Policy

INHFA Policies

Nature Restoration Law

The Nature Restoration Law has been developed following a recommendation in the EU Biodiversity Strategy around the need to protect nature and land areas with a high carbon content.

The law will provide for legally binding EU nature restoration targets to restore degraded ecosystems. Of particular interest are those systems that could contribute most to the capture and storage of carbon. In Ireland, this will apply to Annex 1 Habitats which are predominately peatlands based – blanket bogs, raised bogs (including farmed areas), cut away bogs, and drained farmed peatlands

These legally binding targets are a drastic step up from the existing designations where landowners are often prevented from carrying out further actions as they need permission from State Bodies. Under this proposal landowners (in addition to these restrictions) will also be expected to deliver on restoration targets.

READ THE FULL DOCUMENT

Areas impacted and what will be required

The areas impacted will include our wet and dry heaths that cover most of our upland areas which are currently being farmed with other likely areas to include sandy banks, machair grasslands and Molinia meadows.

Drained-farmed peatlands in lowland areas are potential Annex 1 areas that could be re-established through rewetting.

Most of the focus has been on the rewetting of drained peatlands which was covered under Article 9 of the Law. However, the restoration and re-establishment of these Habitats is the most significant element and has gone largely unnoticed.

Here there is a requirement “to improve to good condition Annex 1 habitats, in order to reach favourable reference area”

There is also a proposal to put in place restoration measures necessary to re-establish Annex 1 habitats. This will include drained farmed peatlands (reclaimed boglands) which will involve rewetting.

Currently, there is 670,000ha of Annex 1 habitat and 620,000ha of land that was previously an Annex 1 habitat

Funding Options & Requirements

While various drafts of this law outline the need for funding there is no specific budget allocated. Under EU Parliament Proposals (Article 11, 2a) details how CAP or other agricultural funding can’t be used as a funding source. However, Article 18,6(a) d refers to funding gaps and uses the words “where appropriate” funding should be provided.

The original Commission proposal detailed how Member States SHALL when preparing their plan take account of ecological, economic, and social functions.However, under the Council of Ministers text which was also adopted by the EU Parliament SHALL has been amended to MAY. This gives Member States the opportunity to renege on funding. 

In relation to funding, there are two elements to consider.

First is the direct cost associated with restoring and re-establishing habitats. This will vary depending on the site and work. However, based on a restoration project in the Brecht Reserve in Belgium the cost to re-establish 570ha of heath came to almost €5m (€8771/ha).

The second element relates to the ongoing funding of farmers/landowners and if farmers are covered beyond the cost associated with carrying out the necessary actions for restoration/re-establishment. i.e. will it be for measures or for loss of income or will any possible funding even cover the landowner’s cost of implementing the law?

Farming activity and CAP payments

Firstly, we need to recognise that CAP payments are only made on land that is an agricultural area. Unfortunately, this Law only recognises these Annex 1 Habitats as ecological areas so there is no guarantee that land subject to this law will be entitled to any CAP support.

Beyond the challenge around CAP supports, Article 12 m of this law calls for an indication of subsidies that could negatively affect the targets and obligations set out in the law

Taking both of these together we create a catch-22 in that, if farmers don’t follow the law their CAP subsidies will be pulled and if they implement the law as required their lands won’t be eligible for CAP Subsidies.

 

What needs to happen

With a policy position from the EU Commission, EU Parliament, and Council of Ministers on Nature Restoration there will be a final law agreed on Nature Restoration later this year.

While we would have preferred to have seen a full re-negotiation of the law we are now looking to have critical amendments included that will help protect our farming way of life that has supported communities while also delivering for nature.

On this basis, we are targeting amendments to have High Nature Value Farmland recognised as a habitat with an ecological status. This can provide a level of protection for most of the lands that will be subject to this law. It will also enshrine current farming activity as a necessary mechanism for protecting these farmed habitats.

A team of INHFA delegates traveled to Brussels to meet the Irish MEPs to outline the devastating consequences the Nature Restoration Law will have on traditional farming practices if implemented in its current format. The INHFA will continue to lobby for amendments to the Law that will protect our farmlands.

Suckler Sector

Recent media reports that outline how the suckler sector will need to reduced further in order to meet our Climate Change targets has angered a lot of suckler farmers especially as other sectors of agriculture continue to expand.

This anger has also been clearly expressed by members of our National Council to Minister McConalogue and his staff and assurances have been given that there is no agenda to undermine or further reduce the suckler herd. However, time will tell on this.

With regard to ongoing supports the Suckler Carbon Efficiency Programme (SCEP) will not deliver for the vast majority of suckler farmers which will put additional pressure on the new Suckler Beef Scheme that will succeed BEEP. This point has been made to the Minister and in discussion with him on our Budget submission, we have pushed hard for achievable measures and the option to increase support beyond the €60/cow and a front-loaded
payment on the first 10 cows. We have also insisted that the Bord Bia requirement under SCEP must not feature here and that there is an adequate budget to accommodate all interested farmers.

Finally, in relation to the suckler sector slow progress is being made around the marketing of Naturally Reared Suckler Beef with potential European markets identified. The concept for a
suckler brand and the funding (€6m marketing budget) was delivered by the INHFA in 2019 There is we believe massive growth potential due to the combination of sustainable environmental practices and favourable welfare practices that keeps the calf with its mother. As suckler farmers have been instrumental in helping to develop this brand we are working to ensure the benefits from any suckler branding is available to all suckler farmers.

INHFA Proposal for Targeted Suckler Welfare Scheme

We are seeking a new Scheme that will be more suitable to our farmers. We have written to the Minister and had several meetings surrounding our proposals. We will continue to lobby for change to the new scheme as there are many issues.
VIEW THE DOCUMENT

Background

In April, we attended an Oireachtas hearing on the disparity in the price of fertilizer. 
  
While the price of fertilizer had seen some price increases up to early 2020, the major pressure came initially from Summer 2020 to the end of 2021. During this time the price almost doubled. However, following Putin’s invasion of Ukraine in February 2022 we saw yet another massive increase in price that in 2022 saw a 123% increase from 2021 prices (based on CSO figures). All of this put enormous pressure on farmers as price and supply became a major issue in Spring of 2022. 
READ MORE

Beef and Sheep Group

The INHFA also sat on the Food Vision Beef and Sheep Group and 3 members of INHFA attended those meetings. This was a group set up by the Minister to look at various ways Farmers could reduce Methane levels and help towards Climate change. There was meetings over the Summer and into November and there was serious issues within the  report that we as an Organisation could not support namely the following

  • Measure 8,9 – Diversification / Extensification proposal (Reduction/Exit Scheme sucklers)
  • Measure 2 – Reducing the age of calving down to 24 months
  • Measure 1 – Reducing the age of slaughter to 24 months

 

The INHFA had serious issues with those measures and we made those issues known within the forum and also by written submissions on numerous occasions. There was no movement on this in the interim report and at this stage we had to call an emergency national council for direction and national council decided on 16th November that it was best we not have our names associated with a report that would infringe on our members’ farming practices and we left the process. After we made this move the Minister decided that there would be no compulsory exit scheme for the suckler sector.

Sheep Sector

In our Budget Submission we sought a payment of €35/ewe and while this may be ambitious we are still pushing the Minister on it. Beyond our Budget Submission the EU have recently announced a support package for farmers impacted by adverse events such as high input costs and market and trade-related issues. Ireland’s allocation is €9.5m however, Ireland can
complement this funding by up to 200% with national funds. This would deliver a payment on all ewes of close to €15/ewe. This is another option we are actively pursuing.

Woolen Industry

Pheilim Molloy our National Vice President had meetings with Steve Hayley who is CEO of British Wool to try and see if could we push for more markets and try and get some movement on the Wool issue. This progressed into more meetings and eventually a large grouping of shareholders came together and there was money announced by the Minister for feasibility studies and further work is ongoing on this. We will continue to lobby on this as new markets needs to be explored for our valuable product.

