Suckler farmers should only have to join the Bord Bia Sustainable Beef and Lamb Assurance Scheme (SBLAS) on the scheme’s “own merits” rather than being forced to under the proposed Suckler Carbon Efficiency Programme.

That’s according to the Irish Beef and Lamb Association (IBLA), which made the comment in its submission for the Common Agricultural Policy Strategic Plan (CSP) consultation.

In its submission, the association highlights that SBLAS is currently a discretionary scheme “and should remain so”.

“The attractiveness of joining SBLAS should be sufficient in its own right and on its own merits to encourage farmers to join.”

“Farmers should not be required to be a member of SBLAS,” the IBLA stressed.

In general, the IBLA welcomed the proposal for the new suckler scheme, but stressed the need for some changes to the current plans.

The association says it “fundamentally objects” to the proposed capping of the number of cows permitted to be kept on a participating holding.

It argued that stocking rates as outlined under the Nitrates Directive in terms of manure nitrogen (N) per hectare should be “the only limiting factor that should apply to the number of animals that can be kept on a farming enterprise”.

In terms of how the reference year under the scheme is established, the IBLA believes the year should be chosen by the participant from a range of recent years nominated by the Department of Agriculture, Food and the Marine.

The IBLA proposes that, once the reference number of animals is established, payment would only be made on this number only, with no additional payment for cows over this figure. However, the animals over and above the reference number would still have to be farmed to the same environmental standards.

In regard to other interventions under the 2023-2027 CAP, the organisation calls payments through the Basic Income Support for Sustainability (BISS) – the proposed follow-up to the Basic Payments Scheme (BPS) – in excess of €60,000 should have the that excess reduced by 85% – the maximum reduction possible under the CAP agreement.

As well as that, the group calls for the removal of a “loophole” that may allow “both paid and unpaid” labour costs to be used to offset capping.

On convergence, the IBLA is calling for full (100%) convergence of payments by 2026 – i.e. that all payments below the national average are brought up to that level – rather than the minimum 85% level outlined in the CAP agreement.

The association’s submission also calls on the government not to seek to reduce the portion of Pillar I that will be paid to smaller farmers through the Complementary Redistributive Income Support for Sustainability (CRISS) below the agreed 10%.

On eco-schemes, the IBLA said it was unable at this time to make a recommendation, as there was no specific detail yet as to how and eco-scheme might look, something the group described as “disappointing”.