Andrew Doyle (Wicklow, Fine Gael)
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I remind members, witness and people in the Visitors Gallery to switch off their mobile telephones. I welcome from the Department of Agriculture, Food and the Marine, Mr. Paul Dillon, assistant secretary, Dr. Kevin Smyth, assistant secretary, Dr. Ronan O'Flaherty, principal officer, Mr. Fintan O'Brien, principal officer, and Mr. Frank Macken, agricultural inspector. I thank them for appearing before the committee to brief it on the Rural Development Programme 2014-2020 and its current issues and on members' concerns around COM (2014) 180 in regard to organic production and labelling of organic products.

Before we begin, on the matter of privilege, I bring to witnesses' attention that they are protected by absolute privilege in respect of their evidence to the committee. However, if they are directed by the committee to cease giving evidence in regard to a particular matter and they continue to so do, they are entitled thereafter only to qualified privilege in respect of their evidence. They are directed that only evidence connected with the subject matter of these proceedings is to be given and asked to respect the parliamentary practice to the effect that, where possible, they should not criticise or make charges against any person, persons or entity by name or in such a way as to make him, her or it identifiable.

Members are reminded of the long-standing parliamentary practice to the effect that they should not comment on, criticise or make charges against a person outside the Houses or an official either by name or in such a way as to make him or her identifiable.

On the first item, Rural Development Programme 2014-2020 and commonages, I call Mr. Dillon.

Mr. Paul Dillon:

I thank the committee for the invitation to address it today on the subject of the new Rural Development Programme 2014-2020 with particular reference to the issues relating to commonages. As the committee will be aware, Ireland has submitted its draft rural development programme, RDP to the European Commission on 3 July this year. The draft RDP was developed over a period of some 18 months and was based on extensive stakeholder consultation, a number of preparatory analyses and a process of independent ex ante evaluation. In total, the proposed schemes included in our draft RDP amount to some €4 billion of EU and national Exchequer support for rural Ireland and the agri-food sector. This financial commitment will be a key support in enhancing the competitiveness of the agri-food sector, achieving more sustainable management of natural resources and ensuring a more balanced development of rural areas. The draft RDP includes a substantial new agri-environment scheme, GLAS, and a number of other targeted environmental measures, continued strong support for areas of natural constraint, formerly known as disadvantaged areas, significant support for on-farm capital investment, a range of knowledge transfer measures, support for collaborative farming and targeted support for the beef sector via the highly innovative beef data and genomics programme.
The next step is for the draft RDP to be formally agreed with the European Commission. We have recently received the Commission’s official observations on our draft RDP and these are now being addressed as a matter of priority within the Department. Given the fact that the Commission is dealing with the workload of agreeing a total of 118 draft RDPs, it is difficult to predict when our draft will be formally adopted. However, we are in ongoing contact with our colleagues in the Commission with a view to expediting the process as much as possible.
On commonage land, as the implementation of the new Common Agricultural Policy has progressed, the Department has been addressing a number of issues relating to commonage land in the context of both the new RDP and GLAS and the new basic payment scheme.
It is useful to set out at this point some of the background to commonage farming in Ireland. Commonage lands form an important part of the farming enterprises of many farmers, particularly along the west coast. They also form an important part of the local environment from the point of view of bio-diversity, wildlife and amenities. The farming of commonage lands has a long tradition in Ireland. It is by its very nature a complex area. There are issues about the legal right to claim and there have always been disputes about grazing of the commonages. In the vast majority of cases, however, commonage shareholders work well together on a co-operative basis.
Each year, approximately 4.7 million hectares of eligible land is declared by applicants under the direct aid and agri-environment schemes. Of that area, in excess of 330,000 hectares of commonage lands are declared, representing 7% of the total area declared. In 2012, almost 15,000 applicants declared commonage lands, equivalent to 11% of scheme applicants.
Commonage lands in Ireland are mainly situated along the western coast, in particular, in Donegal, Mayo, Galway and Kerry. The areas of commonage lands in these counties comprise almost 71% of the total commonage land declared. In Mayo, it is 84,000 hectares; in Kerry, 54,000 hectares; in Donegal, 51,000 hectares; and in Galway, 45,000 hectares. Commonage lands include both upland and lowland grazing habitats. These lands have been used mainly for the maintenance of sheep flocks, with some cattle and pony grazing in certain areas.
In terms of under-grazing, the experience to date since the single farm payment was introduced in 2005 is that there is a growing problem of commonage land being abandoned by farmers. This is not good for the environment, as these areas lose the specific characteristics as natural habitats for flora and fauna. In addition, the creeping ineligibility of these lands under the single payment scheme and other direct payment schemes poses a significant risk to the State in view of the risk of financial corrections being imposed by the European Commission.
There has also emerged a need to replace the now outdated commonage grazing de-stocking plans, which were drawn up in the late 1990s to deal with the then over-grazing problem arising from the level of sheep maintained on the hills to maximise farmers’ payments under the coupled ewe premium scheme. While over-grazing is still an issue in some known areas, the main problem now facing us is the under-grazing of commonages. A variety of reasons have led to a problem with under-grazing. These are the introduction of decoupled payments in the single payment scheme in 2005, the age profile of farmers with commonage lands, low market returns, resulting in reduced livestock numbers, more attractive returns from off-farm income during the Celtic Tiger era and a requirement to destock in certain areas for environmental reasons.
At present, commonage lands in Ireland can benefit from aid payments under the following direct aid and agri-environment schemes. The single payment scheme, the disadvantaged areas scheme, the grassland sheep scheme, GSS, rural environment protection scheme, REPS or the agri-environment options scheme, AEOS. In many cases, farmers are benefitting from four payments for the same area of commonage lands – SPS, DAS, the grassland sheep scheme, REPS or AEOS. The funding for these schemes comes from Pillar 1, full funding, or Pillar 2, partial funding, of the CAP. It is a primary requirement of the EU regulations governing these schemes that the lands benefitting from aid are maintained in food agricultural and environmental condition, GAEC.
Under the reformed CAP regime, which was agreed during the Irish Presidency of the EU, it was decided that direct payments should be more focused on active farmers. In that regard, it will be necessary for all farmers who apply for aid under the basic payment scheme to have an agricultural activity on each land parcel they claim aid on. In the case of marginal land, including commonages, this can only be achieved by grazing the land. Member states are obliged to set their own requirements for the maintenance of such lands.
Currently, discussions are taking places with the Commission regarding the setting of a relatively modest requirement under the Pillar 1 schemes and the areas of natural constraints Scheme for the maintaining of marginal land. The grazing requirement, which must be met by all applicants under the basic scheme, is fixed at one ewe per one and a half hectares. A lower level will be set for commonages where it is necessary from an environmental viewpoint, for example, on blanket bogs. In order to provide flexibility for farmers who benefit from payments for commonage lands on which they claim aid but do not graze, applicants have until December 2015 to obtain the animals to meet the grazing requirement. It is important to note that the optimum management of commonages will not be achieved unless the farmers actually managing these lands are given a role. They have the knowledge of the best methods for their areas and the Department acknowledges this point.
On GLAS and commonages, payments under GLAS can only be made in respect of actions going beyond the baseline requirements under the basic payment scheme under Pillar 1 of the CAP. In simple terms, this means that a farmer cannot be paid twice for the same commitment under both schemes. Farmers are required under the basic payment scheme to maintain the land in good agricultural and environmental condition and commonage land is no exception to this requirement. So, in order to secure funding for hill farmers under GLAS, the challenge is to design a scheme which manifestly goes beyond the baseline. We also have to ensure that the commitments outlined are measurable and controllable, as this is critical to securing approval.
The key characteristic of commonage land is that it is farmed in common and the actions undertaken under GLAS will have to reflect that. We cannot have multiple and varying plans submitted for the commonage. We need a single plan, drawn up by a single advisor, that sets out clearly what the objectives are over a five year period and what those participating in the plan will do, individually and together, to achieve those objectives. On this point, we clearly need to have sufficient people working together to achieve the best results for these commonages, in the interests of both the farming community and the environment.
Originally, we were seeking a 80% participation but that has since been reduced to 50%, and the Minister has further explained how this will work in practice. In the first place, the 50% requirement is based on active farmers only, that is those actually grazing the commonage. The example we have been using to illustrate this is that if there are 20 shareholders on a commonage and 15 are claiming shares under the single payment scheme, but only 10 of those are actively grazing the land at present, the 50% requirement to trigger priority access to GLAS is just five farmers. This makes it much easier for farmers to achieve the threshold required but where real difficulties are still encountered, the Commonage Implementation Committee will intervene. The Minister has clarified that no genuine applicant will be locked out of GLAS because of an inability to achieve the 50% participation requirement.
The Department recognises that hill farmers have genuine concerns about these new proposals and we have attempted to address these concerns in the various public meetings that were held around the country in September and October.
We welcome this opportunity to address any questions members of the committee may have for us.

