The big changes the EU could make to Ireland’s CAP plan

The Commission asked Ireland to consider additional commitments under this farming practice to reduce overall pesticide use or switch to lower-risk pesticides and reduce overall fertilizer use.

An obligation to use low-emission application techniques could also be considered, it said.

Soil sampling and corresponding liming

The Commission asked for clarification on how this practice differs from the pilot soil sampling program currently being implemented by the Irish agricultural authorities.

planting of multi-species grass

The commission said that while sowing multispecies grass is beneficial, it is uncertain whether the requirement to do so on at least 6 per cent of eligible hectares is enough to provide a benefit. It said the rules could be “tightened” (e.g. reducing cutting frequency) to help insects and birds that eat insects or seeds.

definitions

Active farmer

Under Ireland’s GAP plan, active farmers are defined as those who “have at least a minimum level of agricultural activity”.

This is an attempt to address the problem of “armchair farmers” and ensure those who actively farm are rewarded. However, the Commission asked Ireland to ensure that the criteria used to identify active farmers do not penalize farmers who are not engaged in productive activities.

Transfer of Claims

Ireland plans to introduce a 10 per cent clawback on transfer of payment entitlements if a farmer leases more than 80 per cent of his payment entitlements for a period of less than five years.

The Commission asked Ireland to explain the aim of this rule and said it must be remembered that any conditions laid down must be objective and non-discriminatory.

Rules and Conditions (GAEC)

Protection of bogs and wetlands

Among the GAEC regulations that Ireland has planned is the protection of bogs (and wetlands) designated as agricultural land and eligible hectares.

Such areas are submitted by applicants as part of area-related measures. Large amounts of carbon are stored in peatlands (and wetlands) and certain agricultural practices (e.g. ploughing) can have negative effects on such soils in terms of carbon storage.

The Commission has asked Ireland to confirm that wetlands enjoy the same protection as peatlands.

buffer strips

The Irish plans envisage a 5m wide buffer strip alongside watercourses for organic fertilizer application.

The Commission would also like Ireland to consider whether this width could be considered for ploughing, artificial fertilizers and pesticides, which are also problematic in Irish areas near watercourses.

cover crops

Ireland has established two alternative standards: a requirement for crop rotation with winter cover crops and a requirement for crop diversification.

However, the Commission says the practice of crop rotation cannot be seen as optional and alternative to crop diversification under EU rules.

While acknowledging the specific context of the arable sector in Ireland, the limited cropping alternatives and weather conditions, it said the option to meet an annual crop rotation with a winter cover crop could be feasible for all farmers.

Non-productive areas

Under the next CAP, farmers will have to provide “room for nature” on at least 4% of farmland.

However, the Commission underlined that forests, municipal areas and Natura 2000 sites are not eligible for the calculation of the share as they cannot be considered as non-productive agricultural land.

However, limited groves/groups of trees at the edge of agricultural land or in the plots can be considered landscape features, it said.

Organic farming

While welcoming Ireland’s stated national target of 7.5 per cent for organic farming coverage, the Commission asked Ireland to consider whether it could aim for an even higher increase in order to achieve additional environmental benefits while retaining a higher share of the value added for farmers Secure farmers in the food supply chain.

Other systems that may need to be changed

The EU Commission also had some critical comments about Ireland’s plans for key agricultural programs. Here, too, further measures to improve environmental performance were in the foreground.

Welfare program for dairy beef

Under this proposed scheme, farmers will be rewarded for weighing calves in their first year of life to promote animal welfare.

However, the Commission said Ireland must explain how it intends to ensure farmers’ insights from weighing calves lead to improved animal welfare and a reduction in the use of antimicrobials.

Ireland also needed to explain the claimed potential of this intervention to reduce greenhouse gas emissions.

Suckler’s carbon efficiency program

This program will replace the Beef Data and Genomics Program (BDGP) and the Beef Environmental Efficiency Program (BEEP) under the next CAP.

The Commission said Ireland relies heavily on this intervention to achieve the greenhouse gas reductions specified in the CAP strategic plan, so further explanation is needed on how this is to be achieved.

Ireland is asked to better explain the overall emission reduction achieved by previous schemes, the data used for the assessment and the restrictive conditions put in place to ensure an overall net emission reduction through this intervention.

In particular, the Commission said that since this intervention is proposed as a pay-per-hectare obligation for agri-environment-climate management, links to site-specific conditions such as reduced stocking density could be explored.

The commission also said low-protein diets and other feeding strategies should be considered to reduce methane and ammonia emissions.

Ireland was also asked to explain how the productive impact of this intervention was taken into account.

On farm capital investments

This program will replace the TAMS program under the next CAP and will support farmers who wish to invest in capital projects on their farms.

The Commission called on Ireland to ensure that all eligible investments are directly linked to indicators with a clear and direct environmental or animal welfare benefit in order for the green investment intervention to be eligible for earmarking and to ensure that they are financed Investments go beyond normal practice and mandatory requirements.

In addition, Ireland is asked to justify the relevance of an age criterion for the top-up for women farmers (women aged 40 to 66), while the top-up for young farmers (which applies to both men and women aged no more than 40 years) is linked to founding conditions.