Developing an Irish woollen industry

All farmers selling wool over the last number of years will be well aware of the continued fall in price that has seen the product become almost worthless. With prices this year ranging from 10c/kg to 50c/kg depending on the wool grade and time of year sold, sheep farmers continue to shear at a considerable loss. Of course, it wasn’t always a poor trade. Go back to the 1980s and the sale of wool was a very important part of the sheep farmer’s income.

In 1984 when the National Wool Council (An Comhairle Olla) was abolished as a cost saving exercise we exported 5,895 tonnes of wool at a value of over £14m. That is equivalent to €29.7m today. In contrast, 5,641 tonnes was exported in 2019 at a value of €6.8m. While getting back to where we were in the mid-1980s may seem overly optimistic, the coming years will see significant change that could benefit Irish sheep farmers through an improved wool price.

The global wool trade has suffered over the last number of decades due to the increased use of synthetic fibres, especially in the fashion industry where it accounts for 65% of all fibres used, with wool accounting for just 1%. Recent research has shown that these synthetic fibres, which are sourced from crude oil, are, when washed, contributing to micro-plastics in waterways, seas and oceans. This is now a major problem for marine life and is also a problem for humans as it finds its way back through the food-chain. (See second article on this page for details).

As a natural fibre that is biodegradable, wool can provide a safe alternative product and a solution to a crisis that our scientific community and governments are only starting to appreciate. The challenge for us is to increase public awareness of this problem, while at the same time emphasising the important role wool could play in providing the solution. In addition to this, I believe there is a need to examine the possibility of developing a woollen industry here in Ireland and it is an option the INHFA are currently exploring. With five million sheep on the island of Ireland we believe this can be a viable option that could be further enhanced by the importation of wool from other EU countries.

Currently over 95% of wool sourced in Ireland goes to Bradford in the north of England, which may not be an option post-Brexit depending on the outcome of the UK-EU trade talks. Either way, a woollen industry based in Ireland creating local employment and paying a better price to our farmers is a prize worth fighting for.
In developing an industry such as this the first requirement is a scouring plant to clean the wool. While the cost involved in building of such a plant is not the issue, the challenge comes afterwards through the grit and contaminants in the soiled water after the scouring and washing process.

Ensuring the proper filtration and treatment of this water is where the major costs will be. However, all of this is achievable and it can be done without any impact to the environment provided the financial backing is there to do it. An additional factor to be considered when managing the waste from the cleaning process is its possible use as slow-release nitrogen in the growing of rhubarb. By adopting this approach, we help develop the circular economy as promoted through the CAP Strategic Plan. Once in place and working we do need to look at what products we can develop from wool, and this in itself can create further employment. While we would expect a greater requirement for wool in the fashion industry on the back of increased awareness of the dangers of micro-plastics, there are other options that we need to explore.

These should include the use of wool as a thermal and acoustic insulation, replacing bubble wrap and other synthetic packaging. It could also be used as a floor covering and for furniture. Lanolin is also an option, which is widely used in the cosmetic industry. As the UK exits the EU there is now an opportunity to try and establish a woollen industry in Ireland. This will require support from both our Government and the EU. If successful, a revivedwool industry can deliver for our rural economy and, most importantly, for our farmersthrough a higher price.

Sheep Markets

The pressure weighing down on the store lamb price has been further exacerbated by the fact that many traditional tillage farmers, who were crucial in the lamb store market, are no longer engaged in the practice. This shift in behaviour is primarily attributed to the new Good Agricultural and Environmental Conditions (GAEC) rules for tillage farmers, which have discouraged them from planting crops for sheep.

This change in practice is having a profound and alarming effect on the sheep sector and we are calling on the Minister to review and apply amendments to have this situation reversed.

This ongoing fall in the market price comes on the heels of the sheep sector grappling with increased costs, including those associated with shearing, while simultaneously facing the predicament of no market for wool 

The sheep sector is at a critical juncture, and without immediate intervention, its future is uncertain and this is why we are calling on the Government to act immediately and ensure the survival of this vital industry.

Driving on the Atlantic Hill Lamb brand

The INHFA has continued its successful promotion of light lamb through the Atlantic Hill Lamb brand which was been developed in conjunction with Kepak and Bord Bia.

The initiative started in 2017 and promotes light lamb with a carcass weight of 12 – 21.5kg. The specification in carcass confirmation and fat score of ‘O2’ – which is the minimum requirement of the light lamb market – was something we have focussed on by educating farmers since the project began.

All of the lambs supplied to the Atlantic Hill Lamb brand have to be Bord Bia approved. We have seen a big uptake in hill farmers becoming Bord Bia members which has allowed this project to continue to grow.

Farmers sometimes question why Bord Bia certification is required, which we have to admit we did at the start. However, having met quite a number of Kepak’s customers for the light lamb it is clear that supermarkets see it as a critical marketing tool and it is also important for the export market.

A recently new initiative and through intense negotiations, INHFA has secured a deal with Kepak where you can send your lambs through our group and pay only €1/lamb (.50c for transport & .50c for group management). This has resulted in increased interest in the group. Bookings are taken every Friday; you can contact us at 0719302715.

We will also continue to negotiate the best price for our premium product.

Agri-Climate Rural Environment Scheme (ACRES)

Unlike previous Agri-Environment Schemes, there are two distinct elements (streams) to this scheme – General and co-operation. All farmers should at this point be aware of what stream their farm is in and if not please contact your Farm advisor.

The Scheme was opened last Autumn and almost all of the 46,000 applicants were accepted into the scheme. Unlike previous schemes that saw payments based on actions, payments under ACRES will also be made based on a habitat scorecard. Details on this are outlined below.

For farmers currently in ACRES we understand initial payments will be made towards the end of this year – possibly early December with balancing payments made in 2024. For farmers looking to join Tranche 2 of ACRES, the scheme will reopen this October. Currently, there are only 4,000 places available but the INHFA is pushing the Minister and Government to increase this as we anticipate there could be a further 20,000 farmers that are looking to join.

ACRES Co-operative (CP)

  • 8 Zones with over 30,000 farmers who can achieve a maximum payment of €10,500 with an expected average payment of €7,500. – 20,000 places.
  • To qualify farmers will need greater than 3ha or 20% of their land in the CP zone
  • Where a holding crosses more than one CP zone farmer to be assigned to where their largest area of land is.
  • If they have land in both the CP area and in General and accepted into the CP measure, then farmers will also be able to choose actions from the General list provided they have spent less than €7,000 on ring-fencing process.
  • Core payment will come from score achieved using the habitat scorecard
  • Farm Advisor will submit your ACERS application – (c/d Mid- November) and the advisor will work with the CP teams to identify habitats and provide advice on maintenance and improvement.
  • Scoring of habitats will be done by your advisor in year 1, year 3, and 5 with the first scoring being done in Summer 2023.
  • For farmers with commonage a score of 8 will be used for the ring-fencing exercise. The commonage will be scored in 2023 and the payment made to farmers at the end of 2023 will be based on the actual score of the commonage in 2023.
  • For farmer’s private land a figure of €300/ha is used for ring-fencing exercise but farmers will be paid on the actual score given in 2023.
  • Commonage land will be paid on first. All private CP land is scored and paid on in no particular order. There is no limit to the number of hectares.
  • Maximum area payment in the CP area is €7,000, however, there is talk of a possible bonus for high quality.
  • If under €7,000 then you can bring your payment up through either General measures if you also have land outside the CP area or through Landscape Actions (LA’s) and Non Productive Investments (NPI’s).
  •  In total there is €3,500 available for NPI’s and LA’s each year and a total of €17,500 available over the lifetime of the scheme.
  • So if you haven’t spent it in year 1 then you can spend beyond €3,500 in subsequent years provided you don’t go beyond €17.500.
  • All NPI’s and LA’s will be screened by CP teams before being approved by DAFM.