Éamon Ó Cuív (Galway West, Fianna Fail)
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I thank the officials for coming here today. A number of serious issues were raised. Mr. Dillon mentioned that the Department has received observations on the draft RDP.

Might it be possible for the members of the committee to be given a copy of those observations so we can have some sense of what is going on, or what is in mind at EU level? Mr. Dillon said the Department cannot give us a projected date for when it is likely that this will be completed. Perhaps he can give us two indications. How long does he think it will take the Department to prepare the response? In broad terms, are we talking about a fortnight, a month or six weeks? How long after that will it take to get agreement from the EU so we can have some sense of what is happening? Is it likely to take a month, two months, six months or eight months?

Even though we all use the English word "commonage", I have to say I do not like it because it seems to imply that the land in question is commonly owned. Most land in Ireland, including commonage areas, is not commonly owned. It is not "common" as we might have understood that to mean when they used to play cricket on common areas in village centres in Britain. In other words, we are not talking about a common area in public ownership. In most places, the coimíní, or the commonages as they are called in English, are areas of undivided ownership. If a husband and wife own a piece of land, is it a commonage? If they have an undivided share each, is that a commonage? If two people are joint owners, is that a commonage? If a hill is owned outright, is it being considered a commonage even though it is not a commonage? It is important for us to understand what is being called a commonage. To my knowledge, one never sees the word "commonage" in the folios. One sees references to "undivided share, one fiftieth" and that kind of thing. It is important for us to get a clear understanding of what the officials are talking about.

I have seen it all in my time. I have seen the fetish about over-grazing and I have seen the prescriptions to deal with over-grazing. When I served as Minister, I brought the late Michael O'Toole to the Department to meet representatives of the National Parks and Wildlife Service. Mr. O'Toole, who was a soil scientist by profession, had worked for Teagasc for many years. He was also a hill sheep farmer. He had been in charge of the hill sheep station that was run by Teagasc and previously by the Agricultural Institute. He spent five hours warning the officials that if they continued to pursue the prescriptions they were pursuing, they were going to get an under-grazing problem. He said that this problem would not be caused by the farmers, but by the prescription farming that was being prescribed. Needless to say, his warnings fell on deaf ears. The officials carried on regardless and took virtually all the sheep off the mountains in the Maamturks and other areas.

Now that we have moved on from over-grazing to the latest fetish of under-grazing, which we are being told is happening on a massive scale, I think this committee is entitled to information from the Department on the areas that are allegedly under-grazed. I would like to compare those areas with the areas where the two Departments put in the prescriptions and forced the farmers to take away the stock. If my guess is right, the vast amount of under-grazing that the officials are talking about was not caused by farmers who were unwilling to farm the hills or too old to do so - it was caused by the Department's own prescriptions. It would be very unfair to penalise farmers for the outcome of things we had warned about. The idea that farmers are not farming the land - that one will not get enough farmers in all the commonages to put up enough stock to keep them fully grazed - is not my experience. When they come in to see me every week, they ask whether it might be possible for them to put more sheep on the hill. I would be interested to hear Deputy Kyne's experience of this in Connemara. The farmers want to know when the stocking restrictions, which they never wanted, will be lifted. They wanted sheep. Regardless of the amount of money that was given to them, many farmers were very aggrieved about the sheep being taken away in such numbers, particularly in more recent years. The officials need to stop talking in generalities about under-grazing and start giving us the facts. It is important for this Oireachtas committee, the members of which represent the people, to be given that information.

I do not know who came up with the idea under Pillar 1 that a farmer will not get a single farm payment if he or she does not have stock on the commonage area that he or she submits. I will set out a very simple case involving a large commonage area of 300 ha, or 750 acres. If just 30 farmers - this would be quite a small number - in that commonage are farming the lowland, there will be 10 ha per farmer. If we presume that the real stocking level is one ewe per acre - I am talking about a good grass hill, as one would not get such a level on a boggy hill - that is 2.5 ewes per hectare. If the 30 of them have to put their sheep on the hill, there will be 30 flocks of 25 sheep up there. Of course, there are 750-acre commonages with 100 owners who are submitting area aid forms. If the officials do not believe such commonages exist, I can give them examples. I have seen a commonage of 245 acres with 200 owners. The officials can understand how this would affect such a commonage.

My example relates to farmers with 25 ewes each. If the number of farmers in this case was to increase to 60, they would have 12 ewes each over 750 acres. The idea of a farmer chasing around the mountain after 12 sheep that are spread randomly over 750 acres, with another 30 doing the same thing, is farcical. The case I set out involved 30 farmers and 300 ha. This equates to 10 ha and 25 ewes each. If the 30 active farmers could come to an arrangement whereby ten of them could put the sheep up on the hill, and the other farmers would allow them to graze their share for free grass without charge, each guy would get 75 ewes. Chasing around the hill would become a somewhat useful exercise in such circumstances. There would be the exact same number of ewes on the hill, which would be fully stocked. That is basically the way the thing works at the moment. It is not the case that any one of the shares is not being actively farmed. There is a gentlemen's or ladies' agreement between the farmers about who puts up the sheep on all of this land. The idea that it is not kept in good agricultural environmental condition is nonsense. The idea that some other arrangement is reached is equally nonsensical.

