The significance of a farmer being defined as an active farmer and the criteria used to determine this classification has been in the spotlight now for many years.
Under the current Common Agricultural Policy (CAP) Rural Development Programme (RDP) 2014-2020, a farmer can receive their Basic Payment Scheme (BPS) regardless of the level of agricultural activity carried out on their holding.
There are 127,000 prospective eligible BPS beneficiaries with the latest information published by the Department of Agriculture showing that there were 122,637 farmers classified as eligible to receive a BPS payment in 2021.
The system has frequently faced criticism with issues raised including that it encourages inactive farmers to hold on to their land and draw-down payments, limiting the area of land available to active farmers.
The system will remain similar for 2022 before significant changes are introduced under the CAP Strategic Plan 2023-2027.
From 2023 if up to 30% of a parcel is made up of scrub then the entire land parcel will be deemed eligible provided an agricultural activity takes place on it.
It is important to note, however, that some of the changes that will be introduced in 2023 will be directly affected by the level of agricultural activity practiced on your holding in 2022.
This applies to a number of the measures proposed in the impending eco schemes but before delving deeper in to this area it is crucial to point out that participation in eco schemes and indeed payment of a farmer’s Basic Income Support for Sustainability (BISS – replaces BPS) will be dependent on the holding passing an “active farmer check”.
Active farmer check
The CAP strategic plan submitted by Ireland for approval by the European Commission states that “support shall only be granted to those farmers engaged in a minimum level of agricultural activity”.
This agricultural activity will be assessed on a holding basis and it will require applicants to demonstrate the means by which the agricultural activity is carried out on the holding.
The Department of Agriculture circulated some information regarding these changes to farmers this week and it is important for many that this is not overlooked.
The CAP document submitted to Brussels states that “for an applicant to be deemed active they must demonstrate how they bear the economic and agricultural risk with regard to the agricultural activity being undertaken”.
This check will be completed on an annual basis and the Department of Agriculture highlights that it is a safeguard “to ensure the person receiving the scheme payments is the person farming the land being claimed”.
Grassland farmers
For grassland farmers first, a minimum stocking level of 0.15 livestock units (LUs) per hectare will be deemed active.
A caveat to this stocking density is whereby a lower stocking rate may be justified on environmental grounds, similar to the current process under the Areas of Natural Constraint.
It is essential to also point out that the livestock values, or coefficients, are changing in 2023 in terms of the number of animal classifications and LU value of each as discussed in the section below.
In relation to grassland farmers who maintain their lands by non-grazing means, they will be asked to indicate how land is maintained and be in a position to provide evidence to support this declaration.
Examples listed include the making of hay or silage and in such cases the Department has previously specified documentation such as the purchase of fertiliser/plastic wrap or proof of payments made to cover contracting costs or receipts for sold forages may be required to prove agricultural activity.
Information listed in the documentation received this week by farmers also includes topping as an agricultural activity that can be indicated on the BISS application from 2023 onwards, along with denoting if it is planned to purchase livestock in 2023.
Existing databases such as the Animal Identification and Movements (AIM) and the annual sheep census will be the first port of call.
In addition, further information may be required on specific parcels of lands such as commonage parcels with questions raised where suitable stock are not present on the holding to graze the commonage or where an applicant is claiming on land parcels which are located a long distance from the main farming hub.
What constitutes a “long” distance is not outlined in the documentation but it is likely that it ties in with situations which have occurred in the past such as farmers leasing commonage ground for nitrates purposes.
Tillage lands
A percentage of farmers involved in tillage and/or permanent crops will be subject to administrative checks annually and required to provide evidence of activity.
For tillage farmers, this will likely include documentation such as receipts for seed, fertiliser, pesticides (if applicable), etc.
As is the case for grassland farmers, documentation will need to be in the name of the applicant who has submitted the BISS application.
The Department also outlines that a valid share farming agreement will be deemed as a legitimate means of demonstrating activity.
The Department outlines that it will carry out such checks in the first half of 2022 and write to farmers who are at risk of failing the active farmer check in 2023, based on current Department records.
Livestock unit value changes
Table 1 details the livestock coefficients which are proposed to be used for the purposes of the “active farmer check”, the “extensive livestock production” measure in the eco scheme and compliance with the Areas of Natural Constraint (ANC) scheme.
