Dr. Andy Bleasdale:

I am with the National Parks and Wildlife Service, NPWS, of the Department of Arts, Heritage and the Gaeltacht. One of the main areas of work I cover is the agri-environment brief, in terms of the practicalities and the interface with the Department of Agriculture, Food and the Marine with regard to policy. This stemmed from my PhD in botany which was completed 1995 and which looked at the effects of grazing and over-grazing on the uplands in the Twelve Bens and Maumturks in north County Galway. After my PhD in 1995, I worked for Teagasc on contract for three years. I prepared rural environment protection scheme, REPS, plans in Connemara, generally in commonage areas, so I have a good understanding of the issues that relate to farming, farmers and commonages. In 1998 the Department took me on to co-ordinate the commonage framework planning process with the Department of Agriculture, Food and the Marine. This examined, and was prompted by, a series of complaints made to the European Commission regarding over-grazing in Ireland.

Ireland was encouraged to address the situation outside the REPS programme and to look at the condition of commonages in an independent way. This survey was undertaken in partnership between ourselves and the Department of Agriculture, Food and the Marine. It commenced in 1999 and ran until 2004 and 2005. It covered a very large area of commonage in the country, approximately 440,000 hectares or 1 million acres of land. A total of 4,500 commonage framework plans were prepared. In the approval of those plans, we and the Department of Agriculture, Food and the Marine worked jointly to ensure that the destocking figures set down in the plans were fair and equitable, reflected the situation on the ground and that there was no misrepresentation of either under-grazing or over-grazing. It was a rigorous effort over a number of years.

Subsequent to the bulk of that work being completed in 2005, the outcomes of that research were communicated to the farming community. Farmers with commonage and sheep quota were de-stocked where that was necessary. In many areas they were not de-stocked at all. I will discuss that further later. Subsequent to that national survey, we have monitored a select number of commonages to see how they are doing since the delivery of the commonage framework plans, that is, whether they are recovering, whether they are recovering quickly enough and how the over-grazed commonages have reacted since the initial commonage framework planning exercise.

Commonages have been intimately linked with my professional life over a long number of years. I have also been involved in the NPWS farm plan scheme, which paid farmers in commonage areas to de-stock or to manage commonages in a more appropriate way through off-wintering, housing of cattle and sheep, feeding them on the lowland and so forth, based on the needs of the individual commonages in question. I have had a long interaction, therefore, with the farming community and farmers over a long number of years. I emphasise that this is not some type of ivory tower research that does not understand the issues on the ground. We have a good understanding about the needs and expectations of farmers and the challenges that face both the farming community and ourselves with regard to our obligations under the birds and habitats directives.

I have been involved with the Burren LIFE - farming for conservation programme as well, on which I understand there was a presentation to the committee a number of weeks ago. The NPWS administers the funding of that scheme and the Department of Agriculture, Food and the Marine pay the moneys directly to the farmers. Again, we are working in partnership with the excellent work being done by Brendan Dunford and his team in the Burren in County Clare.

We are very actively involved with and supportive of any positive interactions with the farming community.

To proceed to my presentation, members will see from the slide that we are not the competent authority for commonages but we have some responsibilities in the commonage area. We have statutory responsibility for the birds and habitats directives and we engage in the process in that context. The commonage framework plans were a joint exercise between ourselves and the Department of Agriculture, Food and the Marine. We emphasise, and the Department of Agriculture, Food and the Marine would endorse this, that if we are to deliver biodiversity in these upland areas, it can only be done in partnership and dialogue with the farming community. I wish to underline that, because I am not sure if we have communicated that as well as we must to both the committee and the farming community. It is our firmly held belief that this is necessary. We believe the commonage framework plan review process is an opportunity to enter into a new phase of dialogue that does not just impose destocking and restrictions but works with the farming community in a collective way to achieve the goals for stocking levels to manage land under Pillar 1 supports, and hopefully under Pillar 2 supports, and to deliver the consequent biodiversity that is necessary in these upland areas.

I will move quickly through some of the slides. The committee members do not have them in the presentation, as I have just provided the text. Some of the slides will illustrate the reality. Members can see that a large percentage of the country has commonages, particularly in the west but also in the east, south east, north and south. A good area of commonage, 440,000 hectares, is farmed in this country, including north County Galway, Bun Dorracha in County Mayo and the Mullaghareirks in County Cork, which is a hen harrier hotbed and also an upland landscape. It is not always about the mountains and the bogs. We also have semi-improved landscapes with rushy pastures and some forestry landscapes that are also part of the upland and some of which are held in commonage. The Burren is also an upland area and has some commonage.