I was at a meeting at which somebody suggested that a farmer who is not farming the mountain can claim the single farm payment and lease it to another farmer. That is not going to work because as of now, one gets the single payment when it is given and one lets the other guy graze it. Everybody is happy. The thing is fully stocked and maintained. Why would the person who is getting free use of it, in effect, suddenly start paying a lot of money for it? I do not think that is practical. The upshot of this is that if it is enforced in an area like Connemara, the single farm payments of over half the farmers will be destroyed. That is a simple fact. The Department knows from its own statistics that there are twice as many farmers with cattle only as there are with sheep only or with both cattle and sheep. We know that the cattle do not go to the top of the mountain. We were told at the meeting in Maam Cross that one will have to graze all the land as an active farmer. One will not be covered by putting a few cattle in the lower part of it for a few days each year. In light of what happened with LIPIS, I firmly believe this will be enforced to the letter of the law. I can see GPS-sensitive ear tags being put on the sheep five years from now to make sure they are roaming the whole range.

They stated that one would have to use all the commonage. Allowing that it is a mountain, cattle cannot go to the top of the mountain. Ergo, where there is a cattle-only farm, the Department knows immediately to throw the farmer out of the scheme and not allow him or her claim on his or her commonage.

This is one of the most extraordinary and frightening developments in hill farming in a long time. I am sorry that I have taken a while here but I have been working with hill farmers since I went to Connemara in 1974. As somebody who was sheep farmers' co-operative manager in his early days, I am aggrieved at the way the farmers are being treated.

On Pillar 2, just as we did centrally with the commonage framework plans, my belief is that if one wants to get farmers in hill areas into the green low-carbon agri-environment scheme, GLAS, the minimum requirement is that the State commissions and pays for the plan in consultation with the farmers on each commonage. Let us say all of us are farmers in a commonage, we all have different advisers, we all must agree one adviser and we have to pay for it. If I pay for it because I want to get into GLAS, the Chairman might say he was not interested in getting into GLAS. When I have the plan ready, he might say then that he wants to go into it and he will use my handy plan because he must use it. I believe, therefore, that step number one in this is that there should be one plan, like the commonage framework plan but which would be a GLAS plan developed for the commonages, and if I go to my planner, he or she would buy into that plan.

The second detail we need to know is the extra ideas the Department has. The officials stated that good agricultural and environmental condition, GAEC, applies in terms of single farm payment. One of the questions that is left unanswered, therefore, is the nature of the prescription under the GLAS scheme. What will a farmer have to do over and above GAEC, in other words, graze it correctly? If there are physical changes to the commonage involved, any one shareholder, active or inactive, can stop it. One cannot change anything on a commonage physically without the permission of all. If one ever tried to lock-split a commonage - the Land Commission in the Department will give the officials the lowdown on this - one could not do it without 100% agreement.

On this round, it is stated that if there are 20 shareholders on a commonage, and 15 are claiming shares under the single payment scheme, but only ten of those are actively grazing the land, the 50% requirement to trigger priority access to GLAS is just five farmers. It was stated earlier in this regard, however, that if there are 20 shareholders on a commonage and only ten of those are actively grazing the land at present, there can only be ten farmers claiming the commonage for the single farm payment by the end of 2015. What farmers will be forced to do and what I would do is to go to Maam Cross, buy ten cast ewes and let them off on the mountain. They would disappear to the original mountain, but so be it. I would have them up on the hill to meet the Department's requirements. If I have a small enough share, I can put ten up and let them go wild. What about it? Those sheep will return home. This provision shows the total misunderstanding. How will we get all these ewes into place? How will we get them there? If I am in a commonage and I have not been putting sheep up on the hill, and if I decide I want to put sheep on the hill and none of my neighbours is willing to sell me the sheep, how will I get sheep up there? If I go to Maam Cross mart and buy ewes, they will head off across the mountain a distance of ten or 20 miles back to where they came from but I will be able to show in my census that I put them up there and I can leave the Department officials to try find them. This is totally misguided. To put it frankly, we need to think this one out again. This is a much bigger disaster than the Department appreciates.

Martin Ferris (Kerry North-West Limerick, Sinn Fein)
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I thank Mr. Dillon for his presentation. Much of what Deputy Ó Cuív states is what I have been hearing as well at meetings throughout the country. I understand representatives of the Department attended meetings in the west. I was not at those meetings but what I know, from the farmers to whom I have spoken since, as I was in the west last week, is that there is total dissatisfaction. These farmers could not get any straight answers and they are very concerned about what is coming down the track. All of us here, as public representatives, feel the same way about this. As Deputy Ó Cuív stated, this could turn into a nightmare if it is not done right.

On GLAS on the hill and how to draw down the payments, the plan is determined by the buy-in from those who have access to and use of the commonage. One could end up in a situation where one is obliged to maintain the commonage, I assume in its entirety, in good agricultural and environmental condition. I refer to a vast amount of hectares with only a few farmers. In a commonage of 20 farmers, for example, as Mr. Dillon stated, there may be ten active and ten non-active, with the five farmers buying into it responsible for the good agricultural and environmental condition of the commonage. Mr. Dillon should clarify how the Department proposes to determine that.

Mr. Dillon also spoke of a single plan for a commonage. Is this workable? The onus is back on the active farmer to bring forward the plan and get everyone else who is an active farmer to buy into the same plan. It is determined by everyone being supportive of each other, and that may not be the case. If Mr. Dillon is familiar with rural areas and those who share commonages, it is difficult to get shareholders to agree. If that does not happen, who will be at a loss?

Mr. Dillon also stated that no one will be locked out of GLAS if there is not a 50% take-up. If any percentage under 50% is prepared to buy into and work this, their application should be verified and they should be allowed to draw down their entitlements.

Who appoints the commonage implementation committee? Is it the Department or does it include Department officials? I would be concerned to know who it is. If there is a big disagreement here between active farmers on commonages who have been present at the Department's meeting and are not satisfied with the officials who dealt with those meetings, and if those officials are the ones who will adjudicate afterwards, I would be concerned about it.

We have a short space of time to get this right. The Department needs to listen to those on the ground who have been active farmers in commonages all their lives. Those are the best ones to know what is happening there. I hope that will be the case.

Thomas Pringle (Donegal South West, Independent)
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I thank the officials for their presentation. I will not go back over everything that has been outlined by Deputies Ó Cuív and Martin Ferris, except to state that I agree with them. We need clarity on the practicalities of how the commonage plans will work.

My one question relates to the commonage implementation committee. I note that the hill farmers' action group met that committee a number of weeks ago. They believed they had achieved some agreement on changes to take place in relation to the commonages and they since have come to the conclusion that those changes have not been acted on within the Department. What recommendations did the commonage implementation committee make to the Department and has the Department taken them on board?

