Dear Minister Creed,

I write to you to bring to your attention the implementation of the GLAS scheme, with a particular emphasis on the unfolding situation regarding farmers on Commonage lands.

The inability of your department to put in place structures to deliver vital Rural Development funds to where they are most needed exposes the lack of vision and policy direction within the Department and demonstrates indifference to our most vulnerable farmers.

There appears to be a deliberate policy of delay and procrastination culminating in the usual tactic of 11th hour rush to sign documentation without proper information being made available and explanation given.  

The reports we are getting of farmers being asked for upfront payments from both Teagasc and private planners in order to have their “interim Commonage Management Plan” submitted, which is essentially a box ticking exercise, leaves the impression that GLAS is seen as a “cash cow” for Planners and semi state companies rather than a support for farmers to deliver environmental goods.  This is far from the ideals of the rural development plan as set out in EU Regulation 1305/2013 which has at its core encouraging environmentally sustainable farming practices while maintaining rural populations.

A further aspect of concern to us, is reports that when farmers contact your department requesting to change their planner they are refused this.  Is it a policy of your department to favour Teagasc over private planners?   It is unacceptable that individuals who are paying for a service cannot take their business elsewhere if they are dissatisfied with the service they are receiving.  It is this issue that is causing much dissatisfaction as farmers were of the impression that their Teagasc planner would be completing their commonage plan.  They are now finding that the plan will be done by an outside contractor on a short term contract that will leave them with no support and back up should problems arise.   It is recognized that on commonages where there is no agreement between shareholders a planner may have to be appointed but where shareholders are in agreement they must have the right to choose their planner and change their planner if they so wish within the terms of their contract.

The question could be asked why did Teagasc tender for the contract and why did the Department award them the contract when it is now clear that they do not have the necessary staff to undertake the work as they are subcontracting the work out.

 In relation to specific queries can you confirm?

  • Are up-front payments required by planners to submit an “Interim Commonage Management Plan?”

  • Where all the active shareholders are in agreement on a commonage do they have the discretion to appoint their own planner, and change their planner if they wish, within the terms of the contract?

  • The latest circular received by planners stipulates that for commonage to be a “priority asset” and be paid for in GLAS 3 the farmer had to have had the commonage in his 2014 BPS application.  This appears to be a discrimination against commonage farmers, as for other land types a leasing agreement beginning at the start of the five year program is sufficient to be eligible for payment.  What is the reason for this?                 

I would ask you to address these matters as a matter of urgency.  These issues matter greatly to Ireland in the context of defending our CAP budget.  I am a member of the Budgetary control Committee in the European Parliament which scrutinizes all expenditure.  The CAP budget which account for approximately 38% of all EU expenditure comes under particular scrutiny and quite an amount of criticism from other sectors.  We have to be able to defend our action and programs and demonstrate best practice and value for money   

In the implementation of aspects of the GLAS scheme some of the practices being employed lack transparency and fairness, in addition the percentage of the fund being swallowed up by administration appear excessive resulting in much less support for the intended recipients.

I look forward to your reply.

Best Regards,