There are unique challenges for the farming community in these areas. Often, in some of these areas the farmers have tended, be it due to part-time farming, different expectations or for whatever reason, to focus on the more intensively managed parts of the farm, to the neglect of many of the upland areas. We must engage with them to encourage and incentivise them to go back to the hills and the commonages in the years ahead. The committee will note in the slide an upland scene in County Wicklow, which will be familiar to the Chairman. In some of these areas we are becoming concerned that under-grazing is becoming a problem. However, I emphasise that undergrazing is not the only problem. There is still over-grazing in other parts of the country. That is an important message. It is not black and white, and in different townlands in different commonages there are different scenarios, often within the same commonage. There can be under-grazed and over-grazed parts in the same commonage. These upland areas are key and necessary for the management of the biodiversity we have in Ireland, such as the red grouse, the hen harrier and some of the species that depend on good water quality, for example, the freshwater pearl mussel.

I can give the committee some statistics for commonage. The Department of Agriculture, Food and the Marine will cover some of this as well. We have 6,700 LPIS, land plot identification system, plots of commonage in the country and approximately 15,000 herd numbers, so there are up 15,000 farmers claiming commonage. The gross area of the commonage in 2011 was approximately 430,000 hectares. The reference area of that commonage, when one discounts ineligible land, is approximately 410,000 hectares. However, not all of that is being farmed. We should seize the opportunity to address the issue of inactive farmers and dormancy through this debate, to allow farmers who are very active in some of these commonages to increase their stocking entitlement and take up some of the slack of the dormant farmers and the inactive shareholders. If we do not seize this opportunity, it will be a missed opportunity for both biodiversity and the farming community.

To date we have had no proper management of commonage to prevent against under-grazing and over-grazing. We need to empower some of the farmers and leaders in the farming community to set up a system that allows them to manage the land themselves in a way that delivers biodiversity, good agricultural and environmental conditions, GAEC, and a good environment for both this and the next generation of farmers. If we do not do that, there is a significant risk to the moneys that are paid to the commonage farmers in the year ahead. This is not a threat, but the reality. If land becomes under-grazed, at some point in the future, be it sooner or later, the European Commission will decide the land is not farmed, is not in GAEC and is not eligible, so moneys under single payments or Pillar 2 supports will not be paid to the farmers. Therefore, we need farmers and we need to look at the amount of land and housing the farmer has. Farmers who farm in commonage do not have the green land all in one parcel.

It is not like a farmer perhaps in County Meath who has good intensive grassland. In these upland areas the land parcels are distributed around and they would generally have a share in the hill as well. We need to look at the totality of the farm to manage the commonage and the ability of the farmer to take stock off the commonage which is central to the issue.

The next slide represents a typical commonage scene. It looks to be in good condition from this remove but one can see that there is some rank vegetation. In the years ahead, if we do not get farmers in there and give them support to farm these areas, the commonages could soon become undergrazed. Farmers have a variety of other lands at their disposal such as private lands that are often wet and full of rushes. They may have drier holdings or other parts of their farms are drier. Farmers have good land, bad land and middling land. Therefore, we need to examine the totality of the farm to understand how the farmer farms. Some of the privately owned SAC can also be farmed and is farmed. It can also be damaged and undamaged, undergrazed and overgrazed. The slide shows an overgrazed scene on privately owned SAC. It looks like a commonage in a big area. In many cases a farmer has housing for cattle and sheep which must be taken into the mix. We cannot just deal with commonage in isolation. We cannot talk about commonage and not talk about the farmers who farm it. We need to examine the totality of the farming system, the variation among farmers and their ability to manage stock on the commonage at key points of the year.

We have discussed, in passing, the overgrazing issue. There was a European Court of Justice case taken against Ireland which was closed in January 2009 after approximately ten years of effort by the Department and ourselves to address the issue. A lot of money was spent. Subsequently, since that date, money has been paid to farmers to ensure that the land in overgrazed commonages can be delivered to good favourable conservation status and good agricultural environmental condition, GAEC. A considerable amount of effort has already been undertaken to address overgrazing. Whatever we do in the years ahead we cannot undo the good that we have done in addressing the overgrazing situation. In order to address undergrazing we need to ensure that we do not lead to an overgrazing situation as well.