Pat Deering (Carlow-Kilkenny, Fine Gael)
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I have a query about GLAS. Mr. Dillon said the Department had recently received official observations about the draft scheme from the Commission. Will the programme have to be changed much? Will it require amendment and will it be open to public discussion? Will this slow down the entire process? GLAS needs to be put in place as soon as possible. I acknowledge discussions must still take place, but the timescale is important for most farmers. I will leave the commonage issue to those who are more knowledgeable.

Brian Ó Domhnaill (Fianna Fail)
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While we are discussing the rural development programme, it is unfortunate that much of attention and concern of farmers centres on two main issues - commonage and GLAS. However, the programme is much wider than that. I am not sure whether it is the Department's intention to focus on one or two issues and deflect attention from others. The issues of major concern are commonage and GLAS, if they are implemented as proposed. While these might be laudable objectives on paper that will deal with issues such as fires on hills due to a lack of grazing and so on and address commonage plans, they are unworkable. A sledgehammer is being taken to crack a nut. Farmers will be punished because of the way policy was implemented by the Department in previous years. The Department requested in conjunction with NPWS a cutback on hill grazing and to remedy this, the commonage plan is one of the policy objectives it is bringing forward, which in my view and that of farmers and other committee members is not workable and not practicable at all. As Deputy Ó Cuív, who lives beside a commonage in Connemara, has outlined, linking the single farm payment to the commonage area will not work in the manner proposed.

There are farmers on one commonage in my county and 15 different planners are working with them. They all draw down the single farm payments. Some are engaged in AEOS while others are on the verge of leaving the REPS. How will farmers decide which of the 15 planners to employ? It is crazy beyond belief and it will not work. Too much of the onus is being put on farmers and easier and more workable methods could be taken into consideration. It is also a little harsh on farmers. They are being told a policy is being introduced because officials do not think they can manage themselves and they will stipulate clearly what farmers can do. The objectives may be laudable but practicality does not come with them.

When one applies for area aid, one must also apply for GLAS in 2015. What will happen to farmers who are engaged in a five year programme under AEOS? Do they have to give up AEOS and apply for GLAS?

Michael Comiskey (Fine Gael)
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I apologise for not being in attendance for the presentations but I had to be in the Seanad. I am concerned about the tone of the debate regarding GLAS and commonages. Farmers have been destocked and badly treated over the years and many have been unable to restock commonages with sheep. It is important that they be given an opportunity to at least participate in GLAS and not be barred from it. It is also important that a plan for each commonage be agreed with the Department and the planners but that one planner rather than a number of planners implements it. Each farmer could employ a planner to implement the plan. Farmers should be not be disallowed from GLAS. The scheme is an important support for farmers in these areas and they have looked after commonages through the years, long before destocking took place. They managed the commonages in an environmentally friendly way. It is vitally important they be given an opportunity to do that. I look forward to the reply.

Seán Kyne (Galway West, Fine Gael)
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I welcome Mr. Dillon and the other officials. I have a few questions regarding GLAS, which I have raised with the Minister previously. I appreciate the officials have received replies from the Commission regarding issues. I am a former REPS planner and there is a great deal of concern among farmers and planners about the deadline and the scale of what is required to complete the process of preparing complete commonage plans and individual plans for farmers. There is a perception that many planners, where they have a choice, will deal with every non-commonage farmer before even considering a commonage farmer because they are anxious to get work done. They have lists of existing clients or other clients who may be interested and they will deal with everyone bar the commonage farmers first. One of the aims traditionally was to include Natura lands to give options to farmers to participate in schemes on them. If all the other farmers draw up plans and the commonage farmers are left to the end, that defeats the purpose of providing funding for Natura lands.

I agree with Deputy Ó Cuív and others about the Department controlling the commonage plan either by choosing an adviser or going to tender to select an organisation to deal with this. It is probably late in the day to do this now but asking a large number of farmers to pick one person to do the job poses huge difficulties in the context of payments under the plan and controlling it.

Approximately 50% of farmers have more than one commonage area in their single payment scheme application. Five or six townlands have to be dealt with on some forms. On the basis that they have their individual plan and are party to five or six other commonage plans which they must pay for, set up and attend meetings about, it is a minefield in respect of how this will be addressed.

I ask that consideration be given before GLAS opens to allow farmers to express an interest that they wish to participate in the scheme and that the deadline be extended to the end of 2015 to enable commonage farmers to prepare plans because there will be a time lag. This will also give the Department time to examine the allocation of individual commonages to one planner or organisation.

I understand farmers who are in AEOS 1, 2 or 3 have the option to transfer to GLAS. Will the officials clarify whether there is an option or a requirement? I spoke to a planner yesterday who said it was a requirement that they transfer to the scheme. Can they be counted in terms of the 50%? They are in an environmental programme and, therefore, they should be counted. In most cases in my experience, farmers who were in REPS 1 transferred to REPS 2 and 3 and so on and, under various schemes, they transferred where they could.

The GLAS scheme is an important programme for commonages and it is important the programme is workable. Will the officials comment on that?

Before we discuss undergrazing, overgrazing and forage, may I clarify if we are dealing with the single payment and the reduction in forage areas?

Andrew Doyle (Wicklow, Fine Gael)
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Does the Deputy mean-----

Seán Kyne (Galway West, Fine Gael)
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The red lining of areas.

Andrew Doyle (Wicklow, Fine Gael)
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Yes.

Seán Kyne (Galway West, Fine Gael)
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What we have seen in the past is that many commonages were reduced either because of the visibility of scrub from satellite and inspections or undergrazing or non-agricultural activities, with the reduction of the forage areas. This happened this year in Castledaly. I know that Deputy Ó Cuív would have tabled a question on that. Other Members would have been involved in other commonages, such as Keelderry last year. There is a concern about the consequences of this. Obviously there is a penalty for farmers, which is one part, and it is serious for the farmers, but there is also the impact of the reduction from 95% to 45%, which is effectively half the available land for grazing. In theory this means that the number of animals put to the commonage has to be halved. If one is halving the number of animals that are to be allowed on the commonage, it will have the effect of causing more undergrazing and more ineligible areas. Most of the commonages in the country are designated special areas of conservation and special protection areas. The requirements under the EU directives on birds and habitats is that we have to maintain these commonages in proper health and status for the reasons they were designated, for example, the habitat for bird species. If one reduces the number of animals by virtue of reducing the forage area, one is impacting on the status of the commonages. Do the officials believe, as has been suggested by others, that this could lead to Ireland being in breach of EU directives on birds and habitats? This must be given serious consideration in the run=up to the next single payment session.
Dr. David Scallan, who presented a paper recently on preventing the loss of valuable agricultural and environmental habitats, states:

Effectively, current eligibility rules for agricultural payments are forcing many farmers to remove environmentally valuable farmed habitats or abandon high nature value farmland. As a result, farm habitats that host lots of wildlife (in particular some excellent woodcock and pheasant habitat) and provide shelter whilst allowing grazing for farm animals are at risk of being cleared for fear of financial penalties. This will result in a loss of biodiversity, farm productivity and landscape variety, all key characteristics of rural Ireland that European legislation is supposed to protect or enhance.

