Specific Details
IFA Submission on an improved Agri-Climate Rural Environment Scheme (ACRES)
Intended results
To propose a better Agri-environment scheme for Irish farmers.
Engagement with farmers
- Much improved lines of communications & engagement between key stakeholders (e.g. DAFM, ACRES CP Teams, planners) & farmers is required. There is too much ambiguity and responsibility deflection ongoing currently, with farmers left frustrated, uncertain where they stand, and out of pocket because of lack of accountability elsew
- Provide clarification and transparency on remaining rolling budgets to participants on elements including resultsbased scorecard payments, NPIs, LAs and the Landscape Bonus.
- Greater detail and clarity is required with regard the Landscape (High Achievement) Bonus Payment. While we understand it will reward farmers for high average scores across their private land within CP zones, or where they have a large area of land within the CP zone, and it will be backdated/applied to the full period of participation in the ACRES Scheme – how will it be administered; funded; and what impact (if any) will it have on maximum permitted ACRES payments received .
- DAFM need to proactively notify farmers (& planners) of potential penalties/anomalies arising from non-action. By way of example, where scorecards are not submitted in full by the planner. Flexibilities should be provided where it is evident that the farmer is invested in the scheme, yet planner has not fully executed – for example in instances where at least one parcel scorecard has been submitted successfully, yet others remain in ‘Draft' format.
- On low scoring commonages, DAFM should engage directly with those actively cutting turbary and higher stocked farmers (whether ACRES participant or otherwise) to outline the impact of their actions and encourage altered practices and/or grazing management techniques.
Administration
- Adequate resources should be deployed to DAFM staffing; I.T infrastructure etc to ensure the swift delivery of payments per the Farmers Charter of Rights. Individual cases (incl. partnerships), which require additional processing, should not be continually pushed out or without payment, as occurred for over 200 farmers within ACRES. Advance payments should issue to all, with any issue/discrepancy corrected via balancing and/or future scheme payments where required.
- Alleviate the burden of proof/verification required to receive payments by relying more on self-declaration and/or other mechanisms (e.g. Geo-tagged photos; AMS; AIMS, etc). For the second round of scoring, score a sample of parcels rather than all relevant parcels, incorporating therein the largest; lowest and highest scored parcels.
- The cost incurred / income foregone methodology has negated the economic benefit of scheme participation, amplified by delayed NPI/LA approvals; large planner fees for preparation of plans & annual charges. Farmers that implement environmental actions on farm (e.g low scoring commonage areas) should be the main beneficiaries, and better rewarded for their efforts
Given delayed NPI/LA approvals, through no fault of the farmer, it is unlikely the full environmental benefit of actions taken (& consequently financial return through improved parcel scoring) will be reflected within the remaining ACRES period. Consequently, increased payment rates should be offered and/or a return to a ‘whole of farm' approach as per previous agri-environmental schemes implemented
- Given their high nature value credentials (and fewer applicable measures noted within ACRES) a standalone payment, or increased payment rates, should be provided for NPWS designated sites (SACs, SPAs, NHAs, pNHAs
- A transitionary period should apply before the impact of scoring takes effect. This should apply also where key scheme components are required, yet are not yet fully functional. In both scenarios, full potential annual payments should be paid to all applicants.
By way of example - given the late circulation of parcel scoring and non-availability of Non-Productive Investments (NPI)/ Landscape Actions (LA), a full €7,000 / €10,500 payment should be paid to all ACRES applicants for years 1 & 2 ((retrospectively if required), with the impact of scoring, where relevant, to apply only from Year 3 onwards,
where after the farmer has been given ample time and opportunity to correct any anomalies and apply / implement environmental measures through NPI / LAs to support / improve parcel scoring.
This satisfies the results-based approach, and delivers a fair payment to farmers. Increasing possible thresholds for mechanisms not yet available is unreasonable and unacceptable. It places additional pressure on farmers too - incurring larger cash outlays and larger investments/action to recoup fully what was suggested initially through ACRES when approved for the scheme
- Full scheme details must be provided to farmers at the outset. The DAFM / ACRES CP Team agreed protocol of 100m buffer around active turbary should be removed entirely where peat is harvested for personal household use, and on legally held and registered turbary plots assigned by the State. It is excessive, most especially for smaller commonage areas, as currently stands. Under REPS, AEOS, and GLAS, the nett area of the plot harvested was all that was deducted from payment.
- Allow for batch approvals processes (NPI / LA) pre closing deadline to reduce wait times between planning and implementation and to ease also advisor workload
- Unless to the farmer's advantage, individual terms/ qualifications must hold for at least the term of the new CAP programme. There can be no downward revision or pro-rata reduction in either payment or maximum eligible area within individual measures.
- An opt out option without penalty should apply where what was sold & signed up to has not been delivered.