ACRES General

  • 30,000 places available with tiered access. Max €7,500 Avg €5,000.
  • Tier 1- Priority Environmental Assets eg Natura, land, commonage, geese and swan, breeding wader, High water status Rare Breeds, and Organic Farming.
  • Tier 2- Specific conditions/actions eg. Vulnerable waterways, Native woodland establishment, or GPC11 Agro-Forestry, Farm stocking rate over 130kg/livestock manure nitrogen, 30+ha arable crops.
  • Tier 3 – General Actions with participants choosing from a list of 33 actions
  • Actions are measures based such as tree planting and results based such as Low input grassland.
  • Specific actions and payment rates includes – Extensively Grazed Pasture (max 8ha) €250/ha Conservation of rare breeds up to 20LU – €200LU/yr. Coppicing hedgerow 10 to 400m €2.87/m/yr. Laying Hedgerow €5.47/m/yr (max 400m). Planting new hedgerow (10 to 750m) €5.29/m/yr. Grass margins – Grassland 2m – €1/m/yr, 3m – €1.10/m/yr, 6m – €1.37/m/yr (max 2500m).
  • Specific actions cont. Low emission slurry spreading (min 50m) €1.20/m3/yr. Planting trees in riparian buffer zone (10 to 200 trees). €3.18/tree/yr. Riparian buffer zone – Grassland (0.4 to 2ha) €1530/ha/yr. Dry stone wall maintenance (10 to 4,000m) 0.76/m/yr. Tree belts for ammonia capture from farmyards (0.18 to 0.5ha) Max €2,514/yr). Winter bird food plot (0.25 to 3ha) €1,000/ha/yr.
  • Results-based actions – Low Input Peat Grassland (0.25 to 10ha) up to €400ha/yr. Low input grassland (0.25 to 10ha) Up to €400ha/yr. Commonage (no limit) up to €220/ha/yr

ACRES General

  • Low Input Grassland, Peat Grassland & Results based Co operation, 10 – €400: 9 – €375: 8 – €350: 7 – €325: 6 – €300: 5 – €275: 4 – €250: No payment under 4
  • Commonage 10 – €220: 9 – €180: 8 – €145: 7 – €115: 6 – €90: 5 – €70: 4 -€60: no payment under 4 on scorecard but a participation payment of €50/ha under certain conditions.

CAP – Pillar 1 Payments

Ireland’s new CAP Plan will see convergence move to 85% of the National average as well as the introduction of a front-loaded payment on the first 30ha and a flat rate eco-scheme payment.

This we estimate will deliver a payment of €246/ha on the first 30ha made up as follows BISS €140 + Eco Scheme €63 + CRISS (Front loaded) €43.

Farmers currently on the minimum payment will see the majority of this increase in 2023. For the Forgotten Farmer Group, they will see a once-off payment and will qualify for 60% support under the Farm Improvement Scheme.

INHFA was the only Farming Organisation lobbying for convergence and front-loading of payments, this was a significant move that will benefit 60% of farmers nationally.

Eco- Scheme

This is a new scheme paid from Pillar 1 that there seems to be a level of confusion over. Important to recognise that this is different to ACRES or GLAS.

The scheme will see a flat rate payment of at least €63/ha paid to farmers on the completion of two measures. For most hill farmers and those involved in extensive farming systems the three options most likely are 1. Limiting Chemical Nitrogen usage 2. Extensive Livestock production and 3. Space for Nature.

With regard to the Space for Nature measure, if you are over 7% it qualifies as one measure and if over 10% it will qualify for both measures required.

Organic Farming Scheme

There was a major increase in funding for Organics in the new CAP – increasing from €10m to €51m annually. There is also a significant change in the stocking rates (reducing from 0.5LU/Ha to 0.15LU/Ha) which will make it more acceptable for extensive farming systems.

Payment rates are: Dry stock up to 70ha – €300 (conversion) €250 full organic.

In addition, there is a participation payment (irrespective of farm size) of €2,000 for first two years and €1,400 thereafter. This will help cover the certification costs. Also under the new TAMS – On Farm Capital Investment Scheme organic farmers will qualify for 60% grant aid.

Finally, important to be aware that farmers won’t get paid twice on an area based measure so if also considering joining ACRES then discuss in detail all options with your Farm Advisor.

However, there is one exception to this that being the Agro-forestry Scheme.

Agro-Forestry

This is a scheme that facilitates both farming and trees in partnership. The scheme requires farmers to plant between 400 and 1000 trees/ha. These can be thinned out in time to between 160-250 trees/ha. Minimum area is 0.5ha and at least 20m wide. There is and establishment grant (that includes fencing) of €6220/ha paid in two instalments. Premium rates which are for five years are €625ha up to 10ha and €660 over 10ha.

INHFA are looking to get changes on this with regard to trees, the inclusion of hedgerow and extension on the premium term up to 20 years.

Young Farmers

Similar to the current CAP Programme a top-up payment on a per hectare basis will be available for qualifying Young Farmers. This payment will be available for five years and farmers must have a Green Cert and be under 40 on application. Payment will be made on up to 50ha. In addition to this qualifying Young Farmers can apply to the National Reserve and have their payment rates (for BISS) brought up to the national average if currently below.

Forgotten Farmer Group

For the Forgotten Farmer Group, they will see a once off payment and will qualify for 60% support under the Farm Improvement Scheme. For over 60% of farmers they will see an increase in their payments resulting from convergence, the front-loading of payments and the flat rate Eco-scheme. A significant part of this will be delivered in 2023.

NEW CAP Supports – payment model

  • This is based on a farmer with 30ha and 12 suckler cows or 150 ewes
  • Total Pillar 1 support (@ National average €246) €7,380: Suckler/sheep support €1,800: ANC payment €3,782: ACRES €4,000: Organic (on 25ha) €7,500: TOTAL €24,426

Land Designations

Land designations have become an increasingly significant feature of Irish agriculture since the introduction of Environmentally Sensitive Areas (ESAs) in the 1990s.

Introduced under EEC regulation, these ESAs aimed to encourage farming practices which were “compatible with the requirements of conserving natural habitats”.

ESAs were to make way for our National Heritage Areas (NHAs) as we moved through the 1990s. The NHAs then became the baseline national designation, and their introduction saw a significant increase in the area of land designated.

These designations were usually clearly demarcated, with boundaries such as rivers, roadways, walls and ditches.

Subsequently, EU designations in the form of the Natura 2000 network were introduced on the back of the habitats directives in 1997.

The new EU designations took the form of Special Areas of Conservation (SAC) and Special Protected Area (SPA) when introduced. These did not replace the NHAs but became a further designation on lands.

Currently, there are over 400 Natura 2000 sites covering over 700,000ha or 13% of the land area of the country.

The sites are designed to protect species and habitats, with 28 species of land mammal, over 400 species of birds, in excess of 4,000 plant species and over 12,000 species of insect detailed.

When first introduced at EU level the Oireachtas had not passed the necessary legislation to qualify SAC designations. As a result, all Irish SAC designations were initially classified as candidate designations.

However, all restrictions for farmers that related to a fully ratified Natura 2000 designation still applied.

The process of applying full SAC status to these sites commenced in 2017, with the National Parks and Wildlife Services (NPWS) contacting landowners and notifying them of the new status.

This process is currently ongoing. So if you are a landowner with an SAC site and you have not yet been contacted, then the expectation is that you will be in the coming year.

For farmers with SPA sites this ratification process has already been completed.

On the establishment of the INHFA we recognised the major issues these designations were causing which is why we included the term Natura in our name. We have also been working to reduce their impact and to find financial supports for the major burden they are imposing on landowners.

Currently the Natura 2000 network of designations (SAC & SPA) covers 14% of the country with many of these designations west of a line from Lough Foyle in North East Donegal to Cork City.  In addition to this most of these designations falls on hill lands both commonage and private hill land.

The Natura 2000 designations were introduced as a response to falling biodiversity across the European Union with their objective been to protect the high levels of biodiversity that existed in certain areas. So in simple terms the designations were recognition of a job well done by landowners in relation to protecting biodiversity and the vital habitats across our hills on in river basins.

Unfortunately, the management of these designations by State Bodies has been an utter disaster. Farmers and landowners who had delivered habitats worth protecting were side-lined and State Bodies prioritised a policy of preservation over conservation. This policy was best illustrated through the 38 Activities Requiring Consent (ARC’s) that compelled farmers to get permission from the NPWS or the Local Authority to carry out normal farming activities.