In very simple terms, whole swathes of land, particularly in the west of Ireland, are being red-lined as ineligible for payments. The signal from the Commission therefore appears to be that biodiverse landscapes need to be eliminated or farmers will suffer severe multi-annual cuts to their single payment. This feeds the perception that the only solution will be to bulldoze, burn ... or remove any tree, bush, gorse or other species, which does not conform to the Commission approach, which might be perceived as aiming to homogenise land use and farming practices across the European Union.

Andrew Doyle (Wicklow, Fine Gael)
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There are quite a number of in-depth and detailed questions. May I clarify that for the good agricultural and environmental condition, GAEC, there is a requirement of one ewe per 1.5 hectares for the basic payments scheme. If one is not going into GLAS, no plan is needed. That is a proposed requirement in the draft at present. The single plan comes into play for the purposes of the Pillar 2 GLAS payment.

There are locally led environment schemes which are also part of it, for example, in the Burren and others areas that may come forward. There are 160 participants in the Burren environment scheme, getting an average of €7,500 each, and that is done by mutual agreement. That is a further development. It will be specific and will require detailed plans and approvals.

The key point for applications to GLAS is that there will be a need, especially in light of the deeper and wider impacts that Deputy Kyne identified, for the Department to nominate someone and for that person or company to work with the existing planners. It will take some pooling to make it happen. The question being posed is that where a person with a basic payment scheme requirement does not intend to put his or her animals onto the commonage and that person makes an application under GLAS, is there some way of getting around that whereby he or she could nominate or allocate that stock number in order that the plan works and he or she keeps the entitlement? That appears to be the sort of line being pursued. I am trying to put in context the line of questioning that has come forward.

Dr. Kevin Smyth:

I thank the Chairman. We propose to split the questions and I will answer questions on destocking, the undergrazing problem and the questions in respect of Pillar 1 while my colleague, Mr. Paul Dillon, will deal with question on GLAS. Is that okay?

Andrew Doyle (Wicklow, Fine Gael)
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Yes.

Dr. Kevin Smyth:

I hope we will be able to cover all the comments between the two of us. We fully appreciate the difficulties with regard to commonages. They are far more complex than private land. There are difficulties because people must have collective activity and management. It means that people have to work together and get along. The difficulty I see is that we have a problem with massive undergrazing on our commonages. It is not just down to Government policy on destocking and the problem of overgrazing that we had in the past. We have a situation where the number of sheep on the commonages has reduced dramatically. That is down to decoupling and the age profile of the people involved. What we need and what we are looking for is a greater level of activity on the commonages. We know it cannot be done overnight. We know it is not a short-term fix. It has to be done over time, but the reason I say thestatus quo cannot continue is because we are facing massive fines from the European Union, if we leave the commonages the way they area. It is as simple as that.
If the EU auditors see the amount of scrub and undergrazing on our commonages, they will immediately put forward a flat rate disallowance on the country. If we can put in place a credible plan which will show a way of bringing the commonages back into good agricultural and environmental condition, we will have a situation, where I believe we would buy time and credibility with the Commission, which would allow us to get the commonages back to the way they were.
Certain things are happening with regard to farming on commonages with the introduction of the new CAP, the new basic payment and the higher level of payment on convergences, which will allow a greater level of activity to take place. I know it needs time and it is a long-term process, but we must recognise the reality. The reality is that many of our commonages are undergrazed. It is as simple as that.
Deputy Kyne asked about the situation with regard to the commonage implementation committee. That is an advisory committee and not a policy committee. It is chaired by an independent chairman, Mr. Joe Healy, and has representatives from the Department of Agriculture, Food and the Marine and also from the National Parks and Wildlife Service. The purpose of the commonage implementation committee is to solve problems. People who have problems with reaching agreement on commonage plans can go to the commonage implementation committee and they help put in place a plan which is acceptable to all. That is the role of the commonage implementation committee.

The issue of commonages was mentioned where inspectors would go out and say an area was not 95% eligible, rather it was 45% eligible. That does not mean the number of animals allowed would be halved. The problem is that the inspectors are not finding animals on them. There is a problem of undergrazing. I would be delighted if the number of animals on commonages could be doubled because we would able to improve the grazing and deal with the problem of scrub. We should not mix the concepts of scrub and habitat. Habitats are protected. If anyone has established a habitat, they can declare that under the single farm payment scheme and it will be maintained. What we are seeing here is scrub encroachment.
We will accept lower stocking where there are special areas of conservation or special protection areas. We do that for the disadvantaged areas scheme where we allow for lower of numbers of animals in certain areas and, from that point of view, we are more than happy to respect the environmental considerations. As was said, if the area is one of blanket bog, there should be lower numbers of animals on it. The ideal we are trying to bring in is that there would be a minimum grazing requirement such that people would have one ewe per 1.5 hectares to attract the basic payment. It is not a huge requirement. Only 23 animals are required on the average farm size of 32 hectares. We cannot maintain the status quo. As a public official, I must point out that there is a danger of there being a major disallowance if we keep going the way we are going with regard to the commonages.

Éamon Ó Cuív (Galway West, Fianna Fail)
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I think-----

Andrew Doyle (Wicklow, Fine Gael)
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I will come back to the Deputy because I wish to raise a few questions on this area. I will ask Mr. Dillon to respond to the other issue and then I will come back to this issue.

Mr. Paul Dillon:

On the question of the grass, low-carbon agri-environment scheme, GLAS, and why we were leaving it to the farmers to employ an adviser to draw up the plan by themselves, we met the Agricultural Consultants Association, ACA, and Teagasc, separately and jointly, and had a series of consultation meetings with them over a number of months about how we would organise the scheme. We put to them the difficulty of farmers coming together and agreeing on one adviser and one plan. We would all agree there can only be one plan for each commonage because everyone must be working towards a common purpose. We wanted to make it as non-prescriptive as possible in order that the farmers and their advisers would have as much scope as possible as to what measures they would introduce by way of improving the agri-environmental status of the commonage. That is reason we did not want to impose plans on the farmers. We offered to get involved in linking farmers with advisers for the purpose of doing this, but both Teagasc and the ACA said they could look after this themselves.

We also asked them about the timeline and if it was possible to do this, as alluded to by Deputy Kyne, and they said that while the timeline would be tight, they believed it could be done. We are mindful of the fact that all these commonages will all have to be walked and that a good deal of work will need to be done. We may need to revisit the timeline in terms of lodging the plan, but if we are to accept a farmer into GLAS and start making payments to the farmer from the start of a contract date, that means the farmer has entered into agri-environmental commitments. We must have something against which to be able to measure those commitments. We cannot simply take a farmer into the scheme on the basis of signing a commitment to join a plan. We must have something of the detail that is in the plan. The idea was that we would not be prescriptive as to what measures would go in and that the adviser in conjunction with the farmers who wanted to join would be able to agree on the optimum level of stocking that would be appropriate for that particular commonage. They would know the current level among all the shareholders and the optimum level, and then they could take a stepped approach to get from the current level to the optimum level. That was the planning behind it and the reason we were using this model.

