Last week I wrote about greening and the new requirements for crop diversification and environmental focus area (EFA). This week I look more closely at crop diversification and what is required to remain compliant.

Growers with more than 10ha of declared arable area in 2013 or 2014 have received, or are about to receive, notification from the Department that they will need to comply with greening requirements in 2015 and beyond, as specified in Table 1.

Firstly, what is crop diversification? The concept is designed to encourage a greater diversity of crops on holdings which have arable land. The exact requirements depend on the arable area that a farmer is declaring. Crop diversification is not required where a farmer holds less than 10ha of arable land. Arable land includes arable crops, temporary grassland (lands that were used in crop rotation during one or more of the previous five years) and arable land in fallow.

The specific requirements differ for farmers with between 10ha and 30ha of arable land and those with over 30ha. The relative proportions of your main crop and second crop are also specified for your arable land. These thresholds are summarised in table 1.

All farmers are required to comply with these greening requirements but many are seen as “green by definition” and will be exempt from having to take any additional action under greening. Those that are exempt from greening include:

  • Where the area of arable land declared in 2015 is less than 10ha;
  • Where more than 75% of the eligible agricultural land area of the holding (as declared under the Basic Payment Scheme in 2015) is grassland (temporary plus permanent pasture), provided the arable area not covered by these uses (arable crops plus temporary grassland) does not exceed 30ha;
  • Land involved in organic farming where the farmer is registered with the Department of Agriculture and licensed by one of the organic control bodies. However, such exemption only applies to that part of the holding which is farmed organically.
  • Arable farmers, who apply to participate and are accepted in the GLAS Agri-Environment Scheme. Such farmers will have to meet the requirements in relation to the sowing of winter cover on their tillage lands.
  • What crops are regarded as different crops?

    Most of the crops grown in Ireland satisfy crop diversification requirements. These include barley, beans, beet, lupins, maize, oats, oilseed rape, peas, potatoes, wheat etc. which are all separate crops. In addition, the winter and spring version of the same crop, e.g. winter and spring barley, are considered as two separate crops for crop diversification purposes.

    Vegetables are also regarded as separate crops but care is needed here as, for example, broccoli, brussels sprouts and cabbage are referred to as being the same species and are regarded as being the same crop.

    Arable fallow land and temporary grassland can also be used for crop diversification and can be regarded as separate crops. Permanent crops such as miscanthus and willow are not allowed for crop diversification. Permanent pasture is not allowed as a separate crop.

    Many farmers are now considering crop rotation to fulfil the crop diversification requirement. The new premium for protein crops will help make these crops more attractive. There is no obligation for rotation in crop diversification but in most instances this may be the best way to make good economic advantage from a number of crops.

    Some tillage farmers are considering temporary grassland as one of their crops with contract rearing of replacement stock in mind. However, temporary grassland must also be rotated to prevent it from becoming permanent pasture in time. Temporary grassland may be particularly attractive for single-crop farmers with less than 30ha where the ploughing up of some permanent pasture could occur.

    Some growers with only one crop will have the option to use an equivalence measure for crop diversification. For those who wish to avail of this, it can only be done through participation in the new GLAS scheme. Farmers with all spring crops (e.g. either malting or feed barley) will have the option to meet their crop diversification requirement by planting a green cover crop on their tillage area before 1 October.

    To avail of this option, growers must be participants in the GLAS scheme. So, if you are planning on opting for this equivalence measure, it is critical that the application to join GLAS is successful. The intention to meet crop diversification requirement through this winter cover crop in GLAS can be indicated on the 2015 application. The green manure option applies in the year following the crop and not the preceding year.

    This GLAS measure could also apply to farmers who have only one or two crops with more than 30ha of arable if they wish to continue with only their current cropping arrangement. Under the GLAS proposals submitted by the Minister for Agriculture, Food and the Marine as part of the 2014-2020 Rural Development Programme, farmers with over 30ha of arable crops are included in Tier 1 and, therefore, will have priority entry into the scheme. The Department is currently seeking clarification from the Commission on equivalence requirements for arable farmers under GLAS. I will keep you updated on these arrangements.

    It is not yet clear if the whole tillage area will have to be planted with winter cover or only a proportion. Nor is it clear as to whether this cover crop can be grazed in springtime. Obviously one cannot put in a catch crop onto temporary grassland which forms part of the arable area.

    Green catch cropping is also an option to provide EFA. However, the same area cannot be used for both purposes.

    What happens next?

    In order to help farmers meet their greening requirements, the Department of Agriculture is currently developing an online system to help cater for the greening requirements. This will allow arable farmers, who may be subject to greening practices, to cross-check the specifics of their holdings at application time to help ensure that they will be compliant with crop diversification and EFA requirements (more on the EFA requirements next week) based on current practices. This cross-check will alert individuals as to whether additional actions are required.

    The Department is currently using details from the 2013 or 2014 SPS application areas (where processing is finalised) to determine whether the farmers that are subject to crop diversification will meet the thresholds outlined above. This will alert farmers as to their requisite number of crops and whether the percentage of each crop group satisfies the requirements.

    Online application 2015

    The Department has decided that all of the farmers who must meet greening requirements (crop diversification and/or EFA) must apply online from next year onwards. There are a number of reasons for this.