The activities requiring consent included mulching, controlled burning, topping, spreading lime, fertiliser, slurry or farm yard manure. Permission is also required if you want to change the type of stock or introduce a new stock type (eg introducing cattle if they were not there before) or if you are significantly increasing or decreasing your stock numbers.

For landowners looking to put up a new fence, or planning to use a digger on land for any reason then they are expected to get planning permission from the Local Authority (County Council). This planning application will require a Natura Impact Statement (Environmental Assessment Statement) that could cost anything from €1,000 to €3,000.

What all of this has done is to restrict landowners/farmers from carrying out the very activities required to manage and protect these habitats. As a result of this we have seen a regression in the habitat status on many of these sites with no consequence for the environmentalists and State authorities that have contributed to this regression.

Currently the INHFA are working to address many of these issues and ensure that farmers are protected and rewarded for their efforts. We are also seeking financial recognition for the loss of income and the clear devaluation these designations has imposed on these lands.

Finally, for the many farmers that are not impacted by these designations there is now the looming threat of further designations under the EU Biodiversity Strategy that demands designations on 30% of each countries land base. In addition to this there are also proposals to introduce a new designation type called Strictly Protected across 10% of each countries land area. This new designation where applied will see the cessation of all farming activity and is rewilding by another name.

Impact on Farming

In total there are 38 different actions that require consent (ARCs) on a SAC or SPA (Natura 2000) site.

These actions are listed on this page. Please click here to see those 38 ARCS

For landowners with Natura 2000 lands it is important that you are aware of these ARCs as they will impact on your farming activity.

While it is unlikely that all 38 actions will apply to any one site, it is quite probable that 20 or more will. Landowners who have been notified of full SAC or SPA status will have been informed of what specific action(s) applies to their sites.

The impact of these restrictions can vary depending on farming requirements. On a more benign level they can delay critical decisions and actions. However, for some farmers they have added an extra cost through the requirement of planning permission for actions such as fencing.

Where planning permission has been required farmers have often spent in excess of €4,000 through engineering fees and employing expert help in developing a Natura Impact Statement. This is an additional cost that farmers on non-designated land do not incur. Designations can therefore undermine farm profits.

Impact on land sales

In addition to the added costs outlined, farmers with Natura 2000 land are now required to list the designation as a burden on their property folio.

In the event of them selling this land they must notify that person in writing prior to the sale that the property is a European Natura 2000 site and indicate any restrictions that applies to it.

This is having a major impact on the sale price of this land, as was outlined to the INHFA in discussions with auctioneers across the west and northwest.

Findings from these discussions indicate a devaluation of at least 50% on land with a Natura 2000 designation, with one auctioneer in the northwest putting the loss at €2,500/acre.

Land Eligiblity

During 2014 and early 2015 a number of Department of Agriculture inspections targeted at marginal, mountain and commonage lands resulted in farmers receiving penalties of up to 100% on their Single Payment Scheme. These penalties were imposed on the basis of insufficient farming activity. Yet in doing so the Department of Agriculture never set out a criteria for what they defined as insufficient farming activity. Neither did they take into account the environmental condition of these lands or indeed carry out an appropriate assessment where lands had a designation on them – most of the lands targeted had designations on them.

The consequences

Green Low carbon Agri-Environmental Scheme

The consequences of these inspections were two-fold. For any farmer that had land deemed ineligible there was an immediate loss of income for 2014 and a continued loss of income for the duration of the CAP Program till 2020. For all other farmers especially those on marginal lands, they were left with the dilemma of what land to take out and what land should they leave in when filling out their Basic Payment Forms. As the Department had no criteria defined then this became a guessing game that could cost farmers a lot of money.

Getting results

During the Spring of 2015 the INHFA highlighted this issue through our own public meetings and the media. We also challenge the Department through the media, the public information meetings they held on CAP and the Joint Oireachtas Committee on Agriculture to justify their inspection model. Private meetings were also held with Senior Department of Agriculture Officials to try and advance a solution. All of this created the desired effect as by mid-April Land Eligibility had become the major issue in farming circles and one that could no longer be ignored. Significant moves were made by the Department on the 21st April when they announced that provided land is available for grazing then it meets the criteria for eligibility. Other issues around eligibility were highlighted such as burning, the definition of a bogland, heather height, the density of furs and other invasive species. However these are issues we would expect to get resolved and are presently seeking clarification on.

“Seeking Fairness Not Favouritism”

Public Access and Dog Control

Following a significant increase in the number of people accessing our uplands there is now an urgent need to reassess how this is impacting on landowners, local communities and the overall tourism sector. While the increased tourism activity in many communities is a welcome development it is also important to ensure that it doesn’t come at a cost to local people and the landowners who farm these lands. Farmed land is almost exclusively, including commonage, owned land, identical in ownership to a persons’ home or back garden. The vast majority of farmers are willing to facilitate access on their lands provided this goodwill is not abused or their farming activity undermined. There are also some farmers that are not willing to make their land available for public access and this must also be respected, and this fundamental right protected.

 

In a survey we conducted with our members several issues featured strongly. Over 70% of farmers had recreational users crossing their land on a daily or weekly basis. That frequency places significant pressure on the relationship with farmers particularly when over 80% of farmers reported that
recreational users have dogs with them. A further 62% of farmers reported that recreational users had refused to remove dogs from farmland when requested to do so by the farmer. Farms are workplaces with significant risks that must be managed due to the presence of large livestock, heavy machinery and seasonal pressures. There is ongoing unease in relation to insurance liability of public access on farmland. This concern may be heightened by the revival of the practice of larger livestock grazing on uplands. Farmers are concerned that if an incident happens on their farms’ cases will be taken against them; unlike large and institutional agencies or businesses it is very difficult and daunting for an individual to challenge any negative judgment.

A stark outline of the real difficultly farmers face on their own land has emerged from this research. There are very concerning safety issues arising in the survey of farmers feeling threatened and being actually threatened when faced with groups or individual recreational users. Almost 60% of farmers reported having been verbally abused by recreational users. A further 40% reported that they had either been threatened or felt threatened by recreational users accessing their farmland. This is not tolerable.

What came out very strongly in the survey was that there appears to be widespread ignorance of farming practices and ownership of all kinds of farmland, many recreational users do not seem to appreciate that when they walk on farmland they are entering owned land and entering a farmers’ place of work and livelihood. Further, many of these farmlands are found in areas of NATURA 2000 sites (Special Areas of Conservation (SACs) and Special Protection Areas (SPAs)) and National Heritage Area . The lack of joined -up thinking and public access management raises serious concerns for their future environmental protection. Farmers can no longer tolerate the laissez-faire approach of tourism promoters and government and various development bodies that are encouraging outdoor pursuits on farmland but not providing any protection to farming families in their own homes and farms.

The basis for this policy paper is to provide legislative reassurance for those farmers who, on a daily, weekly, monthly basis have members of the public accessing their lands. And to engage with bodies whose responsibility is to manage dog control and those who are promoting walking on farmed land; to address the problems created by the public accessing private farmland.

As outlined above prominent issues that have emerged include:

  • Dog Control
  • Concerns around Insurance and Liability
  • Awareness of land ownership and rights and respect and safety for landowners and;
  • Environmental impacts of increased public access.

 

In this policy paper, we have limited our proposals to these key areas.

Dog Control

Based on the survey and direct contact with farmers, dog control (or the lack of dogs being controlled) is a major issue. Commonly farmers are reporting from first-hand experience witnessing dogs that were supposed to be on leads roaming free and stressing sheep. Some of the replies that farmers reported in this INHFA survey included :

“Some Walkers think they are entitled to let their dogs run without a lead in wide open spaces”

“Told to cop myself on that their dogs would not bother sheep despite sheep being in the immediate vicinity”.

An often reported comment:

“Told to mind my own F***ing business”

“They definitely were not going to abide by requirement to not bring dogs. I back off because there was three of them and I was on my own”

When we consider all options regarding this, we have concluded that the best option for both farmer and recreational users is a complete ban on all dogs by recreational users on our farms.

