Mr. Tom Dawson:

I thank the joint committee for giving me this opportunity to address it.

The Agricultural Consultants Association, ACA, wishes to raise a number of points about the eligibility of marginal and commonage land for the basic payment scheme, GLAS and other area-based schemes. There is anecdotal evidence that departmental inspections of commonages and marginal lands lead to significant reductions in the amount of these lands eligible for the basic payment scheme and other area-based schemes. In the opinion of the ACA, the problem is more widespread due to a number of circumstances. The number of active farmers in commonage areas has reduced significantly in the past ten to 15 years. Since the completion of commonage framework plans more than ten years ago, the number of sheep grazing these lands has reduced substantially, mainly due to enforced destocking prescribed by the commonage framework plans. This, combined with the ageing profile of hill farmers, has led to a decline in the active management of commonage and upland lands.

There is a lack of clarity on the part of the Department on agricultural activity that maintains commonage and marginal lands as eligible lands under the various schemes. The terms and conditions to the basic payment scheme and other area-based schemes stipulate, "In the case of commonage, the activity must be carried out by at least one of the applicants", and that areas ungrazed owing to low stocking rates, areas of ungrazed mature heather, areas of intense rush or ferns and inaccessible areas are not eligible for payments. Greater clarity is required for ACA advisers in order that we can properly advise our clients on the level of activity required on these hills and define what is and is not eligible. Advisers need to be made aware of the exact criteria used to assess commonage and marginal lands. When advising clients, our members must be aware of the criteria the Department uses to assess eligibility in order that we can then advise our clients on how to manage the activity on commonage to ensure eligibility.

ACA and other advisers should be trained, in conjunction with departmental inspection staff, to ensure consistency of approach throughout the sector. We submit that a standardised inspection process should be drafted in conjunction with all relevant stakeholders. In our experience, farmers in commonage areas are well aware of the problems and accept that land eligibility is an issue. However, it cannot be rectified overnight and needs time to be resolved. We contend that where a commonage is under a commonage management plan such as in a GLAS or another management plan and being managed to maintain or increase the eligible area, these lands should be considered as eligible for the duration of the plan in question.

Under the new basic payment scheme, GLAS and in areas of natural constraint there shall be a substantial transfer of payments to marginal land areas. The ACA accepts that to receive these payments, farmers need to be farming the lands and protecting the habitats. However, we submit that the Department needs to permit time for farmers, for example, three to five years, once it can be proved they have a commitment to address or resolve the issues to ensure eligibility.

Historically, the introduction of ewe premia in the 1980s led to large increases in sheep numbers on hill farms and the subsequent problems with overgrazing that evolved from this. The severe destocking prescribed by the commonage framework plans of the late 1990s and early 2000s has led to undergrazing in many of these hill and commonage areas. The ACA is of the opinion that to break this cycle, active co-ordination is required between all stakeholders, including hill farmers and their advisers and the Department of Agriculture, Food and the Marine, with the long-term objective of finding the required balance between the needs of the EU birds and habitats directives and the good agricultural and environmental condition requirements of the Department.