The current coefficients used for the ANC in 2022 are detailed in Table 2.
The number of bovine categories has been expanded from two to six categories with this change also reflecting the higher level of organic nitrogen and phosphorus excretion from dairy cows based on nitrates figures.
The livestock unit values of a suckler cow have, in turn, been reduced, as has heifers aged in excess of two years.
There are also significant changes proposed in the values for sheep/goats and equine animals. Sheep and goats currently have a LU value of 0.15LU.
This will change to 0.1 under the next CAP and farmers sailing close to the minimum requirements need to be mindful of such.
Breeding mares will be awarded a lower LU value of 0.8LU with the same proviso remaining that mares must have produced a foal in the previous two years.
It is proposed that only 50% of the stocking rate requirement can continue to be fulfilled by donkeys. Deer, meanwhile, will be subject to an on-farm inspection by the Department.
Land eligibility changes
It is proposed that from 1 January 2023, land eligibility rules will change to allow an eligible parcel contain features which are classified as beneficial to the climate, environment, biodiversity and water quality.
Where the area of these features is less than 30% of the total parcel area the whole parcel area will be deemed eligible.
The Department has stated this week that there must be an agricultural activity within the land parcel for it to be deemed eligible with this activity either producing food or crops or maintaining the land in a state suitable for production with practices such as topping or mulching outlined as options.
Eco schemes – considerations
The Department outlines that in order to issue payments for eco-scheme measures before the end of 2023, it intend to use a farmer’s 2022 stocking rate to qualify him/her for payment under the relevant eco-scheme measure in 2023.
The 2023 stocking rate will be used for the 2024 payment and so on. The coefficients outlined in Table 1 will be used for the eco-scheme measure “extensive livestock production”.
Under this measure, a farmer is rewarded for farming between 0.15LU/ha and 1.5LU/ha.
This means that a farmer aiming to participate in this measure and also applying for the ANC scheme in 2022 will need to be cognisant of both the LUs in Table 1 and Table 2.
The 2022 stocking rate will also be used as the basis for qualifying for the eco-scheme measure, “limiting chemical nitrogen usage”.
Farmers participating in the measure will be presented with a chemical nitrogen limit in 2023 based on their 2022 stocking rate.
This stocking rate will be calculated based on nitrates excretion levels for different categories of animals as opposed to the livestock unit coefficients used in Table 1.
Table 3 details the maximum permitted volume of chemical nitrogen which can be used based on the previous year’s stocking rate for grassland farmers.
For those that the Department classifies as “arable farmers” the ruling is that they must limit their chemical nitrogen usage to 10% below the national average on arable crops with this stated by the Department as 139.41kg N/ha.
The level of usage and compliance with the eco-scheme measure will be verified using the proposed fertiliser register which the Department is planning to introduce with usage levels verified in quarter four of 2023.
Soil sampling and appropriate liming
To qualify for the eco-scheme measure, soil sampling and appropriate liming, farmers will be required to undertake soil sampling and apply lime, if recommended.
The Department states that if farmers intend to apply for this eco-scheme measure in 2023 then samples should be taken in quarter four of 2022 at a rate of one sample per three hectares.
The Department advises that care needs to be taken to ensure that three months has passed since the last application of phosphorus or potassium via chemical or organic fertilisers.
Comment: confidence in proposals being approved
It is important to note that the CAP information circulated by the Department of Agriculture is dependent on Ireland’s CAP Strategic Plan 2023-2027 being approved by the EU Commission.
The Department expects the CAP plan to be finalised by September 2022 at the latest which leaves the timelines too tight to wait to move on aspects of the plan discussed on these two pages.
However, the fact that the Department is progressing ahead and has moved to disseminate information conveys a sense that they must optimistic that these measures will be approved.
At least farmers will be expecting that this will be the case, given that changes made in a bid to satisfy scheme requirements may have a profound effect on their business.
The proposed change in the livestock unit value of sheep and goats from 0.15LU to 0.1LU is one that is sure to attract scrutiny from those farming on commonage and hill areas and environmentalists.
The information circulated this week is also sure to raise plenty of discussion at the round of information meetings organised by the Department of Agriculture.