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Nature Restoration Law

The Nature Restoration Law has been developed following a recommendation in the EU Biodiversity Strategy around the need to protect nature and land areas with a high carbon content.

The law will provide for legally binding EU nature restoration targets to restore degraded ecosystems. Of particular interest are those systems that could contribute most to the capture and storage of carbon. In Ireland, this will apply to Annex 1 Habitats which are predominately peatlands based – blanket bogs, raised bogs (including farmed areas), cut away bogs, and drained farmed peatlands

These legally binding targets are a drastic step up from the existing designations where landowners are often prevented from carrying out further actions as they need permission from State Bodies. Under this proposal landowners (in addition to these restrictions) will also be expected to deliver on restoration targets.

READ THE FULL DOCUMENT

Areas impacted and what will be required

The areas impacted will include our wet and dry heaths that cover most of our upland areas which are currently being farmed with other likely areas to include sandy banks, machair grasslands and Molinia meadows.

Drained-farmed peatlands in lowland areas are potential Annex 1 areas that could be re-established through rewetting.

Most of the focus has been on the rewetting of drained peatlands which was covered under Article 9 of the Law. However, the restoration and re-establishment of these Habitats is the most significant element and has gone largely unnoticed.

Here there is a requirement “to improve to good condition Annex 1 habitats, in order to reach favourable reference area”

There is also a proposal to put in place restoration measures necessary to re-establish Annex 1 habitats. This will include drained farmed peatlands (reclaimed boglands) which will involve rewetting.

Currently, there is 670,000ha of Annex 1 habitat and 620,000ha of land that was previously an Annex 1 habitat

Funding Options & Requirements

While various drafts of this law outline the need for funding there is no specific budget allocated. Under EU Parliament Proposals (Article 11, 2a) details how CAP or other agricultural funding can’t be used as a funding source. However, Article 18,6(a) d refers to funding gaps and uses the words “where appropriate” funding should be provided.

The original Commission proposal detailed how Member States SHALL when preparing their plan take account of ecological, economic, and social functions.However, under the Council of Ministers text which was also adopted by the EU Parliament SHALL has been amended to MAY. This gives Member States the opportunity to renege on funding. 

In relation to funding, there are two elements to consider.

First is the direct cost associated with restoring and re-establishing habitats. This will vary depending on the site and work. However, based on a restoration project in the Brecht Reserve in Belgium the cost to re-establish 570ha of heath came to almost €5m (€8771/ha).

The second element relates to the ongoing funding of farmers/landowners and if farmers are covered beyond the cost associated with carrying out the necessary actions for restoration/re-establishment. i.e. will it be for measures or for loss of income or will any possible funding even cover the landowner’s cost of implementing the law?

Farming activity and CAP payments

Firstly, we need to recognise that CAP payments are only made on land that is an agricultural area. Unfortunately, this Law only recognises these Annex 1 Habitats as ecological areas so there is no guarantee that land subject to this law will be entitled to any CAP support.

Beyond the challenge around CAP supports, Article 12 m of this law calls for an indication of subsidies that could negatively affect the targets and obligations set out in the law

Taking both of these together we create a catch-22 in that, if farmers don’t follow the law their CAP subsidies will be pulled and if they implement the law as required their lands won’t be eligible for CAP Subsidies.

 

What needs to happen

With a policy position from the EU Commission, EU Parliament, and Council of Ministers on Nature Restoration there will be a final law agreed on Nature Restoration later this year.

While we would have preferred to have seen a full re-negotiation of the law we are now looking to have critical amendments included that will help protect our farming way of life that has supported communities while also delivering for nature.

On this basis, we are targeting amendments to have High Nature Value Farmland recognised as a habitat with an ecological status. This can provide a level of protection for most of the lands that will be subject to this law. It will also enshrine current farming activity as a necessary mechanism for protecting these farmed habitats.

A team of INHFA delegates traveled to Brussels to meet the Irish MEPs to outline the devastating consequences the Nature Restoration Law will have on traditional farming practices if implemented in its current format. The INHFA will continue to lobby for amendments to the Law that will protect our farmlands.

Suckler Sector

Recent media reports that outline how the suckler sector will need to reduced further in order to meet our Climate Change targets has angered a lot of suckler farmers especially as other sectors of agriculture continue to expand.

This anger has also been clearly expressed by members of our National Council to Minister McConalogue and his staff and assurances have been given that there is no agenda to undermine or further reduce the suckler herd. However, time will tell on this.

With regard to ongoing supports the Suckler Carbon Efficiency Programme (SCEP) will not deliver for the vast majority of suckler farmers which will put additional pressure on the new Suckler Beef Scheme that will succeed BEEP. This point has been made to the Minister and in discussion with him on our Budget submission, we have pushed hard for achievable measures and the option to increase support beyond the €60/cow and a front-loaded
payment on the first 10 cows. We have also insisted that the Bord Bia requirement under SCEP must not feature here and that there is an adequate budget to accommodate all interested farmers.

Finally, in relation to the suckler sector slow progress is being made around the marketing of Naturally Reared Suckler Beef with potential European markets identified. The concept for a
suckler brand and the funding (€6m marketing budget) was delivered by the INHFA in 2019 There is we believe massive growth potential due to the combination of sustainable environmental practices and favourable welfare practices that keeps the calf with its mother. As suckler farmers have been instrumental in helping to develop this brand we are working to ensure the benefits from any suckler branding is available to all suckler farmers.

INHFA Proposal for Targeted Suckler Welfare Scheme

We are seeking a new Scheme that will be more suitable to our farmers. We have written to the Minister and had several meetings surrounding our proposals. We will continue to lobby for change to the new scheme as there are many issues.
VIEW THE DOCUMENT

Background

In April, we attended an Oireachtas hearing on the disparity in the price of fertilizer. 
  
While the price of fertilizer had seen some price increases up to early 2020, the major pressure came initially from Summer 2020 to the end of 2021. During this time the price almost doubled. However, following Putin’s invasion of Ukraine in February 2022 we saw yet another massive increase in price that in 2022 saw a 123% increase from 2021 prices (based on CSO figures). All of this put enormous pressure on farmers as price and supply became a major issue in Spring of 2022. 
READ MORE

Beef and Sheep Group

The INHFA also sat on the Food Vision Beef and Sheep Group and 3 members of INHFA attended those meetings. This was a group set up by the Minister to look at various ways Farmers could reduce Methane levels and help towards Climate change. There was meetings over the Summer and into November and there was serious issues within the  report that we as an Organisation could not support namely the following

  • Measure 8,9 – Diversification / Extensification proposal (Reduction/Exit Scheme sucklers)
  • Measure 2 – Reducing the age of calving down to 24 months
  • Measure 1 – Reducing the age of slaughter to 24 months

 

The INHFA had serious issues with those measures and we made those issues known within the forum and also by written submissions on numerous occasions. There was no movement on this in the interim report and at this stage we had to call an emergency national council for direction and national council decided on 16th November that it was best we not have our names associated with a report that would infringe on our members’ farming practices and we left the process. After we made this move the Minister decided that there would be no compulsory exit scheme for the suckler sector.

Sheep Sector

In our Budget Submission we sought a payment of €35/ewe and while this may be ambitious we are still pushing the Minister on it. Beyond our Budget Submission the EU have recently announced a support package for farmers impacted by adverse events such as high input costs and market and trade-related issues. Ireland’s allocation is €9.5m however, Ireland can
complement this funding by up to 200% with national funds. This would deliver a payment on all ewes of close to €15/ewe. This is another option we are actively pursuing.

Woolen Industry

Pheilim Molloy our National Vice President had meetings with Steve Hayley who is CEO of British Wool to try and see if could we push for more markets and try and get some movement on the Wool issue. This progressed into more meetings and eventually a large grouping of shareholders came together and there was money announced by the Minister for feasibility studies and further work is ongoing on this. We will continue to lobby on this as new markets needs to be explored for our valuable product.