At all times our philosophy was that we did not want to impose upon the farmers and the advisers what particular model they should use because it was pointed out to us several times that the people who know what is best for the commonage in terms of how to improve it are the farmers and they could get together with their own advisers in terms of how to improve it. Stocking is one element but there are other collective actions that can be introduced as part of the plan to make it better from an agri-environmental point of view.

The rate payment proposed under GLAS was €120 per hectare per annum. A fair chunk of that payment was arrived at by virtue of the fact the farmer would be paying the adviser to do that. The point has been made about how this will be worked out if several farmers are involved and if it will not be the case that the advisers will go after the easier ones, but there is a flip side to that. If there are a large number of shareholders involved and they and a few planners get together, they will note that the cost they have to charge each farmer will go down the more commonage shareholders there are.

Andrew Doyle (Wicklow, Fine Gael)
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Is the Department working with the Department of Arts, Heritage and the Gaeltacht and the National Parks and Wildlife Service on the one issue? Dr. Smyth made a few references to scrub land. One of the problems is that there have been limitations attached to burning scrub land. Is that aspect part of what will be necessary? In our report last year we referenced specifically inaction with regard to burning. It is an environmental measure and not one that is damaging. Deputy Kyne asked whether the use of a bulldozer or the traditional way is the best way, and I argue that the traditional way, which kept the commonages in good condition, is the way to manage them.

Dr. Kevin Smyth:

I agree with the Chairman that burning is part of the way of managing commonages, particularly when they have fallen into a severe state of disrepair and where there is a severe heather problem. Eight meetings on the commonages were held. The meeting at Maam Cross was especially fractious but many of the meetings went well from that point of view. The same issues came up and one of the issues, as was correctly mentioned by the Chairman, was that of burning. The National Parks and Wildlife service deals with the burning area. The question was raised as to whether it is possible to increase the window in terms of the dates, and that is an issue we have taken up with the National Parks Wildlife Service. I agree with the Chairman that there is a role there for controlled burning as part of commonage management plans, and it is something we have raised with the National Parks and Wildlife Service.

Andrew Doyle (Wicklow, Fine Gael)
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I wanted to clarify those points. I call Deputy Ó Cuív and then I will bring in other members.

Éamon Ó Cuív (Galway West, Fianna Fail)
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Dr. Kevin Smyth has said that there is an undergrazing problem. I have long experience of dealing with farmers and all they have ever told me is that they want to put sheep on the hill and they were allowed to do so. Let us resolve this once and for all. Can Dr. Smyth give me and Deputy Kyne the maps of the areas in Connemara that he believes are undergrazed? If he gives us those, we will be able to compare those with the commonage framework plans and we will know the cause of the problem once and for all. That is what is called evidence-based decision-making. I would want to see the evidence before I would believe there is great deal of that land that has been abandoned by farmers. If we want to ensure there is adequate grazing of the commonage, it is much more likely we would do it in a systematic and better way if a smaller number of farmers were putting a larger number of sheep on the hills. If we force people to put small numbers of sheep on the hills, they will not be able to provide the care for the area that would be provided if there were a big flock of sheep on the mountain.

I will cite a typical example. I am sure Deputy Kyne knows Oorid in Recess. If one checks this commonage in the Land Registry, one will note it comprises 1,753 acres. There are 80 farmers with a stake in it, which works out at approximately 22 acres a head. Dr. Smyth can work out the number of sheep involved. If it is set out in acres, 1.5 hectares would work out at 2.5 and there would be another 1.25.

That is 3.75. Each one is 20 acres. If I divide that by four, I need something like 5 to 7 sheep over 1,753 acres, if they all take up the option to avail of the grant. That is not management, it is chaos. It is not workable.

I cannot understand why the Department of Agriculture does not say it wants x number of sheep on a designated hill, for example 500 ewes on a hill, or if it is a very good hill there might be a ewe to the acre. Presumably the number of ewes will relate to the quality of the land. Blanket bog would take fewer ewes. Say the Department decides it wants 500 ewes on a piece of land. Why can't it tell the farmers that it wants there to be 500 ewes there collectively and it does not care which farmer technically owns the ewes? Then we would get a very well-managed situation where a smaller number will look after the flock well, and will manage the sheep across the range. If the Department is forcing people with five or 10 sheep up onto the hill just to keep their area-based payment, they are not going to be able to manage them over the range. How can five to 10 ewes be managed over that kind of range? It is not practical.

I am appalled at the continued total lack of understanding of the reality of this. I was trying to explain it in Maam Cross. The next problem, of course, is that if we have under-grazing, for example if there were only 200 ewes on the land, it will take a long time to breed up. A farmer will only get 70 lambs out of 100 ewes and only half of those will be female, so that is 35, and of the 100 ewes, 10 will die every year on average, so no we only have 25. Even keeping all of the ewe lambs, which are the profitable ones to sell, the flock can only be increased by 25 ewes per hundred per annum. That is all that can be done. If a farmer wants to go from 100 to 200 it is going to take at least four years. There is a problem here.

Do we know how many hill farmers are on the commonage implementation committee? These are people who have real experience on hills.

Did the farming organisations not warn the Department that this would be chaos in the mountains before the rural development programme went in and all of this was drawn up? In fairness to the IFA they have been vociferous in places like Connemara, saying that this is unworkable.

Seán Kyne (Galway West, Fine Gael)
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I have a couple of questions about the GLAS scheme. Can the witnesses give us some information about the deadlines? It was opening on 1 December but there was some talk it might be January. When would be the closing deadline? Is there any certainty on that?
With regard to the Department not having control of the commonage, it was said that Teagasc and the ACA felt they could look after it. Since then I have seen comments from Teagasc people that they are not going to get involved at all. I am concerned about that. It was said the Department might have to go back to them. Is it going to go and see if Teagasc is still of that view? If this is the case, there needs to be Department involvement and control in relation to the commonage plans. In regard to those who are currently in AEOS1, 2 and 3, do they count towards the 50%?
I agree with Dr. Smyth that we cannot keep the status quoin regard to under-grazing but the point I am making is that if we are reducing the forage area, we are effectively saying that commonage can take less stock. On land where farmers were allowed to put 20 livestock units, if the forage area is reduced by half, they would only able to put on 10 livestock units. This means that the Department is exacerbating the under-grazing situation. What it should be doing is maintaining the forage areas but ensuring that there is a minimum stocking and that the farmers have to prove that they have the stock. If the forage area is reduced, that impacts upon the level of stock that the farmers can put on the farm. It could have serious consequences for habitat status and could cause a greater level of scrubbing up. This could reduce the habitat potential of the commonages and cause infringements of both habitat and birds directives.

Mr. Paul Dillon:

To answer Deputy Kyne's question about AEOS, farmers who are in AEOS have the option to transfer into the GLAS scheme. If they do they will be counted as part of the 50%.

Seán Kyne (Galway West, Fine Gael)
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Even if they do not, they are in an environmental plan and involved in environmental activity. Can they be considered towards the 50% pending transfer or whatever, but on the basis that they are in an environmental scheme?