The significance of a farmer being defined as an active farmer and the criteria used to determine this classification has been in the spotlight now for many years.
Under the current Common Agricultural Policy (CAP) Rural Development Programme (RDP) 2014-2020, a farmer can receive their Basic Payment Scheme (BPS) regardless of the level of agricultural activity carried out on their holding.
There are 127,000 prospective eligible BPS beneficiaries with the latest information published by the Department of Agriculture showing that there were 122,637 farmers classified as eligible to receive a BPS payment in 2021.
The system has frequently faced criticism with issues raised including that it encourages inactive farmers to hold on to their land and draw-down payments, limiting the area of land available to active farmers.
The system will remain similar for 2022 before significant changes are introduced under the CAP Strategic Plan 2023-2027.
From 2023 if up to 30% of a parcel is made up of scrub then the entire land parcel will be deemed eligible provided an agricultural activity takes place on it.
It is important to note, however, that some of the changes that will be introduced in 2023 will be directly affected by the level of agricultural activity practiced on your holding in 2022.
This applies to a number of the measures proposed in the impending eco schemes but before delving deeper in to this area it is crucial to point out that participation in eco schemes and indeed payment of a farmer’s Basic Income Support for Sustainability (BISS – replaces BPS) will be dependent on the holding passing an “active farmer check”.
Active farmer check
The CAP strategic plan submitted by Ireland for approval by the European Commission states that “support shall only be granted to those farmers engaged in a minimum level of agricultural activity”.
This agricultural activity will be assessed on a holding basis and it will require applicants to demonstrate the means by which the agricultural activity is carried out on the holding.
The Department of Agriculture circulated some information regarding these changes to farmers this week and it is important for many that this is not overlooked.
The CAP document submitted to Brussels states that “for an applicant to be deemed active they must demonstrate how they bear the economic and agricultural risk with regard to the agricultural activity being undertaken”.
This check will be completed on an annual basis and the Department of Agriculture highlights that it is a safeguard “to ensure the person receiving the scheme payments is the person farming the land being claimed”.
Grassland farmers
For grassland farmers first, a minimum stocking level of 0.15 livestock units (LUs) per hectare will be deemed active.
A caveat to this stocking density is whereby a lower stocking rate may be justified on environmental grounds, similar to the current process under the Areas of Natural Constraint.
It is essential to also point out that the livestock values, or coefficients, are changing in 2023 in terms of the number of animal classifications and LU value of each as discussed in the section below.
In relation to grassland farmers who maintain their lands by non-grazing means, they will be asked to indicate how land is maintained and be in a position to provide evidence to support this declaration.
Examples listed include the making of hay or silage and in such cases the Department has previously specified documentation such as the purchase of fertiliser/plastic wrap or proof of payments made to cover contracting costs or receipts for sold forages may be required to prove agricultural activity.
Information listed in the documentation received this week by farmers also includes topping as an agricultural activity that can be indicated on the BISS application from 2023 onwards, along with denoting if it is planned to purchase livestock in 2023.
Existing databases such as the Animal Identification and Movements (AIM) and the annual sheep census will be the first port of call.
In addition, further information may be required on specific parcels of lands such as commonage parcels with questions raised where suitable stock are not present on the holding to graze the commonage or where an applicant is claiming on land parcels which are located a long distance from the main farming hub.
What constitutes a “long” distance is not outlined in the documentation but it is likely that it ties in with situations which have occurred in the past such as farmers leasing commonage ground for nitrates purposes.
Tillage lands
A percentage of farmers involved in tillage and/or permanent crops will be subject to administrative checks annually and required to provide evidence of activity.
For tillage farmers, this will likely include documentation such as receipts for seed, fertiliser, pesticides (if applicable), etc.
As is the case for grassland farmers, documentation will need to be in the name of the applicant who has submitted the BISS application.
The Department also outlines that a valid share farming agreement will be deemed as a legitimate means of demonstrating activity.
The Department outlines that it will carry out such checks in the first half of 2022 and write to farmers who are at risk of failing the active farmer check in 2023, based on current Department records.
Livestock unit value changes
Table 1 details the livestock coefficients which are proposed to be used for the purposes of the “active farmer check”, the “extensive livestock production” measure in the eco scheme and compliance with the Areas of Natural Constraint (ANC) scheme.
