The Irish Natura and Hill Farmers’ Association (INHFA) has written to Minister for Agriculture, Food and the Marine Charlie McConalogue to highlight its concerns over Common Agricultural Policy (CAP) reform.

At the centre of the association’s concerns are the Good Agricultural and Environmental Conditions (GAECs), specifically GAEC 2.

The INHFA fears that this GAEC, which deals with peatlands and carbon-rich soils, would undermine farming activity on this type of land.

In the letter, INHFA president Colm O’Donnell wrote: “Under the proposals in the new CAP programme, farmers operating on these lands will be required to comply with a new GAEC 2 that threatens the agricultural status of their lands.”

The letter says: “GAEC 2 identifies peatlands and wetlands as important environmental assets that must be protected.

“While the three main parties in the CAP process [the EU Commission, parliament and Council of Ministers] have specified their individual wordings, it is clear that farmers will be expected to undertake measures to protect these lands and their carbon asset.

O’Donnell noted that these measures have not yet been specified or agreed.

“However, proposals by the Council of Ministers to introduce a derogation that allows for farmers to be paid in the event of the GAEC 2 undermining farming activity and the agricultural area status of these lands is a major issue for us.”

The INHFA says it is “unacceptable” that GAEC 2 could be used in a manner that could remove these lands from being defined as “Agricultural Area”.

“If this happens then future CAP payments on these lands will be jeopardised because the basic entry requirement to access various schemes requires these lands to be defined as an Agricultural Area,” the INHFA letter argues.

O’Donnell told the minister: “Make no mistake, farmers and their farm families have managed those lands for centuries and are crucial to managing these lands from both an agricultural and an environmental perspective and they will deliver positive outcomes, but not if our very ability to exist is being threatened.

The letter went on to quote the Programme for Government, noting that it said the government will “advocate for a fair system of eligibility conditionality, under the reform of [the GAEC] rule”.

“Currently, the ongoing CAP negotiations threaten future payments for farmers on these land types and goes against the principles outlined in the Programme for Government,” the letter stated.

It concluded: “As we approach the centenary celebrations of one hundred years as an independent state, we are asking for a commitment that you as our minister and the government will not allow or provide for any potential separation of our lands to be facilitated in CAP negotiations.”