Last week I reported on the ‘what and the how’ of the greening measures and what they mean for farmers using arable land – mainly tillage farmers. Some will have to grow additional crops on their farms, others have enough crops already to meet the diversification requirements. Growers seem to have grasped this new obligation, but the second obligation to provide environmental focus area, or EFA, is still not fully understood by many farmers.

While the details pertaining to EFAs have not been completely finalised, it is now important that farmers know and understand what the rules entail and what they will mean for each farm. The thresholds of 10ha and 30ha for crop diversification and the 15ha threshold for EFAs are important because either of these could mean a greening penalty.

Greening will account for 30% of the final payment or it is an additional 42.857% top-up on the new basic payments. Failure to comply with greening requirements will mean a loss of the greening payment, plus an additional penalty, resulting in a net 35% loss of potential payment. There may be a level of amnesty on the penalty for the first two years – to be confirmed.

As I indicated last week, the Department is currently exploring the on-farm issues for EFAs along with the system being used to implement its requirements. This has involved a number of farm visits in recent weeks, some to Wexford and some to Kildare, and these are ongoing.

Farm experiences

The farm visits were used to help check the information generated by the new operating system against what was actually seen on the ground during the visit. Specific farms were visited and the details for greening were prepared in advance. They were checking on both the diversification and EFA requirements.

These visits were to be a learning process to help develop an operating system that would work, with as little as complication as possible, and which would enable payments to be made with minimal disruption. But as well as being workable, the new system must still implement the requirements of the new EU regulations.

The recent farm visits included two in Wexford and two in Kildare. I joined in the Kildare visits where the Department has estimated the EFA requirement for the individual farms using the landscape features identified by computer software. The visitors came equipped with farm areas, crop areas, the EFA requirement and the calculated EFA available on that farm. The results from these observations were interesting.

The Wexford visits confirmed that the hedged landscape of much of that county will provide individual growers with more than enough EFA from the hedges alone. On one farm, the hedges contributed over 7% in EFA before any other eligible feature was considered. And there was generally no issue with the make-up of the hedges.

The calculations, done by specialised feature recognition software, tallied well with what was found during the visits by the Department personnel. The features identified were both present and adequate on both farms.

The situation on the Kildare farms was somewhat different. Bigger fields and filled-in drains often resulted in fewer features to contribute to EFAs. Some of the hedges present would not qualify as EFA as they were merely grassy banks. But these banks will be seen by the computer, which will suggest that it is eligible as an EFA. However, it is not and it will be up to you, the farmer, to state that it is not because it does not have woody vegetation present.

Like other parts of the country, some hedges were accompanied by parallel ditches or open drains but it seems unlikely that both will qualify, i.e. that one would be allowed 5m2 of EFA for the hedge plus 6m2 for the ditch. If this is the case, then selecting the ditch will secure more EFA for that feature.

One of the farms had arable land that runs alongside the river Liffey – a water abstraction source. This will now need 2m of uncultivated zone under nitrates and it seems likely that this can be used as EFA (subject to confirmation) but the area allowance is expected to be wider than the minimum 2m required for nitrates.

One of the farms visited had just over 120ha of crops and the Department calculated that this farm required 7.13ha of EFA. The same assessment process calculated that the farm had 5.65ha of EFA actually present. However, the inspection showed that some of the EFA features no longer exist while others were ruled out or had to be questioned. But there were also other features, such as a small amount of forestry, that were not included in the assessment. Neither was the essential buffer by the Liffey included.

So the corrections will be made and the numbers recalculated. All farmers subject to greening will have to work through this process. But if the altered assessment still does not leave adequate EFA, then a protein crop will be considered. Indeed, it is being considered either way on this farm.

Fallow

The second farm was about 90ha in a single block of crops. This farm was calculated to require roughly 4.5ha of EFA. This was a very tightly run tillage operation with only boundary hedges remaining. Some of this hedge length had no woody content and so would not be eligible for EFA. Some of the boundary area is a river which is a designated watercourse and so cannot be used as EFA. If this were just a drain it could be used in the calculation. The calculated EFA available was 2.2ha but some of this was ruled out by the inspection.

The same watercourse ran through the land in other places but again there was little or no hedging or trees on either side of most of it and so very little to accumulate EFA. If this was not a watercourse but rather a drain then it would get a 6m2 allowance per metre of length.

A pond had been installed some years ago to help drainage on low ground and this can be counted as EFA but it was not included in the original calculation. And new buffer strips will have to be installed for nitrates and these will then qualify for EFA. But a farmer will have to know these things to be able to judge his assessment when it arrives next autumn.

This farm had a length of boundary hedge planted with trees (oaks) on the field side of the boundary in a slightly staggered fashion. The boundary hedge would allow 5m2 while trees in a line are given 10m2 per metre length. But, given that both exist, which must be given priority when features coexist?

This particular farm had a section of low-lying land in set-aside or fallow since 1993. It was continuously maintained by planting grass and regular topping outside of the nesting season. However, the fact that a previous application declared that it was sown to grass at some point in the past has meant that some of this land is now designated as permanent pasture, which is excluded, rather than fallow which would provide the EFA. If this land was designated as fallow, which is what it is only that it is well maintained rather than just growing rubbish, then this would provide more than enough EFA on that farm.

If this does not happen, then beans will be added to the current mix of three crops to provide the required EFA. However, if the grass area is accepted as fallow, the requirement for EFA will increase because the fallow land will be included in the initial calculation.

Both farms are already growing three crops excluding the ‘permanent pasture’.

Possible EFAs

There is quite a big list of potential features that can be used as EFAs under EU rules. Individual options have different ratings depending on the rules, with hedges and trees in a row given 10m2 per metre of length, ditches are 6m2, etc. But other measures are less than one. Protein crops were originally designated at 0.3 but will now be 0.7; areas of coppice are 0.3, etc. Other possible areas include fallow, buffer zones beside watercourses, etc.

The priority for Ireland will be hedges and ditches and then other features will be included, as necessary, to enable farmers to qualify. But not all these options will be available to Irish farmers.

Watercourses are not allowed as EFA but the buffer areas that must be in place beside them are allowed.

Under declaration

In the past it was not a problem if an applicant claimed a smaller area than was actually in a parcel as long are there were adequate hectares for the number of entitlements. This will be different in the future, especially for some people. For those relatively close to the thresholds for two or three crops (10 or 30ha in crops and temporary grass), or the 15ha for EFA, to under-declare could be deemed as an attempt to avoid some of the greening measures. So under-declaration of field size will be an issue in the future, especially for those close to the thresholds.

COMMENT - The process must be done

Every grower will have to go through this process, but by him/herself or with an adviser, and this is very important. To end up with insufficient EFA or the wrong crop diversification percentages will mean the loss of about 35% of the total new payment.

Up to now growers could be forgiven for not paying attention to the evolving CAP situation. But now the time has come to pay serious heed. Individual applicants have to make themselves aware of these new requirements and begin to consider what they will use to provide their EFA and crop diversification. The latter is more straightforward because it is easy to do the sums. Very many growers will have more than 5% EFA available from hedges and/or ditches plus some landscape features. But your EFA calculations can only be done by the Department (with your help), so you must wait for the letter in the post.

Still, the time has come to begin asking questions. A hedge is a woody division between parcels – what have you got? Will it qualify? Do you have unusual features or boundaries; if so will they count? As of now the operating rules are only being developed and can be influenced by what is actually present on the ground. Start thinking and talking. Know what a hedge is. If you have something different ask if it will qualify. If you have other features that might be considered, ask.