Mr. Paul Dillon:

The answer as of now is that they cannot because they have not signed up to the particular collective actions that the GLAS commonage farmers would have. They are two different schemes.

Seán Kyne (Galway West, Fine Gael)
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It is going to be very difficult. There are a lot of people already in schemes, be it AEOS 2, AEOS 1 or AEOS 3. If the Department is waiting for them to go out and transfer this will be difficult. With the way GLAS is at the moment, farmers might decide to wait a year and see how this sorts itself out. If they are counted towards the 50% at least it will encourage other people to get into GLAS. They will not be tied down. I think it should be considered.

Mr. Paul Dillon:

I will note what the Deputy is saying.

On the question of the involvement by Teagasc, initially it said it was not going to get involved but subsequently it started a procurement process to contract out some of the work to do with GLAS. That is underway at the moment. Teagasc has told us it will have an arrangement in place to deal with GLAS. As I said, we met with Teagasc and the ACA both separately and jointly and we put all these questions to it in terms of capacity.

Éamon Ó Cuív (Galway West, Fianna Fail)
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The people who actually do these on the ground are telling us this is not practicable. The obvious thing to do is to get involved in the lowland because this is going to be so difficult to get agreement. We are not getting the same vibes as Mr. Dillon seems to be getting. I have to support Deputy Kyne on that.

May I ask a question to clarify what Deputy Kyne asked? What we were told was that if a farmer is in AEOS at the moment and wants to join GLAS, that he or she has to join GLAS on the same day as everybody else. If the five of us are in a commonage, and four of us decide to go into GLAS next year, and Deputy Kyne is in AEOS and has two years to run, if he wants subsequently to get into GLAS then he has to actually leave AEOS and join GLAS with two years to run on his scheme. That is what we were told. Is it the case?

Dr. Ronan O'Flaherty:

I will try to answer that for Deputy Ó Cuív. In regard to AEOS, as we have said, it is optional and not mandatory to come into the scheme. That is the first thing in terms of GLAS. Farmers can come in at the same time as everybody else, form part of the group, and they will get the full five years.

Éamon Ó Cuív (Galway West, Fianna Fail)
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One gets three years if one joins two years late.

Dr. Ronan O'Flaherty:

That is right.

Éamon Ó Cuív (Galway West, Fianna Fail)
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That is robbery.

Dr. Ronan O'Flaherty:

That is a situation where once the clock has started on the plan, because it is a five-year plan, people who join after the start date will only get what is left on the plan.

Andrew Doyle (Wicklow, Fine Gael)
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So, to clarify, they could get two years of AEOS, for example, and three years of GLAS.

Éamon Ó Cuív (Galway West, Fianna Fail)
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Better still, if the four members across the table were in AEOS and myself and Deputy Ferris wanted to join GLAS, they could refuse to tango with us. By holding us back two years they would get the five years.

Andrew Doyle (Wicklow, Fine Gael)
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I think that is where the commonage implementation committee would come in, if people were genuinely trying to get in.

Dr. Ronan O'Flaherty:

That is right, it would be a situation where through no fault on the part of Deputies Ó Cuív and Ferris, they could make a case to the committee that they could not get the 50% but they were anxious to start. They could say that they would like to start but the others would not come in. The committee would look at it on that basis and would presumably approve it.

Éamon Ó Cuív (Galway West, Fianna Fail)
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If the implementation committee ruled in our favour then the other farmers will be hung out by us and imagine the friends we will have in the mountains then. Those guys will lose two years because we managed to trump their blocking of us. Is the Department trying to start a civil war?

Andrew Doyle (Wicklow, Fine Gael)
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We are getting into the realms of speculation. The plan will only last for six years, so if people decide that they have three years left to delay us and they want to avail of five years, they will not get eight years, they will only get-----

Éamon Ó Cuív (Galway West, Fianna Fail)
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Why? It is n + 3 this time, is that not right?

Andrew Doyle (Wicklow, Fine Gael)
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We are getting into nitty-gritty that is not relevant. I would rather we moved on. There are more high-level concerns than speculating over rare events or scenarios. Dr. Smyth clarified the situation with regard to late entry to the scheme and the commonage implementation committee. Deputy Kyne asked a question about the continual reduction with regard to scrub. I honestly feel that if the auditors came over here and said "Hold on" and the Department said that it was trying to reinstate good vegetation management but was having difficulties with the National Parks and Wildlife Service concerning rules about burning, which is an effective tool for vegetation management, the auditors would tell us to get our act together.

Seán Kyne (Galway West, Fine Gael)
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It is not the scrub, per se, that one can see with a red line, it is that they deem the land not to be used, even though it looks like forage. It is scrubbing up, effectively.

Dr. Kevin Smyth:

There is evidence of land abandonment on some commonages, where there is no evidence of agricultural activity and no animals. The encroachment of scrub is also an issue. I can understand the point the Deputy makes about the need to maintain the forage area so that the payments can be maintained, but the inspectors are required to comply with the EU regulations. If the land is abandoned or there is scrub encroachment, the system must reflect that, and the land parcel identification system must reflect the state of the land. That is where the problem lies and the Deputy is right to state we do need more sheep on the hills. On that point the issue is activity.

Éamon Ó Cuív (Galway West, Fianna Fail)
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The Department took them off.

Dr. Kevin Smyth:

We have 12,000 farmers claiming mountain DAS and for 4,000 of them there is no evidence that they have any animals.

Éamon Ó Cuív (Galway West, Fianna Fail)
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The Department took them off.

Dr. Kevin Smyth:

We have seen a huge reduction in the number of sheep in the country. It is not down to destocking alone.

Éamon Ó Cuív (Galway West, Fianna Fail)
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Can Dr. Smyth give us the maps?

Dr. Kevin Smyth:

I can give the examples. I can give the orthos showing the encroachment-----

Éamon Ó Cuív (Galway West, Fianna Fail)
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Then we will be able to identify-----

Andrew Doyle (Wicklow, Fine Gael)
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We have another item to finish here. Although we had no commonage framework plans to destock where I come from, there has been a significant reduction. One of the things that has not been mentioned, and is probably not a phenomenon that worries people to the same degree in the west of Ireland, is dog-worrying. It is a serious issue. There are people in the Visitors Gallery who will empathise with that. It has been one of the problems that has deterred people. This relates less to recreational users but just loose dogs causing serious problems. That and some problems with vegetation management but one is as important as the other. There were no destocking framework plans in the hills in Wicklow and there has been a significant reduction for other reasons. We must address them all. If there is an overlap where there has been significant reduction or land abandonment on commonages where there were commonage framework plans for destocking, they must be reversed very quickly. If members are satisfied that the officials have got a fairly good flavour of what the key points are for us, we can move on. I could open this up again, but-----

Seán Kyne (Galway West, Fine Gael)
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The question relating to the habitats and birds directives was not answered.

Éamon Ó Cuív (Galway West, Fianna Fail)
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I would like confirmation of one question. Perhaps we should deal with Deputy Kyne's question first.

