While welcoming recent changes made by the Department of Agriculture on land Eligibility following representations made by the Irish Natura and Hill Farmers Association.The organisation still believes clarity is needed on land Eligibility guidelines.This clarity is required so farmers can fill out their Basic Payment Applications clear in the knowledge that penalties will not be applied in any subsequent inspection.
With regard to proposed changes on the implementation of Article 32 of EU Reg 1307/2013 for Natura (designated) land, INHFA CAP Chair Colm O Donnell stated that “the regulation is clear in that all lands that gave right to payment in 2008 remains eligible for payments today”
Presently it would seem that the Department are interpreting this in a different manner that could see some of these lands remain ineligible. This comes despite the fact that the designation may have caused that land to become ineligible prior to 2008.
For Commonage farmers it is still not clear if the appointed planner for the Commonage Management Plan will also determine the Maximum Eligible area for these farmers Basic Payment.
Mr O Donnell stated that “this issue remains a concern especially as these Plans may not be completed until the Autumn which will leave farmers in a difficult position when filling out their Basic Payment Application”
Mr O Donnell added that “Commonage farmers need to work with their individual planners and the appointed Commonage planner to ensure boundaries are correct and ineligible features such as roads, bare rock, streams and lakes are deducted for the claimed area in their 2016 application”.
Mr O Donnell concluded by stating how “Ireland had chosen the option to define heather/molinia dominated forage areas as permanent grassland under established local practices and as such then these farmed areas are fully eligible and it is important the department clarifies this”