Developing an Irish woollen industry

All farmers selling wool over the last number of years will be well aware of the continued fall in price that has seen the product become almost worthless. With prices this year ranging from 10c/kg to 50c/kg depending on the wool grade and time of year sold, sheep farmers continue to shear at a considerable loss. Of course, it wasn’t always a poor trade. Go back to the 1980s and the sale of wool was a very important part of the sheep farmer’s income.

In 1984 when the National Wool Council (An Comhairle Olla) was abolished as a cost saving exercise we exported 5,895 tonnes of wool at a value of over £14m. That is equivalent to €29.7m today. In contrast, 5,641 tonnes was exported in 2019 at a value of €6.8m. While getting back to where we were in the mid-1980s may seem overly optimistic, the coming years will see significant change that could benefit Irish sheep farmers through an improved wool price.

The global wool trade has suffered over the last number of decades due to the increased use of synthetic fibres, especially in the fashion industry where it accounts for 65% of all fibres used, with wool accounting for just 1%. Recent research has shown that these synthetic fibres, which are sourced from crude oil, are, when washed, contributing to micro-plastics in waterways, seas and oceans. This is now a major problem for marine life and is also a problem for humans as it finds its way back through the food-chain. (See second article on this page for details).

As a natural fibre that is biodegradable, wool can provide a safe alternative product and a solution to a crisis that our scientific community and governments are only starting to appreciate. The challenge for us is to increase public awareness of this problem, while at the same time emphasising the important role wool could play in providing the solution. In addition to this, I believe there is a need to examine the possibility of developing a woollen industry here in Ireland and it is an option the INHFA are currently exploring. With five million sheep on the island of Ireland we believe this can be a viable option that could be further enhanced by the importation of wool from other EU countries.

Currently over 95% of wool sourced in Ireland goes to Bradford in the north of England, which may not be an option post-Brexit depending on the outcome of the UK-EU trade talks. Either way, a woollen industry based in Ireland creating local employment and paying a better price to our farmers is a prize worth fighting for.
In developing an industry such as this the first requirement is a scouring plant to clean the wool. While the cost involved in building of such a plant is not the issue, the challenge comes afterwards through the grit and contaminants in the soiled water after the scouring and washing process.

Ensuring the proper filtration and treatment of this water is where the major costs will be. However, all of this is achievable and it can be done without any impact to the environment provided the financial backing is there to do it. An additional factor to be considered when managing the waste from the cleaning process is its possible use as slow-release nitrogen in the growing of rhubarb. By adopting this approach, we help develop the circular economy as promoted through the CAP Strategic Plan. Once in place and working we do need to look at what products we can develop from wool, and this in itself can create further employment. While we would expect a greater requirement for wool in the fashion industry on the back of increased awareness of the dangers of micro-plastics, there are other options that we need to explore.

These should include the use of wool as a thermal and acoustic insulation, replacing bubble wrap and other synthetic packaging. It could also be used as a floor covering and for furniture. Lanolin is also an option, which is widely used in the cosmetic industry. As the UK exits the EU there is now an opportunity to try and establish a woollen industry in Ireland. This will require support from both our Government and the EU. If successful, a revivedwool industry can deliver for our rural economy and, most importantly, for our farmersthrough a higher price.

Sheep Markets

The pressure weighing down on the store lamb price has been further exacerbated by the fact that many traditional tillage farmers, who were crucial in the lamb store market, are no longer engaged in the practice. This shift in behaviour is primarily attributed to the new Good Agricultural and Environmental Conditions (GAEC) rules for tillage farmers, which have discouraged them from planting crops for sheep.

This change in practice is having a profound and alarming effect on the sheep sector and we are calling on the Minister to review and apply amendments to have this situation reversed.

This ongoing fall in the market price comes on the heels of the sheep sector grappling with increased costs, including those associated with shearing, while simultaneously facing the predicament of no market for wool 

The sheep sector is at a critical juncture, and without immediate intervention, its future is uncertain and this is why we are calling on the Government to act immediately and ensure the survival of this vital industry.

Driving on the Atlantic Hill Lamb brand

The INHFA has continued its successful promotion of light lamb through the Atlantic Hill Lamb brand which was been developed in conjunction with Kepak and Bord Bia.

The initiative started in 2017 and promotes light lamb with a carcass weight of 12 – 21.5kg. The specification in carcass confirmation and fat score of ‘O2’ – which is the minimum requirement of the light lamb market – was something we have focussed on by educating farmers since the project began.

All of the lambs supplied to the Atlantic Hill Lamb brand have to be Bord Bia approved. We have seen a big uptake in hill farmers becoming Bord Bia members which has allowed this project to continue to grow.

Farmers sometimes question why Bord Bia certification is required, which we have to admit we did at the start. However, having met quite a number of Kepak’s customers for the light lamb it is clear that supermarkets see it as a critical marketing tool and it is also important for the export market.

A recently new initiative and through intense negotiations, INHFA has secured a deal with Kepak where you can send your lambs through our group and pay only €1/lamb (.50c for transport & .50c for group management). This has resulted in increased interest in the group. Bookings are taken every Friday; you can contact us at 0719302715.

We will also continue to negotiate the best price for our premium product.

Agri-Climate Rural Environment Scheme (ACRES)

Unlike previous Agri-Environment Schemes, there are two distinct elements (streams) to this scheme – General and co-operation. All farmers should at this point be aware of what stream their farm is in and if not please contact your Farm advisor.

The Scheme was opened last Autumn and almost all of the 46,000 applicants were accepted into the scheme. Unlike previous schemes that saw payments based on actions, payments under ACRES will also be made based on a habitat scorecard. Details on this are outlined below.

For farmers currently in ACRES we understand initial payments will be made towards the end of this year – possibly early December with balancing payments made in 2024. For farmers looking to join Tranche 2 of ACRES, the scheme will reopen this October. Currently, there are only 4,000 places available but the INHFA is pushing the Minister and Government to increase this as we anticipate there could be a further 20,000 farmers that are looking to join.

ACRES Co-operative (CP)

  • 8 Zones with over 30,000 farmers who can achieve a maximum payment of €10,500 with an expected average payment of €7,500. – 20,000 places.
  • To qualify farmers will need greater than 3ha or 20% of their land in the CP zone
  • Where a holding crosses more than one CP zone farmer to be assigned to where their largest area of land is.
  • If they have land in both the CP area and in General and accepted into the CP measure, then farmers will also be able to choose actions from the General list provided they have spent less than €7,000 on ring-fencing process.
  • Core payment will come from score achieved using the habitat scorecard
  • Farm Advisor will submit your ACERS application – (c/d Mid- November) and the advisor will work with the CP teams to identify habitats and provide advice on maintenance and improvement.
  • Scoring of habitats will be done by your advisor in year 1, year 3, and 5 with the first scoring being done in Summer 2023.
  • For farmers with commonage a score of 8 will be used for the ring-fencing exercise. The commonage will be scored in 2023 and the payment made to farmers at the end of 2023 will be based on the actual score of the commonage in 2023.
  • For farmer’s private land a figure of €300/ha is used for ring-fencing exercise but farmers will be paid on the actual score given in 2023.
  • Commonage land will be paid on first. All private CP land is scored and paid on in no particular order. There is no limit to the number of hectares.
  • Maximum area payment in the CP area is €7,000, however, there is talk of a possible bonus for high quality.
  • If under €7,000 then you can bring your payment up through either General measures if you also have land outside the CP area or through Landscape Actions (LA’s) and Non Productive Investments (NPI’s).
  •  In total there is €3,500 available for NPI’s and LA’s each year and a total of €17,500 available over the lifetime of the scheme.
  • So if you haven’t spent it in year 1 then you can spend beyond €3,500 in subsequent years provided you don’t go beyond €17.500.
  • All NPI’s and LA’s will be screened by CP teams before being approved by DAFM.

