and get along. The difficulty I see is that we have a problem with massive undergrazing on our commonages. It is not just down to Government policy on destocking and the problem of overgrazing that we had in the past. We have a situation where the number of sheep on the commonages has reduced dramatically. That is down to decoupling and the age profile of the people involved. What we need and what we are looking for is a greater level of activity on the commonages. We know it cannot be done overnight. We know it is not a short-term fix. It has to be done over time, but the reason I say thestatus quo cannot continue is because we are facing massive fines from the European Union, if we leave the commonages the way they area. It is as simple as that.
If the EU auditors see the amount of scrub and undergrazing on our commonages, they will immediately put forward a flat rate disallowance on the country. If we can put in place a credible plan which will show a way of bringing the commonages back into good agricultural and environmental condition, we will have a situation, where I believe we would buy time and credibility with the Commission, which would allow us to get the commonages back to the way they were.
Certain things are happening with regard to farming on commonages with the introduction of the new CAP, the new basic payment and the higher level of payment on convergences, which will allow a greater level of activity to take place. I know it needs time and it is a long-term process, but we must recognise the reality. The reality is that many of our commonages are undergrazed. It is as simple as that.
Deputy Kyne asked about the situation with regard to the commonage implementation committee. That is an advisory committee and not a policy committee. It is chaired by an independent chairman, Mr. Joe Healy, and has representatives from the Department of Agriculture, Food and the Marine and also from the National Parks and Wildlife Service. The purpose of the commonage implementation committee is to solve problems. People who have problems with reaching agreement on commonage plans can go to the commonage implementation committee and they help put in place a plan which is acceptable to all. That is the role of the commonage implementation committee.

The issue of commonages was mentioned where inspectors would go out and say an area was not 95% eligible, rather it was 45% eligible. That does not mean the number of animals allowed would be halved. The problem is that the inspectors are not finding animals on them. There is a problem of undergrazing. I would be delighted if the number of animals on commonages could be doubled because we would able to improve the grazing and deal with the problem of scrub. We should not mix the concepts of scrub and habitat. Habitats are protected. If anyone has established a habitat, they can declare that under the single farm payment scheme and it will be maintained. What we are seeing here is scrub encroachment.
We will accept lower stocking where there are special areas of conservation or special protection areas. We do that for the disadvantaged areas scheme where we allow for lower of numbers of animals in certain areas and, from that point of view, we are more than happy to respect the environmental considerations. As was said, if the area is one of blanket bog, there should be lower numbers of animals on it. The ideal we are trying to bring in is that there would be a minimum grazing requirement such that people would have one ewe per 1.5 hectares to attract the basic payment. It is not a huge requirement. Only 23 animals are required on the average farm size of 32 hectares. We cannot maintain the status quo. As a public official, I must point out that there is a danger of there being a major disallowance if we keep going the way we are going with regard to the commonages.