The current coefficients used for the ANC in 2022 are detailed in Table 2.
The number of bovine categories has been expanded from two to six categories with this change also reflecting the higher level of organic nitrogen and phosphorus excretion from dairy cows based on nitrates figures.
The livestock unit values of a suckler cow have, in turn, been reduced, as has heifers aged in excess of two years.
There are also significant changes proposed in the values for sheep/goats and equine animals. Sheep and goats currently have a LU value of 0.15LU.
This will change to 0.1 under the next CAP and farmers sailing close to the minimum requirements need to be mindful of such.
Breeding mares will be awarded a lower LU value of 0.8LU with the same proviso remaining that mares must have produced a foal in the previous two years.
It is proposed that only 50% of the stocking rate requirement can continue to be fulfilled by donkeys. Deer, meanwhile, will be subject to an on-farm inspection by the Department.
Land eligibility changes
It is proposed that from 1 January 2023, land eligibility rules will change to allow an eligible parcel contain features which are classified as beneficial to the climate, environment, biodiversity and water quality.
Where the area of these features is less than 30% of the total parcel area the whole parcel area will be deemed eligible.
The Department has stated this week that there must be an agricultural activity within the land parcel for it to be deemed eligible with this activity either producing food or crops or maintaining the land in a state suitable for production with practices such as topping or mulching outlined as options.
Eco schemes – considerations
The Department outlines that in order to issue payments for eco-scheme measures before the end of 2023, it intend to use a farmer’s 2022 stocking rate to qualify him/her for payment under the relevant eco-scheme measure in 2023.
The 2023 stocking rate will be used for the 2024 payment and so on. The coefficients outlined in Table 1 will be used for the eco-scheme measure “extensive livestock production”.
Under this measure, a farmer is rewarded for farming between 0.15LU/ha and 1.5LU/ha.
This means that a farmer aiming to participate in this measure and also applying for the ANC scheme in 2022 will need to be cognisant of both the LUs in Table 1 and Table 2.
The 2022 stocking rate will also be used as the basis for qualifying for the eco-scheme measure, “limiting chemical nitrogen usage”.
Farmers participating in the measure will be presented with a chemical nitrogen limit in 2023 based on their 2022 stocking rate.
This stocking rate will be calculated based on nitrates excretion levels for different categories of animals as opposed to the livestock unit coefficients used in Table 1.
Table 3 details the maximum permitted volume of chemical nitrogen which can be used based on the previous year’s stocking rate for grassland farmers.
For those that the Department classifies as “arable farmers” the ruling is that they must limit their chemical nitrogen usage to 10% below the national average on arable crops with this stated by the Department as 139.41kg N/ha.
The level of usage and compliance with the eco-scheme measure will be verified using the proposed fertiliser register which the Department is planning to introduce with usage levels verified in quarter four of 2023.
Soil sampling and appropriate liming
To qualify for the eco-scheme measure, soil sampling and appropriate liming, farmers will be required to undertake soil sampling and apply lime, if recommended.
The Department states that if farmers intend to apply for this eco-scheme measure in 2023 then samples should be taken in quarter four of 2022 at a rate of one sample per three hectares.
The Department advises that care needs to be taken to ensure that three months has passed since the last application of phosphorus or potassium via chemical or organic fertilisers.
Comment: confidence in proposals being approved
It is important to note that the CAP information circulated by the Department of Agriculture is dependent on Ireland’s CAP Strategic Plan 2023-2027 being approved by the EU Commission.
The Department expects the CAP plan to be finalised by September 2022 at the latest which leaves the timelines too tight to wait to move on aspects of the plan discussed on these two pages.
However, the fact that the Department is progressing ahead and has moved to disseminate information conveys a sense that they must optimistic that these measures will be approved.
At least farmers will be expecting that this will be the case, given that changes made in a bid to satisfy scheme requirements may have a profound effect on their business.
The proposed change in the livestock unit value of sheep and goats from 0.15LU to 0.1LU is one that is sure to attract scrutiny from those farming on commonage and hill areas and environmentalists.
The information circulated this week is also sure to raise plenty of discussion at the round of information meetings organised by the Department of Agriculture.
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