Convergence and flattening of payments

The INHFA remains committed to 100% convergence (flattening) of the new Basic Income Support for Sustainability (BISS) payment. This can be achieved over the lifetime of the CAP Programme and will ensure that all farmers who are subject to the same standards and requirements under GAEC conditions are treated equally in terms of payments and supports.


The INHFA are seeking a fair uniform payment per hectare with equal access for all land and farm types. It is vital that any land which qualifies for the BISS payment will be available for the eco-scheme. If the eco-scheme accounts for 25% of the Pillar 1 budget then we estimate the payment available for the eco-scheme will be in the region of €67/ha. This should be available on every hectare from the commencement of the new CAP. All farmers should have adequate opportunities to avail of an equal payment per hectare.

Front-loaded payment

Under the new CAP there is the opportunity for Member States to provide for an increased Complimentary Redistributive Income Support for Sustainability (CRISS). It is dependent on the Member State providing a budget of substance and will we maintain require at least 6%
of the Pillar 1 budget. This payment should be made on the first 10 hectares and possibly up to the first 20ha depending on the final budget. There has been a good deal of discussion on the possibility of farmers on small holdings on high value entitlements loosing out under convergence. This option can help protect those farmers.

Capping of payments

Proposals to cap the BISS payment at €100,000 while also allowing for labour units and no limits on any eco scheme is farcical. In addition to this, it undermines future CAP budgets as the non-farming media, highlight excessive payments to a tiny number of farmers. This doesn’t play well with the general public across the EU who’s taxes are needed to fund the CAP budget. The INHFA are proposing a very generous limit of €60,000 for all Pillar 1 payments with no allowance for labour units.

Pillar 2 Schemes

The INHFA are seeking a commitment from the Government to deliver a substantial increase in the overall Pillar 2 budget. Any new budget should average at least €750m each year (currently €590) which even then will only bring us back to the levels we were at for the 2009-14 period. With a budget of this size we can substantially increase both the ANC and Agri-Environmental supports, double the supports in the sheep welfare scheme and put in place supports for our suckler farmers paying at least €200/cow. Commonage Lands and Privately Owned Mountain Type Lands Currently access to the pilot REAP scheme is not available to farmers on commonage lands and privately owned lands with heather, which is a blatant discrimination. In the next Agri environmental Scheme we must have an extension of the current GLAS Commonage Management Plan (CMP) action where sustainable stocking rate figures (Min- Max) have been determined by DAFM for all commonage shareholders. In recognizing the unique farming systems that operates on our commonages it is also vital to recognize that each farmer operating these lands are individuals. Suitable measures must be available to Private Mountain type lands within all future Agri Environmental Schemes.

Active Farmer

In relation to defining an active farmer it is concerning how some of the proposed definitions outlines details of income tests and production assessments that could exclude part-time farmers from CAP payments. This cannot happen.

Natura 2000 lands

On Natura 2000 lands (SAC & SPA) which based on the EU’s Nature Fitness Check are delivering between €2-3bn annually to the economy the total annual payment through GLAS of €6m is insulting and must be addressed in the new CAP. Article 67 allows for a specific payment on these lands and we are calling for a payment of €150/ha on all Natura lands in recognition of the burden that has being imposed on them. This payment should be seen as separate to any management payment which can be made through an agri-environmental

Generational Renewal

It would be important that a Farm Retirement option would be available in circumstances where a clear farm succession plan would be put in place. This is a critical component if we are to have young talent enter farming.