Mr. Joe Condon:

One of the solutions suggested was qualifying for greening on environmentally valuable permanent grassland. I do not think that option has been examined closely enough as a possible solution to the activity question.

Looking deeper into the regulation, Annexe I allows equivalent practices and Annexe IX(II) allows extensive grazing systems. A requirement exists and timing and maximum stocking levels may apply to the extensive grazing. It also allows for shepherding and mountain pastoralism, along with using local or traditional breeds for grazing. The working group, if it comes out of this, has areas where a lot of the activity problems may be associated with a lowland farmer with 30 ha. One days' topping will qualify him for maintaining his land as fully eligible for one year. Using the narrowest interpretation of a commonage farmer, and bearing in mind the average farmer in Ireland has 560 ha, he must have stock on every area of that commonage for 365 days a year. There is a reference to member states implementing regulations with objective criteria to ensure equal treatment of farmers in Article 2 of the regulation, but farmers will be uncertain about this. One day's work by one farmer down in the valley will maintain his land as eligible while another farmer is required to have 365 days of activity. Perhaps a menu of options is the most feasible.