Have your say on CAP policy direction

Ollie Whyte’s letter in last week’s Irish Farmers Journal is indicative of how many tillage farmers feel about the road ahead for tillage.

Money continues to be taken from the sector, while more and more obstacles and obligations have to be overcome.

And this appears to be more the case for tillage than other farming sectors but perhaps there may be more environmental restrictions facing other enterprises.

The opportunity for those affected to have their say ahead of a final CAP agreement must be welcomed but it can only be of benefit if people interact with the process.

The process is full of acronyms and new terms that challenge its understanding

This means understanding what is being proposed and addressing the elements that can be altered.

But for this process to be constructive and effective, it needs to be set out in language that is clear and unambiguous.

Unfortunately, this is not the case. The process is full of acronyms and new terms that challenge its understanding.

When the CAP was primarily driven by the Commission, the official text was largely legible – now that the people’s representatives are involved in the process (the European Parliament) the text seems much more complicated.

Far from clear

Take just one tillage example. The word “arable” is bandied about and even used in a definition in which it is inappropriate. It is used to refer to land that is cropped while it really means land that is capable of being ploughed or cropped.

In this context, we used arable acres for years as a descriptor of the land quality on farms. Why the need for confusion? It may be an official EU term but why confuse the language for Irish growers in this consultation process.

The contribution of areas of scrub and natural habitat was ignored for years, but we now have a new suggestion that any parcel can have up to 30% such ground and be deemed fully eligible for a claim.

This is very belated, but welcome for those who have not reclaimed such areas.

However, many such areas that still exist on tillage farms are likely to be in separate parcels now and have their own LPIS number.

But if a parcel must have agricultural activity to be considered eligible, such parcels of habitat may still be considered ineligible for aid, as agricultural activity may not be possible. So can such habitat parcels on tillage farms qualify for aid, or not?

Targeted objectives

Specifics aside, it is inevitable that the next CAP will bring many changes, as will other policy drivers.

There are new Statutory Management Requirements (SRMs) for the maintenance of land in Good Agricultural and Environmental Condition (GAECs) which are part of the “enhanced conditionality” of the next CAP, as laid out in the CAP strategic plan.

There are many macro budgetary obligations, as well as those that impinge on individual farmers. These include:

The problem is that these measures take from the traditional support given to produce food and there is little to suggest that the EU will act to support European producers against the imports that have traditionally pulled down food prices.

Ultimately, the vision for highly sustainable family farms is being increasingly blurred as it depends on having sufficient income at farm level to continue and our biodiverse agriculture will continue to drift to a single enterprise.

Targeting of direct payments

Most farmers already know that convergence, a process to equalise the value of high and low value entitlements, is continuing and that it is a net income reduction across the tillage sector.

But such actions come with the vulnerability of a system that depends on aid.

The objective to ensure a fairer and more targeted distribution of direct payments can hardly be argued against

The people who pay the piper and set the agenda always seem to know better how to do things than the farmers.

The objective to ensure a fairer and more targeted distribution of direct payments can hardly be argued against, but how this should be done is much more controversial.

How should it be balanced against the continuing need for food production, the sustainability of food systems, the need for care for the environment and the need to support those who depend on the land for their livelihood?

With environmental and climate issues receiving a greater focus in this CAP, it is hardly surprising that there is more focus on how land is managed and defined. These changes are stated in the requirements for good agricultural and environmental condition (GAEC), but they seem to focus very heavily on tillage.

GAEC 1 has been an EU measure for many years to protect against the excessive loss of permanent pasture, especially in the EU.

Its presence is supposedly a safeguard against conversion to other agricultural uses to preserve carbon stock.

It is a new GAEC that is a direct obstacle to increasing tillage area and makes no reference to an ability to manage new land into tillage to minimise or prevent organic matter or carbon loss.

Ireland’s objective must be to maintain tillage area rather than permanent pasture and this is acknowledged in AgClimatise and Food Vision 2030.

GAEC 3 is a ban on burning straw or stubble, except for plant health reasons. Controls are already in existence and burning with permission has been used occasionally.

GAEC 4 is the establishment of buffer strips along watercourses. We already have this for nutrients and pesticides but will it apply to all sectors? Tillage is really the only sector being asked to take these strips fully out of production.

GAEC 6 is about the use of appropriate cultivation techniques to limit the risk of soil degradation. This is already in existence and a very important consideration for tillage farmers but it makes reference again to this ridiculous issue of managing for slopes.

GAEC 7 deals with green cover and avoiding bare soil in period(s) and areas that are sensitive to nutrient loss. This is already in existence and now proposed as a nitrates measure post harvest.

GAEC 8 is perhaps most controversial for many growers. This deals with rotation and you remember that the EU wants us to have a different crop in every parcel every year. This is a new GAEC requirement, but the Department hopes that our crop diversification requirement as part of Greening will be acceptable.

GAEC 9 appears to be something like the ecological focus areas in the current Greening.

It calls for a minimum share of agricultural area devoted to non-productive areas and features – at least 4% – including land lying fallow.

This GAEC is partly new and partly in existence already.

The suggestion is that it may include non-productive features including land lying fallow, nitrogen-fixing crops, catch crops, eligible forestry, short-rotation coppice, field copse, hedgerows, drains, buffer strips, as well as non-productive features.

There is also a suggestion of measures to help avoid invasive plant species, which might be of benefit to fields where grass weeds are a serious issue.

It is proposed that this GAEC apply to all agricultural areas and not just tillage.

Unclear suggestions

There are other unclear suggestions in the document which could take the 4% obligation down to 3% if a farmer commits at least 7% of his/her tillage land to an enhanced eco scheme, which seems to involve the production of at least 7% of the cropped area in catch crops or nitrogen-fixing crops, cultivated without the use of plant protection products, which would make the latter less attractive.

A weighting factor of 0.3 is indicated for catch crops, which would mean growing 10ha to the counted as 3ha when the percentage is being calculated.

The document references the fact that the Protein Aid Scheme will continue into the new CAP.

While there are no numbers indicated, it is believed the scheme will be bigger both in terms of the targeted hectares to be supported and the aid level per hectare.

But this needs additional funding to solve the supply inconsistency problem for feed producers.

The crops to be supported are again peas, beans and lupins, with consideration to be given to soya beans and mixed cropping.

Provision is being made to support a capital investment scheme by providing grant aid for investment areas such as environment, nutrient storage, tillage, young farmers, organics and farm safety.

Support

If the Government is serious about maintaining or increasing tillage area, then the support for tillage equipment needs to be broadened out to help new entrants to the sector, as has been the case for other sectors.