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

I welcome the delegations from the IFA and the ACA. I have filled out many single payment forms in my time. Previously it was much simpler in that one left out any site that might have been built on, as well as farmyards, high bank bogs, lakes, small ponds and scrub areas. The current form is very subjective and it is difficult to say "Yes" or "No" to any farmer. Particularly in respect of commonage areas, I am reluctant to assist a farmer or give advice because I do not know whether I am doing the right thing given the subjectiveness involved. There is no right or wrong. I could say something and Mr. Carroll could say something else. The inspector could then come along to declare that we are both wrong, while an EU auditor could have a different view on the entire area. It is very unsatisfactory.

I agree with Mr. Downey in regard to regionalisation. The majority of members of the IFA were opposed to regionalisation and, in fairness to the Minister, he was also opposed to it. We are now facing the risk of regionalisation by the back door because the changes made to the entitlement regime are being undermined in forage areas across the country. I agree that the situation is unsatisfactory but unfortunately some inspectors are taking an overly zealous approach. This is also related to the issue of subjectivity.

I agree with Mr. Dawson regarding the decrease in active farmers and the lack of clarity. There are different issues on commonages. Compulsory destocking is easier to explain because there is a reason for it. The commonage framework plan for other commonages may have included restrictions such as prohibitions on grazing in winter months. Such restrictions have to be taken into account. I accept that the Department is trying to get the message through to the EU auditors. Farmers on the majority of commonages were not able to put out cattle and horses between 1 November and the end of April. That has a knock-on effect due to the animals' inability to graze the heather. As farmers have got older and their numbers have decreased, there have been changes in farm practices. Other farmers have taken sheep off the hills. A wide range of issues arise and I agree that the National Parks and Wildlife Service should also be involved in drawing up a solution.

I understand that ACA members had training days with the Department in regard to GLAS. Was there any clarity on its views, and is the Department still sure about what areas are eligible? In a recent meeting with a departmental representative, we were told that the EU auditors were coming over. He indicated that a lady who came over from the Commission and identified certain areas as ineligible is now head of the audit section of the Commission. I am not defending the Department but it would argue that it is being plagued by EU auditors identifying certain lands as ineligible and, thus, no activity is taking place. What is the solution to this problem? Departmental officials appear unsure about what solution could be found with the Commission. The Commission is saying that there is no evidence of activity on some of these areas, whether commonage or marginal land. What solutions can the ACA and the IFA suggest?

In respect of the Natura areas, I have made the case to the Department that if it reduces the forage area on a commonage, it is pretty well telling farmers that they should put less stock on it. Most of those commonages are Natura areas and if a farmer puts less stock on them, the knock-on effect will be more under-grazing, less utilisation and knock-on effects for the habitat in terms of habitat potential and the value for the birds because some of these are SPAs for birds. One could be in breach of the habitats and birds directives.