Mr. Patrick Kent:

I thank the Chairman and members of the joint committee for the invitation. The issue we bring to members' attention relates to young farmers who, through no fault of their own, are not catered for under the national reserve arrangements in terms of entitlements under the new basic payment scheme. The ICSFA believes this issue must be revisited if we are serious about supporting the future of agriculture and encouraging those who have worked hard to make a go at farming with very little EU or national support to date. The issue essentially revolves around the technical definition of a young farmer set out in EU regulations which refer to a young farmer as having commenced farming in the five years preceding the first submission of an application under the new basic payment scheme. This definition was set out in reference to the young farmers' top-up payment. It was also used initially in the definition of a young farmer under the national reserve scheme.

A key issue in the debate on CAP reform revolved around the definition of a young farmer as being under 40 years of age. This limit continues to apply but the national reserve regulations were subsequently revised so that old young farmers, that is, farmers who commenced their farming activities in 2008 or 2009 would also be eligible to apply for entitlements. The off-farm income limit of €40,000 which applies in all cases has resulted in a number of anomalies. It is important that farmers who commenced farming prior to 2008 are given a chance. The basic entitlements allocated under the new basic payment scheme are linked to the rate of entitlements held by farmers under the old single payment scheme. As members will be aware, these entitlements reflect the farming activities carried out during the original reference period from 2000 to 2002. A cohort of farmers who commenced their farming activities too late to benefit from the original period are now considered to have been farming for too long a period to get a fair opportunity under the new scheme. The problem is that the national reserve during the single payment era imposed a restrictive ceiling on off-farm income of €30,000, as well as limits on allocations per hectare. We ask that farmers in this category be brought up to the national average payment per hectare, which is approximately €250. That is a very modest amount for hard-working young farmers. ICSA believes that it is profoundly unfair to leave these farmers behind. It is welcome that a way was found for old young farmers but it is now time to resolve the unfair treatment of the remaining farmers.

We cannot complain about the age structure of the industry if we allow a cohort of young farmers to be left behind. We have met a considerable number of farmers in this category and, in all cases, we were impressed by the hard work, courage and determination they brought to farming. It is a major flaw in the national reserve that regulations do not allow for a five-year use-it-or-lose-it clause. The options should include a substantial clawback on entitlement sales to ensure there are funds in the national reserve. At this point we have no information on how many of the current applicants to the national reserve will be successful, or how much money will be left over. The key message is that the farmers concerned have a compelling case based on merit and we have to do the right thing by them.