ACRES General

  • 30,000 places available with tiered access. Max €7,500 Avg €5,000.
  • Tier 1- Priority Environmental Assets eg Natura, land, commonage, geese and swan, breeding wader, High water status Rare Breeds, and Organic Farming.
  • Tier 2- Specific conditions/actions eg. Vulnerable waterways, Native woodland establishment, or GPC11 Agro-Forestry, Farm stocking rate over 130kg/livestock manure nitrogen, 30+ha arable crops.
  • Tier 3 – General Actions with participants choosing from a list of 33 actions
  • Actions are measures based such as tree planting and results based such as Low input grassland.
  • Specific actions and payment rates includes – Extensively Grazed Pasture (max 8ha) €250/ha Conservation of rare breeds up to 20LU – €200LU/yr. Coppicing hedgerow 10 to 400m €2.87/m/yr. Laying Hedgerow €5.47/m/yr (max 400m). Planting new hedgerow (10 to 750m) €5.29/m/yr. Grass margins – Grassland 2m – €1/m/yr, 3m – €1.10/m/yr, 6m – €1.37/m/yr (max 2500m).
  • Specific actions cont. Low emission slurry spreading (min 50m) €1.20/m3/yr. Planting trees in riparian buffer zone (10 to 200 trees). €3.18/tree/yr. Riparian buffer zone – Grassland (0.4 to 2ha) €1530/ha/yr. Dry stone wall maintenance (10 to 4,000m) 0.76/m/yr. Tree belts for ammonia capture from farmyards (0.18 to 0.5ha) Max €2,514/yr). Winter bird food plot (0.25 to 3ha) €1,000/ha/yr.
  • Results-based actions – Low Input Peat Grassland (0.25 to 10ha) up to €400ha/yr. Low input grassland (0.25 to 10ha) Up to €400ha/yr. Commonage (no limit) up to €220/ha/yr

ACRES General

  • Low Input Grassland, Peat Grassland & Results based Co operation, 10 – €400: 9 – €375: 8 – €350: 7 – €325: 6 – €300: 5 – €275: 4 – €250: No payment under 4
  • Commonage 10 – €220: 9 – €180: 8 – €145: 7 – €115: 6 – €90: 5 – €70: 4 -€60: no payment under 4 on scorecard but a participation payment of €50/ha under certain conditions.

CAP – Pillar 1 Payments

Ireland’s new CAP Plan will see convergence move to 85% of the National average as well as the introduction of a front-loaded payment on the first 30ha and a flat rate eco-scheme payment.

This we estimate will deliver a payment of €246/ha on the first 30ha made up as follows BISS €140 + Eco Scheme €63 + CRISS (Front loaded) €43.

Farmers currently on the minimum payment will see the majority of this increase in 2023. For the Forgotten Farmer Group, they will see a once-off payment and will qualify for 60% support under the Farm Improvement Scheme.

INHFA was the only Farming Organisation lobbying for convergence and front-loading of payments, this was a significant move that will benefit 60% of farmers nationally.

Eco- Scheme

This is a new scheme paid from Pillar 1 that there seems to be a level of confusion over. Important to recognise that this is different to ACRES or GLAS.

The scheme will see a flat rate payment of at least €63/ha paid to farmers on the completion of two measures. For most hill farmers and those involved in extensive farming systems the three options most likely are 1. Limiting Chemical Nitrogen usage 2. Extensive Livestock production and 3. Space for Nature.

With regard to the Space for Nature measure, if you are over 7% it qualifies as one measure and if over 10% it will qualify for both measures required.

Organic Farming Scheme

There was a major increase in funding for Organics in the new CAP – increasing from €10m to €51m annually. There is also a significant change in the stocking rates (reducing from 0.5LU/Ha to 0.15LU/Ha) which will make it more acceptable for extensive farming systems.

Payment rates are: Dry stock up to 70ha – €300 (conversion) €250 full organic.

In addition, there is a participation payment (irrespective of farm size) of €2,000 for first two years and €1,400 thereafter. This will help cover the certification costs. Also under the new TAMS – On Farm Capital Investment Scheme organic farmers will qualify for 60% grant aid.

Finally, important to be aware that farmers won’t get paid twice on an area based measure so if also considering joining ACRES then discuss in detail all options with your Farm Advisor.

However, there is one exception to this that being the Agro-forestry Scheme.

Agro-Forestry

This is a scheme that facilitates both farming and trees in partnership. The scheme requires farmers to plant between 400 and 1000 trees/ha. These can be thinned out in time to between 160-250 trees/ha. Minimum area is 0.5ha and at least 20m wide. There is and establishment grant (that includes fencing) of €6220/ha paid in two instalments. Premium rates which are for five years are €625ha up to 10ha and €660 over 10ha.

INHFA are looking to get changes on this with regard to trees, the inclusion of hedgerow and extension on the premium term up to 20 years.

Young Farmers

Similar to the current CAP Programme a top-up payment on a per hectare basis will be available for qualifying Young Farmers. This payment will be available for five years and farmers must have a Green Cert and be under 40 on application. Payment will be made on up to 50ha. In addition to this qualifying Young Farmers can apply to the National Reserve and have their payment rates (for BISS) brought up to the national average if currently below.

Forgotten Farmer Group

For the Forgotten Farmer Group, they will see a once off payment and will qualify for 60% support under the Farm Improvement Scheme. For over 60% of farmers they will see an increase in their payments resulting from convergence, the front-loading of payments and the flat rate Eco-scheme. A significant part of this will be delivered in 2023.

NEW CAP Supports – payment model

  • This is based on a farmer with 30ha and 12 suckler cows or 150 ewes
  • Total Pillar 1 support (@ National average €246) €7,380: Suckler/sheep support €1,800: ANC payment €3,782: ACRES €4,000: Organic (on 25ha) €7,500: TOTAL €24,426

Land Designations

Land designations have become an increasingly significant feature of Irish agriculture since the introduction of Environmentally Sensitive Areas (ESAs) in the 1990s.

Introduced under EEC regulation, these ESAs aimed to encourage farming practices which were “compatible with the requirements of conserving natural habitats”.

ESAs were to make way for our National Heritage Areas (NHAs) as we moved through the 1990s. The NHAs then became the baseline national designation, and their introduction saw a significant increase in the area of land designated.

These designations were usually clearly demarcated, with boundaries such as rivers, roadways, walls and ditches.

Subsequently, EU designations in the form of the Natura 2000 network were introduced on the back of the habitats directives in 1997.

The new EU designations took the form of Special Areas of Conservation (SAC) and Special Protected Area (SPA) when introduced. These did not replace the NHAs but became a further designation on lands.

Currently, there are over 400 Natura 2000 sites covering over 700,000ha or 13% of the land area of the country.

The sites are designed to protect species and habitats, with 28 species of land mammal, over 400 species of birds, in excess of 4,000 plant species and over 12,000 species of insect detailed.

When first introduced at EU level the Oireachtas had not passed the necessary legislation to qualify SAC designations. As a result, all Irish SAC designations were initially classified as candidate designations.

However, all restrictions for farmers that related to a fully ratified Natura 2000 designation still applied.

The process of applying full SAC status to these sites commenced in 2017, with the National Parks and Wildlife Services (NPWS) contacting landowners and notifying them of the new status.

This process is currently ongoing. So if you are a landowner with an SAC site and you have not yet been contacted, then the expectation is that you will be in the coming year.

For farmers with SPA sites this ratification process has already been completed.

On the establishment of the INHFA we recognised the major issues these designations were causing which is why we included the term Natura in our name. We have also been working to reduce their impact and to find financial supports for the major burden they are imposing on landowners.

Currently the Natura 2000 network of designations (SAC & SPA) covers 14% of the country with many of these designations west of a line from Lough Foyle in North East Donegal to Cork City.  In addition to this most of these designations falls on hill lands both commonage and private hill land.

The Natura 2000 designations were introduced as a response to falling biodiversity across the European Union with their objective been to protect the high levels of biodiversity that existed in certain areas. So in simple terms the designations were recognition of a job well done by landowners in relation to protecting biodiversity and the vital habitats across our hills on in river basins.

Unfortunately, the management of these designations by State Bodies has been an utter disaster. Farmers and landowners who had delivered habitats worth protecting were side-lined and State Bodies prioritised a policy of preservation over conservation. This policy was best illustrated through the 38 Activities Requiring Consent (ARC’s) that compelled farmers to get permission from the NPWS or the Local Authority to carry out normal farming activities.