Andrew Doyle (Wicklow, Fine Gael)
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What was the question again?

Seán Kyne (Galway West, Fine Gael)
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The issue was that if one reduces the forage area, by definition one is stating that fewer animals are allowed on the commonage, thereby exacerbating the problem of the scrubbing up and impacting on the habitats. The forage area should be left intact but a requirement should be put in place that one must have a certain number of sheep, cattle, horses or whatever and prove that one has them.

Andrew Doyle (Wicklow, Fine Gael)
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The other thing is that the forage area should be at this level and part of the plan is to bring it back up to that level. If the forage area was 100 h and now it is only 75% of that, a GLAS management plan or a commonage management plan can bring it back up to that. That is part and parcel of what the plan is.

Seán Kyne (Galway West, Fine Gael)
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This is in relation to Pillar 1, this is the single payment.

Andrew Doyle (Wicklow, Fine Gael)
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It is the same thing, surely.

Seán Kyne (Galway West, Fine Gael)
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It is the same thing but it is-----

Andrew Doyle (Wicklow, Fine Gael)
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Is that not the key point here that actually the plan can bring it back to where it should be? To go back to what Dr. Smyth said, we are saying that this is a problem. We have identified what the percentage of the original 100% is and the plan will bring it back there.

Seán Kyne (Galway West, Fine Gael)
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Yes, but if maps or forms will be issued next March for submission in May under the single payment scheme and commonage has been reduced by 50% to 70% in that year, what impact will that have on future forage availability and on the habitat and birds directives? The Department will have another section of the Commission down on top of us when the solution is to maintain the forage areas as they are but force the farmers in those cases to up the stocking level.

Dr. Kevin Smyth:

In my time we have had numerous EU audits. I have seen problems with what they see as effective land abandonment and the growth of forage. They have never told me in all that time that we have a problem with the habitats and birds directives. As I said, habitats can be protected under the single payments scheme. One simply puts it down as a habitat and it will be respected as such. The difficulty I have here is that scrub is not biodiversity.

Andrew Doyle (Wicklow, Fine Gael)
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It is a nuisance.

Éamon Ó Cuív (Galway West, Fianna Fail)
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Can the representatives of the Department confirm that what they are saying to us today is that each individual farmer who does not stock the commonage will not be entitled to single farm payment, areas of natural constraint payment or GLAS payment on that land? Can they confirm further that sheep would be the required animal on mountains going up to 2,000 feet, so that it will not suffice to throw cattle on the low land? That is a very important point. Have they done a calculation as to the loss of income that will occur on the commonage areas in the counties of Galway, Mayo, etc., due to the fact that if certain farmers continue not to stock the commonage because it makes it unviable, it would effectively double their single farm payment or they are not going to get the lift that the witnesses are talking about? It will become a mirage, like many things are becoming in the hills, and they will lose also the areas of natural constraint, ANC, payment and they will be locked out of REPS, which they would have been getting. Have they done a calculation on the net loss in the hill areas of this collective suite of measures? It seems to me that they are not for turning.

Dr. Kevin Smyth:

Different species of animals are suited to different areas of commonage, as the Deputy knows. It could be cattle, ponies or sheep; it is down to the individual commonage plan. Generally, it is sheep, but it can be other species also. As the Deputy knows, all these livestock-----

Éamon Ó Cuív (Galway West, Fianna Fail)
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Do they have to graze the whole commonage? That is what we were told.

Dr. Kevin Smyth:

How much of the commonage is being claimed? As I said, in certain cases 10% or 20% of the commonage is claimed.

Éamon Ó Cuív (Galway West, Fianna Fail)
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The problem with a commonage is that everyone claims his or her share of the total. No farmer has a right to say he or she has a claim over an identifiable part. It may be 100th of the total. Therefore, he or she is claiming to the top of the mountain. I do not want people bitten in the bum by small things, as they were with the LPIS. Does Mr. Smyth believe the Department credibly believes one is putting cattle up to the top of the mountain?

Dr. Kevin Smyth:

As I said, what we need here is a credible commonage management plan that shows how the commonage will be brought back into GAEC and the number of animals required. We are not setting minima and maxima – we said that – but we wanted the people to work with the commonage implementation.

Éamon Ó Cuív (Galway West, Fianna Fail)
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I am talking about the single farm payment.

Dr. Kevin Smyth:

The Deputy is absolutely right about the level of breeding of animals. This will not be done overnight. It is a long-term process but if we do not see increased activity we will have problems. What we are examining is a flat-rate disallowance on all farm payments. I refer to the €1.5 billion. A flat-rate percentage could be taken off.

Éamon Ó Cuív (Galway West, Fianna Fail)
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Has the calculation been done allowing for the net effect based on farmers' practices? As Mr. Smyth says, all sorts of photographs are taken so the Department will be keeping track of who has what on the hill. If the farmers who do not currently put stock on the mountain, who comprise approximately 50%, are all put out of the schemes, what will be net loss to the economy in the relevant areas as a consequence?

Dr. Kevin Smyth:

I do not have that figure but I can give the Deputy another figure.

Éamon Ó Cuív (Galway West, Fianna Fail)
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Approximately €17 million.

Dr. Kevin Smyth:

I will give the Deputy another figure. There are 15,000 commonage farmers. They will gain €3,141 per head through convergence.

Éamon Ó Cuív (Galway West, Fianna Fail)
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They will not.

Dr. Kevin Smyth:

They will.

Éamon Ó Cuív (Galway West, Fianna Fail)
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I want to explain.

Dr. Kevin Smyth:

If we get this right, an extra €3,141 will be available on average.

Éamon Ó Cuív (Galway West, Fianna Fail)
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No. The reason-----

Andrew Doyle (Wicklow, Fine Gael)
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Sorry, I know exactly what Deputy Ó Cuív is going to say.

Éamon Ó Cuív (Galway West, Fianna Fail)
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What am I going to say?

Andrew Doyle (Wicklow, Fine Gael)
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He is going to say that if people do not get the full benefit-----

Éamon Ó Cuív (Galway West, Fianna Fail)
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They do not get any benefit.

Andrew Doyle (Wicklow, Fine Gael)
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It comes back to a basic point. I outlined for consideration before I went back to the original questions the question of a basic payment scheme requirement of one per 1.5 hectares where somebody involved in a GLAS commonage plan nominates somebody else to take care of his or her requirement on the commonage according to a system whereby the commonage is held in an enhanced position beyond GAEC. By this system, the farmer would still have met his or her responsibly. I do not know whether that will fly with Europe but that is basically the key point if it is the case that somebody has to be active. It comes back to the signing of an agreement, which is rather different from somebody claiming somebody else’s entitlement saying he had a certain number of sheep on the commonage while his neighbour did not, and that he is going to continue in this regard. Signing makes people sit down and agree with one another. It will be difficult but I do not foresee any easy solution.

We cannot continue on this any longer as it is 4.05 p.m. and we must deal with organic farming. I ask members to remain here for ten minutes. I thank Dr. Smyth, whom I understand has to leave.