It is not just the commonage plans and the destocking that concerns us. It is the issues of decoupled payments which means that farmers will not need to keep as much stock as in the past and the effect that is having on upland vegetation. It may encourage farmers to keep farm levels intensive on the lowland part of the farm but not generally throughout the farm. It is the more extensive parts of the farm that suffers. An aging farming population farms many of these commonage areas and reduced supports. That is the reality. I am not saying that it is unfair. It is just the reality that we are faced with because of the climate that we are in. Cuts have been made to disadvantaged areas payments, single farm payments, REPS and AEOS. Therefore, less money is available to farmers which means there is less of an incentive to farm some of these upland areas.

The next slide is interesting. The picture was taken in late 2007 or 2008 as we flew to Mayo to carry out a site inspection report. As I flew over the area the view I captured is a microcosm of the issues that face farmers on commonages and designated areas. One can see a whole suite of things happening in the picture ranging from the archaeological features, the archaeological mound, old turfcutting and an old clachain - which is an old village system which has been abandoned, scrub encroachment, bracken encroachment, intensification, tracks, rushes, areas which have been reclaimed, and then rushes reclaiming the reclaimed land. To think that we can freeze a landscape like that in perpetuity through the designations or through commonage framework plans is a fallacy. We need to work with the farmers to encourage them to do the things that we think are appropriate and to support them in so doing. I hope my slide made my point clear.

We are concerned about heather management on commonages. It is about preventing overgrazing. I do not want to depress anyone when I show slides displaying the extent of overgrazing in years gone by. My next slide shows an area in County Galway which shows completely bare peat over hundreds of hectares in an overgrazed commonage. The next slide shows what it looks like on the ground. Obviously the overgrazing led to the erosion of peat and a run-off into rivers which affects salmon, salmon spawning and so on. I am not underplaying the situation that pertained in the late 1990s and through the 2000s due to overgrazing. We must ensure that we do not return to that.

My next slide shows another upland scene in the mid-west of an overgrazed commonage. Overgrazing is also bad news for the farming community, the heather species, the purple moor grass species and the palatable species that were available to sheep in the past. Sadly, peat erosion has led to the dominance of monocultures of certain species that sheep do not like such as the one displayed on my slide. That species spreads by rhyzones over the overgrazed hillsides. Heather has returned in some of these areas but we need to ensure that it is well managed and well grazed in the years ahead.

Commonage in the mid-west, in particular, forms a large part of the land available to farmers. There is more of an incentive to engage with the farming communities in the areas where the commonages are most prevalent to their farming enterprise. We conducted detailed commonage framework planning surveys throughout that landscape, mapped areas of undergrazing, overgrazing and moderate grazing and gave through the destocking caculations figures for farmers to manage in the years ahead.

My next slide is on County Wicklow and clearly shows that not all commonages were overgrazed or undergrazed. The colours that I have chosen to present here are as follows: green represents not overgrazed but sustainably grazed commonages. My slide shows that in the late 1990s in County Wicklow the commonage framework planning exercise showed that those commonages were in good condition and no destocking was required. Pictures vary from one area to another. In County Kerry one can see a mixture of greens and then reds and purples. The red and purple areas reflect the more overgrazed commonages. The greens are the better grazed or more well managed commonages. Members will be able to see pockets of colours in the pictures. If the pockets are not green then they are pockets of overgrazing. That is what the commonage framework plans have tried to address.

In County Galway and south Connemara one can see that there are a lot of well managed commonages which are not in bad condition at all. As one moves further north towards the Twelve Pins and Maumturk mountains and then heading to County Mayo there was more of an overgrazing problem. I have tried to show that it was not a one-size-fits-all approach and there was not one message. There was variation in the condition of commonages and there still is. Mayo also has a similar situation.

Let us take a look at the area in County Mayo where we, post the commonage framework plans, worked with the farming community to go beyond the commonage framework plans and to pay them top-ups to address serious overgrazing over large hectarages. My next slide shows the situation that pertained in a part of County Mayo in 2005. Again, in case members think that all commonages were undergrazed my slide shows what this area was like in 2005. I shall show the committee before and after slides taken of the same spot. The picture on the left is from 2005 and the one to the right is from 2010. As one views the slides from left to right one can see appreciable commonage recovery in five years through our interventions.

