Submission by the Agricultural Consultants Association (aca) on the cap direct Payments Consultation Document to the Department of Agriculture, Food and the Marine. September 2013




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Submission by the

Agricultural Consultants Association (ACA)

on the

CAP Direct Payments Consultation Document

to the

Department of Agriculture, Food and the Marine.

September 2013.

1. Introduction:
The Agricultural Consultants Association (ACA) is the largest professional advisory body in Ireland supporting independent Agricultural Consultants who provide advice to the agricultural industry.

ACA was established in 1979 with its business name registered in 1981 to represent Independent Agricultural Consultants in Ireland.

The Agricultural Consultants Association (ACA) currently has 144 professional members with a further 271 professional, technical and administration staff employed with our members throughout Ireland. An independent survey conducted by the Irish Small and Medium Enterprises (ISME) of our entire membership in 2010, estimated that our members now advise in the region of 44,500 farmers, making ACA the largest advisory body in Ireland.
2. Overview
This document represents the ACA’s response to stakeholder consultation questionnaire with regard to the implementation of the reform of the Common Agricultural Policy (CAP) in Ireland. www.aca .ie PRESIDENT SECRETARIAT Mike Brady M.Agr. Sc., M.A.C.A. ACA Members Services Ltd., Brady Group Main Street, The Lodge, Carrick on Suir, Cork, Co. Tipperary. Co. Cork Teleephone: 021 4545 120 Telephone: 051 645705 Mobile: 087 2500 475 Fax: 051 640932 Fax: 021 4542 404 E-Mail: acaservices@som.ie Email: mike@bradygroup.ie

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3. The Importance of Agriculture to the Irish Economy.


From a national prospective, Agriculture and the Agri – Food Industry represents exports of over €9bn with continued growth in the sector. However, despite this, the sector at farm level requires continued substantial support. The view of the ACA is that continued support of the sector under Pillar 1 and Pillar 2 of the CAP can ensure the viability of the farming community, the protection of the environment and the production of quality produce which is traceable and verifiable.
4. ACA Recommendation in the implementation of the CAP.
The following represent the position of the ACA in relation to the questions and issues posed on the Direct Payments Consultation Questionnaire.
a. Active Farmer.
The ACA’s view is that direct payments should be targeted to Active Farmers. A minimum average Stocking density should be set for all farmers with lands in Less Favoured Areas of 0.15 Lu / Ha and a higher density of 1.0 LU / HA from farmers outside LFA’s. This will encourage food production and also assist with farm viability. All stocking density requirements should be subject to local environmental constraints. www.aca .ie PRESIDENT SECRETARIAT Mike Brady M.Agr. Sc., M.A.C.A. ACA Members Services Ltd., Brady Group Main Street, The Lodge, Carrick on Suir, Cork, Co. Tipperary. Co. Cork Teleephone: 021 4545 120 Telephone: 051 645705 Mobile: 087 2500 475 Fax: 051 640932 Fax: 021 4542 404 E-Mail: acaservices@som.ie Email: mike@bradygroup.ie

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b. Flexibility between Pillar 1 & Pillar 2.


ACA does not support the transfer of funds between Pillars’s. The recommendation of ACA is that Pillar 2 funding should be used for the development of strong, realistic and viable Agri-environmental programmes, Farm and Land Transfer Programmes, and schemes to develop knowledge transfer. A study conducted in 2009 by ACA in relation to the expenditure on REPS showed that the exchequer spends were revenue neutral.
c. Allocation of Entitlements under the Basic Payment Scheme.
i. ACA proposed that farmers who do not have entitlements but were actively farming in 2013 should be allocated entitlements from the national reserve based on objective selection criteria.
ii. ACA recommends that the number of entitlements allocated be based on the lesser of the number of eligible hectare declared in 2013 or 2015. This is recommended so as not to distort the land rental marked and land availability in 2015.

d. Convergence.
i. ACA proposes that 90% of the National Average be used as the threshold.

www.aca .ie PRESIDENT SECRETARIAT Mike Brady M.Agr. Sc., M.A.C.A. ACA Members Services Ltd., Brady Group Main Street, The Lodge, Carrick on Suir, Cork, Co. Tipperary. Co. Cork Teleephone: 021 4545 120 Telephone: 051 645705 Mobile: 087 2500 475 Fax: 051 640932 Fax: 021 4542 404 E-Mail: acaservices@som.ie Email: mike@bradygroup.ie

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ii. Entitlements should not be increased by more than one third of the difference between the Initial Unit Value and 90% of the national average.
iii. The minimum payment under the Basic Payment Scheme should be set at 60% of the National Average.
iv. Ireland should apply a maximum reduction by 2019 of 30% of the Initial Unit Value for those farmers whose payments will decrease over the period of the scheme.

e. National Reserve.
i. ACA proposed that the maximum 3% funding be allocated to the national reserve for young farmers and new entrants.
ii. ACA recommend that additional selection criteria be included for eligibility to the national reserve including: education (Green Cert minimum); stocking density; farm improvement; entitlements allocated on the basis of owned and leased lands only, not rented lands; development of five year plan for the farming unit.
iii. ACA propose that national reserve applicants show a commitment to farming and that they must farm for a five year period and that a clawback mechanism should be included where this requirement is not fulfilled.

