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.