    Firstly, it would be very difficult to deal with the practicalities of greening using paper applications and it would inevitably result in delays in the processing of applications. This could have consequential delays in the issuing of payments.

    Secondly, an online application system will enable the Department to help farmers ensure that their application is valid. This is particularly important with EFAs but it will also be important in the case of crop diversification. The system will provide cross-checks during the application process to ensure that the crop diversification requirements are met.

    Farming close to the thresholds

    Farmers who think they are exempt because they are just below a threshold need to be very certain about parcel areas. For example, a 9.8ha claim (less than the 10ha minimum threshold) of arable crops could be in breach of crop diversification if the inspected area turned out to be 10.1ha.

    It is also worth remembering that many farmers did not increase their claimed area on parcels since the coupled Arable Aid Scheme finished in 2004. Since then, arable farmers were entitled to claim the margin or headland and the hedge/ditch.

    So in the case of the previous example, if an inspection determines 10.2ha of arable land in 2015, that farmer will have his greening payment reduced if he has only one crop sown.

    It is vital, therefore, that arable farmers ensure that they are claiming all of the eligible land in their 2015 application. This is particularly important for those farmers that are declaring arable just below the different thresholds of 10ha, 15ha (for EFA) and 30ha (for the three crop rule) to ensure that they are claiming all of their arable lands.

    A similar note of caution applies to farmers who are declaring up to 75% for their main crop and close to 95% for their two main crops. For these reasons, avoid being too close to any of these important threshold values.

    A second risk of unconscious breech could occur where land in grass is rented for grazing but where it is temporary grass rather than permanent pasture. Temporary grass is arable land and this is subject to both crop diversification and EFA. So arable farmers renting grassland for 2015 must establish whether it is permanent grass or temporary grass. The online application will alert applicants to this potential problem.

    Recent farmer questions

    At the recent Crops and Sprayers event in Kildalton, Department personnel encountered a range of questions from farmers and some of these are outlined below, along with answers provided by the Department.

    Q. My 100ha farm is used for crop production and I intend to sow the following areas of crops in 2015: 74.5ha of spring barley; 20ha of beans and 5.5ha of oats. Will this be acceptable?

    Yes, this is acceptable but caution is urged in relation to sowing too close to the thresholds. Also bear in mind that the cropped area will now include field margins and hedges but this is the same for all the crops declared and so should even itself out.

    Q. Crop diversification is also known as the three crop rule. Can I plant five crops from 2015? Are there things I need to be careful about with regard to crop diversification rules?

    You will be compliant if you are planning, for example, 20ha winter barley, 20ha spring barley, 20ha of spring wheat, 20ha of oilseed rape and 20ha of beans. However, if you grew 80ha of spring barley and 4ha oats, 4ha beans, 4ha of beet and 4ha of potatoes, you will not meet the crop diversification requirement as the main crop is greater than 75% of the total area of arable land. Remember that your main crop cannot be greater than 75% and your two main crops cannot be greater than 95% irrespective of the number of arable crops you plant.

    Q. I intend to grow over 30ha of seed potatoes, main crop potatoes and winter wheat next year. Will I meet my crop diversification requirement?

    No. Seed and main crop potatoes are the same crop and, therefore, you will not meet the three crop requirement.

    Q. If I am renting in land next spring how can I ensure that it is permanent grassland rather than temporary grassland?

    The Department intends to operate a helpline so you can contact them and confirm if land is temporary or permanent grassland. Alternatively, if you have the land parcel number you will be able to access the relevant details on the online application system when it becomes available in the autumn.

    Q. I have never altered the claimed area of my parcels since 2004 when the Arable Aid Scheme ended. What impact will the new requirement to include headlands and hedges in my claimed area have on the number of new entitlements I will be allocated in 2015?

    The Minister for Agriculture decided earlier this year that the number of entitlements that a farmer will be allocated under the Basic Payment Scheme (BPS) will be based on the number of eligible hectares in either 2013 or 2015, whichever is the lower. If, for example, you declared 50ha in 2013 and then declare 53ha in 2015, you can only be allocated 50 new entitlements. However, you will have a buffer of 3ha in case of any future over-claims.

    Q. I currently have 100ha under arable crops but I am converting from arable to dairying in 2015 once milk quotas are abolished. Will the greening requirements apply to me in 2015?

    No. If you convert all of the land to grassland, you will be exempt under the 75% grassland rule. If, however, you planted 35ha of maize you would be required to meet the three-crop rule and the 5% EFA on your 100ha.

    Q. I am currently in a share farming arrangement. I farm 60ha, 40ha of which are under winter wheat under a share farming arrangement.

    If you apply on your own behalf next year, you will have to meet the three-crop rule and the 5% EFA. The Department is reviewing this matter. If share farming arrangements can be recognised at the end of this process, it will be necessary for all of the lands farmed by farmers in share farming arrangements to be submitted on one application.

    Getting help

    The Department has established a dedicated telephone number (0761 064441) and e-mail address (greening@agriculture.gov.ie) to deal with your greening queries. You can apply online in the usual way at www.agfood.ie. If you are having difficulties registering contact the helpdesk at 1890 252 118 or 0761 064424.

    Alternatively, you can authorise an agricultural consultant or Teagasc advisor to apply on your behalf. Authorisation forms to make this application can be found at http://www.agriculture.gov.ie/agfoodinformationpages/agfoodagentforms/