Making the CAP Fit

Recently I facilitated a group of farmers from the Irish Natura and Hill Farmers Association (INHFA) to come to Brussels, to once again engage with Commission officials on the contested issue of land eligibility for CAP payments.

As the conversation and discussion continued between both parties, and having met DG Agri officials on several occasion, it is clear there are two issues to be addressed, the solution to both of which lie not in Brussels but at home. These are:

1.            The current implementation of the existing scheme in its flawed fashion;

2.            The unwillingness of the Minister and the Department to face up to past mismanagement and mistakes which is preventing a long-term strategy being put in place.

Regarding the first point:

The Department produced an information booklet for farmers setting out the terms and conditions of the schemes, yet the training note for inspectors released after a request from farmers indicate a different interpretation of the rules.

For the highly contested issue of eligible land the booklet for farmers refers to Article 32      Regulation (EU) No 1307/2013 which sets out the principle that Natura 2000 lands which were eligible for payment in 2008 should still be eligible for payment.

It is astonishing that this important principle is not the first item in the training note for inspectors. This should set the base-line for the inspection – what is the background on this land? Is it working under a restriction?  It barely gets a mention, the focus being on the vegetation cover on the ground, ignoring the fact that farmers on these lands are restricted in the stock they can carry. This copper-fastens the belief amongst farmers that despite assurances from Dept officials during meetings, in reality the inspectors on the ground are working to a different agenda.

Other concerns regarding the training note is that no mention is made of the timing of the inspections; farmers reported that lands were being inspected in winter, a time when molinia grass naturally turns white and stock are off the hills, with findings then being made of no evidence of growth or agricultural activity – a foregone conclusion, as anyone with a screed of sense would know.

Of fundamental concern also is the vague definition of what constitutes grazeable forage, subjective decisions made regarding heather heights without any scientific justification.

In relation to the second point;

The current situation has its roots in the action taken by the EU against Ireland in relation to breaches of the Birds and Habitats directive in 2002.  This prodded the Dept out of their inertia to address the issue, but rather than consult properly and implement a workable solution on Natura lands, they adopted ablunt approach of a 30% destocking across all commonages designated or not. Commonage Management Plans were drawn up limiting the number of stock the farmer could graze on commonage. Despite undertakings given at the time to review the CMP and stocking rates, which even at the time were clearly unsuitable as not all hills were overgrazed, these commitments were not honoured and an initial unsatisfactory situation was allowed to stagnate, even deteriorate.

The starting point now must be that all land restricted under the CMPs must come under the protection of Article 32 of 1307/2013. It is deeply unfair that lands outside the Natura 2000 designation but still being constrained under the same regulation are now being deemed ineligible through perceived inadequate stocking rates. It goes against all natural justice and fairness that farmers who complied in good faith with a Department-imposed solution should now find themselves penalised for doing so.

In looking for solutions to this we do not need to reinvent the wheel; the “Burren Life” project which is highly regarded internationally is an example of what can be achieved.

This should be the template for our Department and the work should start now, with a lead-in time of three years to the next round of CAP.

The choice is clear: Do we want a living countryside providing the public goods that benefits wider society, the most important element here being the retention of people and families to underpin local communities, or is the aim a depopulated landscape of monoculture forest interspersed with abandoned farms?