There is anecdotal evidence that Department inspections on commonages and marginal lands are leading to significant reductions in the eligible areas of these lands for BPS and other area based schemes, according to Agriculture Consultants Association President Tom Dawson.

However, he said, there is a more widespread problem due to the number of active farmers in commonage areas reducing significantly over the last 10-15 years.

Dawson said since the completion of Commonage Framework plans (CFP) over 10 years ago, the number of sheep grazing these lands has reduced substantially – mainly due to enforced destocking prescribed by said CFP’s.

“This combined with the ageing profile of hill farmers has led to a decline in the active management of these commonage lands.”

Lack of clarity

Dawson also said there is a lack of clarity from the Department in terms of agricultural activity that maintains commonage and marginal lands as eligible lands under the Basic Payment Scheme.

He said the terms and conditions to the scheme stipulate that “In the case of commonage, the activity must be carried out by at least one of the applicants” and that “areas ungrazed due to low stocking rates, areas of ungrazed mature heather, areas of intense rush or ferns and inaccessible areas” are not eligible for payments.

Tom Dawson

ACA President Tom Dawson


“More clarity is required for ACA advisors in order to properly advise our clients on the level of activity required on these hills,” he said.

Advisors, he said, need to be made aware of the exact criteria that are used to assess commonage and marginal lands.

“When advising clients, our members must know the criteria the Department use to assess eligibility so that we can then advise our clients on how to manage the activity on commonage to ensure eligibility.”

Dawson also said the ACA believe that advisers should be trained in conjunction with Departmental inspection staff to ensure consistency.

ACA also submit that a standardised inspection process should be drafted in conjunction with stakeholders.