The activities requiring consent included mulching, controlled burning, topping, spreading lime, fertiliser, slurry or farm yard manure. Permission is also required if you want to change the type of stock or introduce a new stock type (eg introducing cattle if they were not there before) or if you are significantly increasing or decreasing your stock numbers.

For landowners looking to put up a new fence, or planning to use a digger on land for any reason then they are expected to get planning permission from the Local Authority (County Council). This planning application will require a Natura Impact Statement (Environmental Assessment Statement) that could cost anything from €1,000 to €3,000.

What all of this has done is to restrict landowners/farmers from carrying out the very activities required to manage and protect these habitats. As a result of this we have seen a regression in the habitat status on many of these sites with no consequence for the environmentalists and State authorities that have contributed to this regression.

Currently the INHFA are working to address many of these issues and ensure that farmers are protected and rewarded for their efforts. We are also seeking financial recognition for the loss of income and the clear devaluation these designations has imposed on these lands.

Finally, for the many farmers that are not impacted by these designations there is now the looming threat of further designations under the EU Biodiversity Strategy that demands designations on 30% of each countries land base. In addition to this there are also proposals to introduce a new designation type called Strictly Protected across 10% of each countries land area. This new designation where applied will see the cessation of all farming activity and is rewilding by another name.

Impact on Farming

In total there are 38 different actions that require consent (ARCs) on a SAC or SPA (Natura 2000) site.

These actions are listed on this page. Please click here to see those 38 ARCS

For landowners with Natura 2000 lands it is important that you are aware of these ARCs as they will impact on your farming activity.

While it is unlikely that all 38 actions will apply to any one site, it is quite probable that 20 or more will. Landowners who have been notified of full SAC or SPA status will have been informed of what specific action(s) applies to their sites.

The impact of these restrictions can vary depending on farming requirements. On a more benign level they can delay critical decisions and actions. However, for some farmers they have added an extra cost through the requirement of planning permission for actions such as fencing.

Where planning permission has been required farmers have often spent in excess of €4,000 through engineering fees and employing expert help in developing a Natura Impact Statement. This is an additional cost that farmers on non-designated land do not incur. Designations can therefore undermine farm profits.

Impact on land sales

In addition to the added costs outlined, farmers with Natura 2000 land are now required to list the designation as a burden on their property folio.

In the event of them selling this land they must notify that person in writing prior to the sale that the property is a European Natura 2000 site and indicate any restrictions that applies to it.

This is having a major impact on the sale price of this land, as was outlined to the INHFA in discussions with auctioneers across the west and northwest.

Findings from these discussions indicate a devaluation of at least 50% on land with a Natura 2000 designation, with one auctioneer in the northwest putting the loss at €2,500/acre.

Land Eligiblity

During 2014 and early 2015 a number of Department of Agriculture inspections targeted at marginal, mountain and commonage lands resulted in farmers receiving penalties of up to 100% on their Single Payment Scheme. These penalties were imposed on the basis of insufficient farming activity. Yet in doing so the Department of Agriculture never set out a criteria for what they defined as insufficient farming activity. Neither did they take into account the environmental condition of these lands or indeed carry out an appropriate assessment where lands had a designation on them – most of the lands targeted had designations on them.

The consequences

Green Low carbon Agri-Environmental Scheme

The consequences of these inspections were two-fold. For any farmer that had land deemed ineligible there was an immediate loss of income for 2014 and a continued loss of income for the duration of the CAP Program till 2020. For all other farmers especially those on marginal lands, they were left with the dilemma of what land to take out and what land should they leave in when filling out their Basic Payment Forms. As the Department had no criteria defined then this became a guessing game that could cost farmers a lot of money.

Getting results

During the Spring of 2015 the INHFA highlighted this issue through our own public meetings and the media. We also challenge the Department through the media, the public information meetings they held on CAP and the Joint Oireachtas Committee on Agriculture to justify their inspection model. Private meetings were also held with Senior Department of Agriculture Officials to try and advance a solution. All of this created the desired effect as by mid-April Land Eligibility had become the major issue in farming circles and one that could no longer be ignored. Significant moves were made by the Department on the 21st April when they announced that provided land is available for grazing then it meets the criteria for eligibility. Other issues around eligibility were highlighted such as burning, the definition of a bogland, heather height, the density of furs and other invasive species. However these are issues we would expect to get resolved and are presently seeking clarification on.

“Seeking Fairness Not Favouritism”

Public Access and Dog Control

Following a significant increase in the number of people accessing our uplands there is now an urgent need to reassess how this is impacting on landowners, local communities and the overall tourism sector. While the increased tourism activity in many communities is a welcome development it is also important to ensure that it doesn’t come at a cost to local people and the landowners who farm these lands. Farmed land is almost exclusively, including commonage, owned land, identical in ownership to a persons’ home or back garden. The vast majority of farmers are willing to facilitate access on their lands provided this goodwill is not abused or their farming activity undermined. There are also some farmers that are not willing to make their land available for public access and this must also be respected, and this fundamental right protected.

 

In a survey we conducted with our members several issues featured strongly. Over 70% of farmers had recreational users crossing their land on a daily or weekly basis. That frequency places significant pressure on the relationship with farmers particularly when over 80% of farmers reported that
recreational users have dogs with them. A further 62% of farmers reported that recreational users had refused to remove dogs from farmland when requested to do so by the farmer. Farms are workplaces with significant risks that must be managed due to the presence of large livestock, heavy machinery and seasonal pressures. There is ongoing unease in relation to insurance liability of public access on farmland. This concern may be heightened by the revival of the practice of larger livestock grazing on uplands. Farmers are concerned that if an incident happens on their farms’ cases will be taken against them; unlike large and institutional agencies or businesses it is very difficult and daunting for an individual to challenge any negative judgment.

A stark outline of the real difficultly farmers face on their own land has emerged from this research. There are very concerning safety issues arising in the survey of farmers feeling threatened and being actually threatened when faced with groups or individual recreational users. Almost 60% of farmers reported having been verbally abused by recreational users. A further 40% reported that they had either been threatened or felt threatened by recreational users accessing their farmland. This is not tolerable.

What came out very strongly in the survey was that there appears to be widespread ignorance of farming practices and ownership of all kinds of farmland, many recreational users do not seem to appreciate that when they walk on farmland they are entering owned land and entering a farmers’ place of work and livelihood. Further, many of these farmlands are found in areas of NATURA 2000 sites (Special Areas of Conservation (SACs) and Special Protection Areas (SPAs)) and National Heritage Area . The lack of joined -up thinking and public access management raises serious concerns for their future environmental protection. Farmers can no longer tolerate the laissez-faire approach of tourism promoters and government and various development bodies that are encouraging outdoor pursuits on farmland but not providing any protection to farming families in their own homes and farms.

The basis for this policy paper is to provide legislative reassurance for those farmers who, on a daily, weekly, monthly basis have members of the public accessing their lands. And to engage with bodies whose responsibility is to manage dog control and those who are promoting walking on farmed land; to address the problems created by the public accessing private farmland.

As outlined above prominent issues that have emerged include:

  • Dog Control
  • Concerns around Insurance and Liability
  • Awareness of land ownership and rights and respect and safety for landowners and;
  • Environmental impacts of increased public access.

 

In this policy paper, we have limited our proposals to these key areas.

Dog Control

Based on the survey and direct contact with farmers, dog control (or the lack of dogs being controlled) is a major issue. Commonly farmers are reporting from first-hand experience witnessing dogs that were supposed to be on leads roaming free and stressing sheep. Some of the replies that farmers reported in this INHFA survey included :

“Some Walkers think they are entitled to let their dogs run without a lead in wide open spaces”

“Told to cop myself on that their dogs would not bother sheep despite sheep being in the immediate vicinity”.

An often reported comment:

“Told to mind my own F***ing business”

“They definitely were not going to abide by requirement to not bring dogs. I back off because there was three of them and I was on my own”

When we consider all options regarding this, we have concluded that the best option for both farmer and recreational users is a complete ban on all dogs by recreational users on our farms.

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The Square, Tubbercurry
Co. Sligo F91 YPN3

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