Ms Helen Scully:

We will deal with the salient points in the 2015 report on the organic farming scheme and the issues which seemed of prime importance to the group which presented its findings in respect of that report. The Organic Trust is of the view that a streamlined approach to payments ought to be adopted to ensure that organic farmers can realistically expect to be paid within predefined periods in each calendar year and that payments are accompanied by a detailed statement outlining the formula for payment in each case. This will facilitate properly informed checks being conducted by organic operators so that issues of under or overpayment can be readily identified. This will also promote significant efficiencies within the organic unit as it will considerably reduce the number of calls from organic operators who are in receipt of payment and endeavour to establish the accuracy or otherwise of their own payment. Currently, farmers are not presented with a detailed breakdown and this has resulted in a high degree of confusion for the organic operators.

In addition, we feel that where delays in payment are envisaged as a result, for example, of an inspection from the Department or issues relating to GLAS or other schemes, these should be communicated to the operators concerned and the likely anticipated delay in payment should be indicated.

We suggest that a payment tracking system be established for all organic farming scheme, OFS, participants. In common with all businesses, we feel that organic farmers must budget for their activities, and delays in payment can have a detrimental effect on their activities.

The Organic Trust has also expressed concern regarding IT difficulties that have been identified around payment provision for operators or participants in the OFS and GLAS. On behalf of our members we would like to emphasise the urgency of addressing those issues so that delays in the potential clawback of moneys paid is avoided. One of the recommendations we have made in respect of GLAS is that a consultation process be established around the synergy required between GLAS and the OFS, particularly around the double funding issue that primarily affects organic farmers under the 20 ha size farm. There are various suggestions for addressing this issue such as front-loading payments etc. This consultation process would take place between the organic certification bodies and strategic members of the Department to address those issues.

Another point raised by the report was a request that Bord Bia take over the organic certification process. Austria was used as a model of best practice. The legislation underpinning organic farming was first published in 1992.  At that time, each member state was given a choice regarding the method of organic certification to prevail. Three choices were given, system A, B or C. System A was private organic certification bodies and the approval of those, system B was designated public control authorities, and system C was for a mix of both systems. Ireland chose system A, as did the majority of EU member states at that time. Three organic certification bodies were approved in 1992 - the Organic Trust, the Irish Organic Farmers and Growers Association and Demeter. Since then two further bodies have been approved to operate in Ireland.  It is important to note that system A, the private certification bodies system that prevails in Ireland, is also the system adopted by Austria, which was mentioned as having an organic certification system of best practice. It is important to state that there are eight such bodies operating in Austria at this time.

In common with the previous presentation, the Organic Trust agrees that creating a monopoly in any area has never resulted in a reduction in costs or the raising of standards. We believe it has had the opposite effect. The presence of more than one organic certification body ensures the maintenance of high standards of organic production on which the consumer depends. Most economists would agree that competition in the marketplace generally leads to higher standards and lower costs.

The role of the organic certification bodies is specifically stipulated in the organic regulations, in ISO 17065, to which organic certification bodies, OCBs, must be accredited, and in the service agreement between the organic certification bodies and the Department of Agriculture, Food and the Marine. Changes to the organic standards are based on legislative change or as a result of clarifications of interpretation decided at meetings of the organic forum to which all the OCBs are party. Such issues of interpretation can also be challenged by auditors such as the European Commission's Directorate General for food and health safety, DG SANTE, which can determine that Ireland's interpretation does not match EU requirements. The OCBs have no discretion regarding the implementation of the subsequent legislative changes to the standards.

The organic certification fees charged by the Organic Trust are set by the board of management each year following an examination of the costs involved in providing the service. The fees charged in Ireland compare very favourably with fees in other member states.  In some cases the fees charged are lower and in other cases fees are constructed differently. The two main organic certification bodies in Ireland are not-for-profit organisations, and this significantly benefits the members. We are of the view that the fees charged are very reasonable given the depth of service that must be provided. We do not link the schedule of fees to OFS payments because Government schemes come and go and the amount of Government aid can change at any given time. In the Organic Trust, every organic operator who is inspected incurs a fixed cost for the provision of the service. After that, the board of management examines the expenses that were incurred in providing the service and allocate the costs as evenly as possible across the membership. Any excess funds, after the payment of all expenses, is reinvested in the organisation and added to the prudent reserve. A detailed review of the fee schedules to prevail in every calendar year takes place.

Reference was made to the requirement to adopt a risk-based inspection regime in Ireland. It is important to state that this is already enshrined in organic sector legislation and is already taking place. It requires that every organic operator is subject to at least one annual scheduled inspection and there are legislative requirements for further prevention inspections over and above the current inspections. Organic licences are issued for a maximum 12-month calendar year period to comply with departmental and regulatory requirements.

On organic regulations, it has been suggested that the model of best practice in Austria was operating to a lower organic standard than that operated in Ireland. When organic livestock production was first legislated for on 24 August 2000, opportunities were available through communications with the organic development committee at that time to establish the level of service to be provided. On publication of that very comprehensive report, it was agreed that there would be five issues of difference where a higher standard would prevail in Ireland for a range of commercial reasons to do with the export market situation at that time, to which organic operators were trying to get access. It is important to note that now, in 2017, there is only one area of difference. This relates to the origin of livestock. In Ireland we do not allow non-organic livestock to convert to organic meat. It is very important to note that this standard alone has resulted in Ireland being offered overseas contracts for organic meat because it was considered best in class when considered through a tendering process in common with all the other organic operators throughout the Europe who had tendered for those contracts. It is important to know that it is just one area of difference now.

There were other issues indicated in the 2015 report on the organic farming scheme. Time precludes me from going into these in detail but we have submitted a written response.