We know we can address the problem but we can only do so with the correct incentives and the correct participation of the farming community. My next two slides show the same area before and after and date from 2005 and 2010 also. I have more slides from both years which show the changes that were made over that period.

If the committee concludes from what I have said today, and because we now accept that there are issues in certain parts of the country with undergrazing, that the commonage framework plans led to undergrazing then I argue strongly that is not the case. The commonage framework plans are only one of many drivers that face upland farmers. Overgrazing is still a serious issue in certain parts while undergrazing is a problem in others.

The commonage framework planning exercise identified that almost 70% of the commonage areas were undamaged. I do not think that point is widely known or appreciated. Only 5% of the area that we surveyed through the commonage framework planning exercise could be described as severely damaged and with severe destocking associated with it. Of the 4,500 plans prepared only 407 plans had a destocking of more than 50%. When we reviewed some of those commonages framework plans that had more than 50% destocking in 2008 the bulk of them had recovered. We had managed to address the bulk of the overgrazing problem. How do we go from that point in our history to a new point with a whole suite of new drivers? The new drivers are decoupling, agri-environmental schemes and rules, a lack of agri-environmental programmes, diminished supports, aging farming populations, the Celtic tiger which encouraged people to move away from the land to jobs, part-time jobs and work elsewhere, and the changing expectations of the younger farming community.

We need to address dormancy through this process of dialogue with the committee and the farming community. We can demonstrate to farmers that there is a dormancy issue for some commonages. What do we do about it? Maintaining the status quowill not resolve the issue of undergrazing if we are only dealing with half of the farmers being active in a given commonage. Despite the best will in the world those active farmers will not deliver the sheep that is necessary for that full area. At present those active farmers are frozen from increasing numbers. We propose, through this process, that the active farmers be allowed to increase their numbers to take up the slack for the inactive farmers and the dormant farmers. We need to engage on the issue. At present these farmers are frozen by the commonage framework plans. We need to replace the commonage framework plans now and quickly in order to allow farmers who wish to be active to increase their activity on those commonages.

Some farmers claim the commonages but do not graze them at all.

I argue, as will the Department, that this is an opportunity for farmers, not necessarily an imposition but if we work well together on this it can assist in managing commonages better in the future to protect single farm payments and to give opportunities for Pillar 2 supports for a future REPS programme, for a future agri-environmental scheme.

I will move quickly through the issue of dormancy in different parts of the country. The green commonages on the slide have little dormancy, maybe 10% is dormant, those in red and purple have a high percentage of dormancy. Oranges, purples and reds indicate many areas of dormancy, where not enough farmers are grazing those commonages. If that continues into the years ahead those farmers and commonages will face a serious problem. There are a lot of red, purple and orange areas in the Cooley Mountains in County Louth. On paper the farmers are not fully grazing that commonage. The active farmers could provide sufficient grazing but in certain parts of the country sufficient grazing may not be provided. Dormancy is not an indication that an area is under-grazed but it is a clue that perhaps not all farmers are farming those areas. There is a similar situation in County Wicklow. It is a worrying trend that some of these commonages are under-grazed. Similarly on the northern peninsula in County Kerry there is a north-south divide. As one moves north through the peninsula there is more under-grazing and dormancy than potentially in the southern part of the peninsula. I cannot explain why. It is just the reality that fewer farmers are claiming in some of those commonages.

I do not wish to deliberate for too long on this issue. I need to conclude quickly as we need to hand over to the Department of Agriculture, Food and the Marine. I have shown slides of over-grazing so it is fair to show slides of under-grazing also. This slide shows an upland commonage landscape where gorse has taken over. This is not good for man, beast or biodiversity. Areas like this must be addressed collectively in partnership with the farming communities and with the support of agri-environmental schemes to address a poor environmental condition. It is not just gorse, there is rhododendron over 50 hectares which is a big problem. Bracken is also a problem in some of the commonages. Purple moor grass has taken over other commonages. There is a suite of different types of problem in various parts of the commonages in various parts of the country.

To date we have published or it has been notified in the Irish Farmers' Journal, that 4,600 LPIS parcels have been communicated in terms of the minimum and maximum numbers for those commonages. This accounts for 370,000 hectares. There is more work to be done. Approximately 10% of the commonages are not yet prescribed for minimum and maximum.