Charlie McConalogue (Donegal, Fianna Fail)
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The objective of the €1.5 billion ACRES scheme is to improve environmental performance on farmland, including commonage.

In this context, my Department is obliged to ensure that the scheme meets its objectives, but also to ensure that applicants are treated fairly when it comes to scoring of environmental performance.

The original proposal in relation to the scoring of turbary areas was to have it applied and included in a single score for the entire commonage parcel.

Farm representatives brought their concerns to me, before any scoring of commonages took place, that this could disproportionately impact on the score of an overall commonage parcel.

It is against this background that my Department, in conjunction with the ACRES Co-operation Project (CP) teams, put a protocol in place that mitigated the negative impact that turbary would have on commonage scores.

The protocol provides that areas of active turf cutting, together with appropriate buffer area, are scored separately to areas of peatlands without turbary. The blending of these separate scores limits the potential impact of turbary on the relevant commonage parcel score.

The buffer area was applied to take account of the negative impact of active turbary on adjacent peatland hydrology. Without this zone, the environmental integrity of the scheme, and therefore the justification for substantial EU and national funding, would be undermined.

The buffer area is included in the turbary field, but is not itself differentiated from the active turbary area. In addition, the buffer area will often incorporate adjoining areas of turbary activity where a mosaic pattern of activity is evident on the relevant commonage parcel. This again helps to mitigate the impact of the turbary area on the commonage parcel score.

It is also very important to note that a farmer's payment under ACRES is made up of several different elements, in addition to the scoring of commonage lands, including farm size, actions chosen, and scores obtained on other, non-commonage, lands, which will not be impacted by the arrangements described above.

Commonage parcels with turbary have been fully scored and submitted by CP teams on this basis of this protocol. Recently farmer representatives have raised concerns with me about how the protocol applied to the turbary areas will affect the overall commonage parcel scores.

While it is difficult to be definitive at this point, because my Department is continuing to process the relevant data, my Department’s judgement is that this system will not have a significant overall impact on the payments received by commonage shareholders, although there may be some exceptions.

Overall, the objective of the approach taken has been to strike a reasonable balance between the need to protect the environmental integrity of the scheme, meet European objectives in relation to the CAP Strategic Plan, and the need to ensure that commonage owners are treated in a fair and proportionate way for effective environmental action.