www.aca .ie PRESIDENT SECRETARIAT Mike Brady M.Agr. Sc., M.A.C.A. ACA Members Services Ltd., Brady Group Main Street, The Lodge, Carrick on Suir, Cork, Co. Tipperary. Co. Cork Teleephone: 021 4545 120 Telephone: 051 645705 Mobile: 087 2500 475 Fax: 051 640932 Fax: 021 4542 404 E-Mail: acaservices@som.ie Email: mike@bradygroup.ie

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f. Transfer of Entitlements:
ACA recommends that a clawback be applied to entitlements that are transferred via rent / lease without land. This is to encourage active farming and to discourage a community market for entitlements. Force Majeure should be included for circumstance outside the control of the farmer.
g. Redistributive Payment:
A redistributive payment should not be used in the case of Ireland. Should such an option be adopted this would encourage fragmentation of farms and restrict land mobility. ACA recommends that a strong Pillar 2 support system be established in support of smaller and naturally extensive farms.
h. Greening:
i. ACA recommends that the Greening payment be included as a fixed percentage of farmers' Basic payments.
ii. The use of “verifiable” equivalent practices should be permitted in order to meet the greening measure requirements to encourage diversity.
iii. Ireland should use National Certificate Schemes enabling farmers to meet their requirement under greening. This will increase the environmental and climatic benefit of greening and also increase the level of knowledge transfer among farmers.

www.aca .ie PRESIDENT SECRETARIAT Mike Brady M.Agr. Sc., M.A.C.A. ACA Members Services Ltd., Brady Group Main Street, The Lodge, Carrick on Suir, Cork, Co. Tipperary. Co. Cork Teleephone: 021 4545 120 Telephone: 051 645705 Mobile: 087 2500 475 Fax: 051 640932 Fax: 021 4542 404 E-Mail: acaservices@som.ie Email: mike@bradygroup.ie

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i. Permanent Grassland.
The obligation for the maintenance of permanent grassland should be applied at national level.
j. Ecological Focus Area.
i. All of the areas listed should be considered as eligible area in Ireland.
ii. ACA’s recommends the implementation of 50% of the EFA obligation at regional level in order to establish adjacent collective EFA area to increase the environmental and climatic benefits.

k. Young Farmers Scheme.
i. ACA proposes that the maximum 2% funding be allocated to the Young Farmers Scheme to promote farm transfer, increase the knowledge base of the farmer and increase production.
ii. ACA recommend that additional selection criteria be included for eligibility to the Young Farmers Scheme including: education (Green Cert minimum); stocking density; farm improvement; entitlements allocated on the basis of owned and leased lands only, not rented lands; development of five year plan for the farming unit.

www.aca .ie PRESIDENT SECRETARIAT Mike Brady M.Agr. Sc., M.A.C.A. ACA Members Services Ltd., Brady Group Main Street, The Lodge, Carrick on Suir, Cork, Co. Tipperary. Co. Cork Teleephone: 021 4545 120 Telephone: 051 645705 Mobile: 087 2500 475 Fax: 051 640932 Fax: 021 4542 404 E-Mail: acaservices@som.ie Email: mike@bradygroup.ie

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iii. The maximum number of hectares upon which Young Farmer entitlements should be allocated should be 90 Ha of owned and 5 year leased lands. This will encourage a commitment to farming, encourage farm transfer and discourage farm fragmentation.
iv. Entitlements should be allocated on the basis of 25% of the national average payment per hectare multiplied by the number of entitlements activated by the young farmer.

l. Coupled Support
i. ACA recommends that the Minister uses the maximum 8% of the national ceiling to support vulnerable sectors including the Beef and Sheep Sector. This coupling payment should be linked to specific standards in husbandry and efficiency that are verifiable.

m. Small Farmer Scheme.
ACA does not believe that a small farmer scheme is appropriate for Ireland. Support for smaller and more vulnerable farmers should be included under Pillar 2 arrangements. www.aca .ie PRESIDENT SECRETARIAT Mike Brady M.Agr. Sc., M.A.C.A. ACA Members Services Ltd., Brady Group Main Street, The Lodge, Carrick on Suir, Cork, Co. Tipperary. Co. Cork Teleephone: 021 4545 120 Telephone: 051 645705 Mobile: 087 2500 475 Fax: 051 640932 Fax: 021 4542 404 E-Mail: acaservices@som.ie Email: mike@bradygroup.ie

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n. Areas of Natural Constraints.


ACA recommends that support for Areas of Natural Constraints be included under strong Pillar 2 structure and schemes including an effective Agri-Environmental Scheme.
o. Administration
i. ACA proposes that all applications under the Basic Payment Scheme from 2015 are only acceptable where submitted using an online system to reduce administration costs. This online application may be submitted by either the farmer or their nominated agents.
ii. ACA also proposes that all approved agents under the Single Payment Scheme must meet minimum standards of education (Level 8 in Agricultural Science or equivalent), be approved ccFAS advisors and have professional indemnity insurance.
This Submission is recommended to the Minister of Agriculture, Food and the Marine for inclusion in the implementation and administration of Direct Payment in Ireland.

ACA Council



September 2013.


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