Among the concerns ICSA Ireland, the Irish Cattle and Sheep Association has raised in its submission on the Rural Development Programme 2014-2020 was its provisions for the sheep sector.
In an extensive submission examining the new programme, the organisation claims its consultation with its members has brought to light a consensus that sheep farming in Ireland has been generally overlooked as part of the Common Agricultural Policy Reform process.
It stated: “The incorporation of the Sheep Grassland Scheme (SGS) payment into the Basic Payment is an additional significant concern. This change will immediately bring many sheep farmers towards or above the national average payment, thereby effectively eroding any benefit low payment farmers might have seen through internal convergence and minimum payment while their SGS payment remained as a discrete sum of money on top of their single farm payment (SFP).”
According to ICSA Ireland: “Farmers currently near the SFP average will be driven above it and as a consequence see their SGS payment effectively diminished as approximation comes into play over the coming years.”
Other key overarching themes of ICSA’s submission relate to appropriate targeting of rural development funds, simplification of application and record keeping, cost implication of capital measures, equitable division of sectorial budgets and focused measures for suckler and sheep farmers.
In the document the ICSA welcomed the scope and objectives of the Beef Data and Genomics Programme (BDGP), despite having concerns over the proposed payment levels.
It says: “There have already been significant discrepancies in the quoted prices for genomic testing. These will need to be standardised to the lowest level possible prior to the initiation of the programme so that the calved cow payment will not be overly diluted through associated testing costs.
“There is some concern amongst farmers that the BDGP may involve onerous record keeping in relation to calf events. ICSA is advocating the department ensure the level of bureaucracy required as part of the programme be kept to an absolute minimum. ICSA also proposes that the BDGP budget is ring-fenced,” it added.
On the area of on farm capital investments a key concern raised by ICSA relates to the equitable distribution of capital investment funding amongst all the agricultural sectors. The ICSA proposes that the overall TAMS II budget should be delineated into sectoral sub-budgets at the initial stage, which should then be maintained according to their relative proportions throughout the entire period of the RDP.
It said: “Doing so will ensure that the overall budget is not depleted by any single sector, to the disadvantage of other sectors. There is a specific concern that the abolition of dairy quotas in 2015 will lead to a significant demand for milking, storage and cooling infrastructure which could lead to a disproportionate number of dairy producers applying for grant funding under TAMS II.”
Budget cuts in relation to areas of natural constraint was also a key issue for the ICSA. It highlighted concern at the impact of cuts to the Less Favoured Areas budget from and allocation of €257m to €190m in a relatively short timeframe.
The organisation said: “While all cuts are regrettable, the impact of these cuts is particularly severe on low income drystock farms (typically sucklers and sheep) especially, but not exclusively, on very marginal land in the west of Ireland.”
ICSA welcomes the fact that the proposed GLAS scheme appears to be more comprehensive and ambitious than AEOS. However, ICSA highlighted a number of concerns surrounding certain aspects of the scheme.
In relation to the GLAS scheme the core concern for the ICSA is the record-keeping requirement. The ICSA is advocating any bureaucracy required as part of the scheme should be kept to a feasible minimum.
Also in relation to consultancy required for drafting up nutrient plans and environment measures, ICSA’s has noted concerns regarding possible ‘Teagasc-centric’ advisory services.
It said: “The department must ensure that private farm advisors are not discriminated against by the structuring of advisory requirements for GLAS. Furthermore, the overall cost to farmers requiring advisory services for GLAS must not be perceived as prohibitive.” ICSA also advocates that farmers should be able to make GLAS applications electronically when feasible.
The ICSA concluded its submission by noting: “There is significant potential that a well thought-out and implemented Rural Development Programme has for ensuring agricultural competitiveness, sustainably managing natural resources and providing balanced territorial and economic development in rural areas.”