Most serious tillage farmers will be aware that there are many strings attached to the new CAP regime from 2015 onwards. Given all the recent talk about what is needed to establish the new entitlements, it is obvious that all farmers are aware of this aspect of the changes. However, matters relating to the new greening measures are equally important and tillage and mixed farmers have a lesser understanding of what these involve.

Two initial points

1. The greening measures will account for 30% of the total payment that a grower is entitled to from 2015 onwards. Greening means three things:

a) Controls on the ploughing up of permanent pasture, but this is a national rather than an individual issue.

b) Crop diversification on individual farms, which is a minimum of three crops for those with more than 30 ha of cereals and temporary grass or a minimum of two crops for anyone with more than 10ha in tillage and temporary grass.

c) Farms with more than 15ha in tillage and temporary grass will need to have 5% of their land area in uses compliant with Environmental Focus Areas (EFAs). Such areas include hedges, ditches/open drains, landscape features, ponds, buffer strips, trees in a line, coppice, etc and protein crops but only some may be allowed.

2. The second point is greening applies to all farms but livestock farms with more than 75% of the land base in grassland (permanent or temporary) are exempt from the greening requirements providing that the remaining 25% of the area does not contain more than 30ha of arable land.

The system

The Department of Agriculture must now develop and put in place a system that identifies and calculates the requirement of greening for all those affected by the new measures. The system must be workable to avoid excessive complications for applicants but it must implement the new EU regulations.

At the moment the Department is evaluating a computer system that identifies landscape features, such as hedges and drains, and using software to calculate both the EFA requirement of farms and the estimated EFA area present on that farm. This is being tested and evaluated on some farms and Department staff are then assessing its validity on the ground.

This system works by picking up features from OS maps but some of these may or may not still be present. Hedges may have been removed in the intervening period or others may have been planted. And the definition of what exactly constitutes a hedge is still to be clarified but unplanted hedges will not be eligible. Large gaps in a woody hedge might also be an issue.

The constitution of a hedge can also be a problem. It does not need to be built on a bank but it will need a woody component, such as whitethorn. Banks that are almost exclusively grass will not qualify and these are present on many farms. The species sown to make the hedge could also be an issue, with native species preferred.

Last week I was out on two farm visits with Department officials in Kildare. The previous week they visited farms in Wexford. Before the visits Department staff previewed the specific farms, did the assessments, calculated the EFA required and then went on farm to verify the presence of the features identified by the software and see if these were usable under the EFA regulations.

At the outset the EU has allowed quite a number of features to be used as EFAs. Hedges and ditches are the priority for Ireland and where these do not suffice, the Department is now considering what other options it will allow. There are many items that might be acceptable.

From an administrator’s perspective, the challenge is to have the guidelines clear enough to avoid uncertainty, which could lead to complications at inspection time. So while certain features may contribute to the environment they may not be allowed because they cannot be clearly and unambiguously described in the guidelines.

Examples would be what constitutes a hedge? We saw beech hedges and talked about other hedges made from different species, as well as whitethorn. The general consensus appeared to be that if a planted hedge (say beech) backed onto another agricultural area, e.g. another field or a farm yard, it might be counted as EFA but if it backed onto a house, garden or amenity feature it may not be deemed agricultural and therefore is not usable as EFA. All these issues remain to be confirmed.

EFAs can only be supplied from the cropped areas of the farm (cropped includes temporary grass). However, where an area of permanent pasture is adjacent to a tillage field(s), the hedges and drains in this area may also be added to those in the cropped fields to provide EFA. Clarification is also needed here.

Adjacent is meant to imply touching but if there is a drain, river or farm roadway on the pasture side of the hedge, these may still mean that the permanent pasture is adjacent, allowing the features to be used as EFAs. Adjacent does imply the other side of a hedge rather than one narrow field away.

How the system will work

One of my big questions was how will the calculations work? How will the percentages be calculated? Will EFA be a percentage of the full parcel area or just the actual area sown?

Firstly, the most correct answer is none of the above. Arable parcels are now being looked at again and the parcel areas are being looked at in terms of total area and EFA area. These are the figures that will be used in the calculations. But you can take it that the area will be close to the map area with the obvious exclusions. So this will be the starting point.

Then in the holdings subject to greening each individual parcel will be assessed to calculate the area of EFA indicated by the computer system and all of the relevant parcels will be added to calculate the required EFA area. The system will also calculate the area of EFA that appears to be available on the farm application.

All of this process will be done by the Department and then sent, with maps, to individual growers to be cross-checked. Because the system uses OSi maps in the background, some hedges or ditches may have been removed since the maps were created and others may have been put in place.

Because the process will use the equivalent of ‘reference areas’ rather than the ‘cropped area’ that most people were claiming, most will find that the EFA requirement will be slightly bigger than anticipated.

The area on which EFA is calculated will be the parcels being cropped plus those in temporary grass. So for a parcel with a hedge around it, half of the designated 10m2 footprint is given to that parcel and the other half to the adjoining parcel, whether it is yours or not. So boundary hedges only get half the allocation. The parcel areas used will include hedges, ditches, features, etc, and this will also become the area of the actual parcel in which the crop is grown. So crop areas will be bigger and this will slightly reduce the consequence of convergence.

Online registration

The new system is very complex and only the Department will know much of the details needed. At the moment it is trying to cross-check the computer software that is doing the calculations with the actual situation on the ground in some farms. It wants to be as aware as possible of the situation on the ground so as to help prevent problems occurring later by getting them ironed out in advance of the roll-out. But the hope is that this will be done by autumn because that is when winter crop growers will need to make decisions to meet their EFA and three-crop obligations.

For those who will not have adequate hedge, ditch or landscape features or buffer area to meet their EFA requirement, a crop like beans or peas may be the only option. Originally it was proposed that a hectare of beans would only account for 0.3ha of EFA, but it now looks like that figure will be 0.7ha per hectare for EFA purposes. But, as stated previously, it is up to each applicant to ensure that the EFA allowances are valid and that the stated structures or crops exist.

From 2015 onwards, 5% of the area in crops and temporary grassland must be in some type of allowable EFA. But we must all be aware that there is a provision for the EU to increase the EFA percentage from 5% to 7% from 2017. This must be regarded as a serious possibility and should be considered in the package of changes that will take place at farm level to supply both diversification and EFAs.

The complexity of applications from 2015 onwards will mean that the process will need to be done online. The Department is building a system that will do the cross-calculations to help prevent problems. Once you enter all the parcels that you are farming, your application will calculate your EFA requirement, tell you the percentage you have of different crops and if you are eligible for greening, and then calculate (based on the instructions you will have given earlier) the amount of EFA available on your farm for the different features allowed.

That whole process will be automated, so online application will be essential.