- New entrants post 2022 interested in an agri-environmental scheme must be accommodated. Farmers cannot be left without an agri-environmental scheme for the remaining term of the existing CAP programme.
Scoring
- A review of the scoring / payment system should apply. The DAFM need to acknowledge that past agri-environmental scheme criteria may have impacted current scoring (e.g. minimum stocking rates), and whether relating to late scoring submissions; minimal invasive species; turbary activity and/or dumping, ACRES applicants should not be penalised for the actions / non-actions of third parties.
Force majeure, proportionality, and fairness should apply. Similar to BISS, there should also be a period from which parcel scores / plans could be amended without penalty.
- Farmers should be advised the date that their lands are being scored, and provided with the opportunity, should they so wish, to accompany the planner/consultant during the scoring exercise to enable information sharing and corrective action to be relayed in a timelier fashion than having to wait a significant period as occurred with ACRES. More broadly, an agreed timeline is required for the provision of parcel scoring to farmers post completion.
- The probability of achieving a high score should at least be equal to the probability of achieving a lower score. No negative marking should apply, with a ‘0' the lowest score applied. Currently, within individual ACRES scorecards, most carry far higher cumulative negative scoring. This should be corrected and a re-weighting of scores & associated payments assigned where required.
- In light of Year 1 scores achieved nationally, review and consider the appropriateness or otherwise of the €145/ha rate utilised for ALL owned/rented/leased commonage parcels in ringfencing calculations.
Where material discrepancies arise, and additional non-commonage lands were held but excluded, a retrospective payment, equivalent to the differential between the parcel rate derived and €300/ha (i.e. the rate assigned for all owned forage CP parcels declared as Permanent Pasture, Low Input Permanent Pasture or Traditional Hay Meadow) should be made to impacted farmers for each additional non-commonage hectare excluded from the scheme, subject to €7,000 overall core payment.
Any additional residual amounts should be allocated to Non-Productive Investment allocations as per existing arrangements.
- Applicants with parcels scoring below payment levels (i.e. <4) should be automatically entitled to a participation payment and have such parcels rescored in the subsequent year (not all lands) should they so wish, and prioritized, so as to not impinge core payments received in immediate subsequent years.
- Applicants with parcels scoring below payment levels (i.e. <4) should be automatically entitled to a participation payment and have such parcels rescored in the subsequent year (not all lands) should they so wish, and prioritized, so as to not impinge core payments received in immediate subsequent years.
- A streamlined appeals mechanism to be put in place where repayment requests from the Department can be adjudicated on in a timely and efficient manner. A similar efficient commonage scoring appeals system is required.
- Any recoupment of funds should be done only on agreement and span multiple years where necessary. No interest charge/penalty on such funds should apply.
General Actions
- A wide selection of on-farm actions should be provided for participants to select the most suited for their individual operation. The Riparian Buffer Zone & Grass Margin measure should be included as an option for ACRES Co-operation as it is currently for ACRES General applicants.
- As budgets (and budgets predications allow), raise the maximum core payment from €7,000 to €10,000. This would incentivise additional ecosystem services and should not require a new IT system re-build to implement.
- Where 2 or more actions are implemented in parallel on individual parcels/locations (e.g. new hedge alongside riparian buffer margin), one fence should satisfy.
- Greater flexibility around individual measure completion deadlines (at least to Year 4), most particularly where adverse weather conditions and/or input supply constraints are clearly evident in the weeks leading up to completion deadlines. Planting requirements should span the lifetime of the scheme to allow national suppliers build necessary native stocks instead importing plants and exposing native species to a greater risk of disease.
Non-Productive Investments / Landscape Actions
- Existing Non-Productive Investments / Landscape Actions should be available to all farmers whose land is scored, regardless of being in CP or General. The purpose of NPI's is to improve scores, however farmers in ACRES General with LIG or Commonage have no direct support, financial support nor means of applying for NPI's to improve these field scores. This must be corrected.
- New/additional bespoke measures should also be eligible for payment where more appropriate to promote/enhance habitat/biodiversity in individual locations and agreed in consultation with CP Teams.
- It is essential that farmers are provided with a schedule of NPI & LA application windows (i.e. opening & closing dates), but more importantly an agreed decision timeline is derived (& enforced) from when, post the end of the application window, farmers can expect to receive approval letters. Non-receipt of formal decisions within agreed timelines are assumed approved.
It is unacceptable, as has happened to date, that applications for NPI which closed early December 2023, yet mid-November 2024 no farmer has been able to undertake the necessary environmental action because the issuing of approval letters has not yet commenced
- A centralised fund per ACRES CP Team should be established, with greater authority afforded to ACRES CP Teams to approve NPI / LA, at least for certain investment types, to support a more streamlined NPI / LA process
- Similar to mobile TAMS applications (subject perhaps to max. €5,000 ceiling per application), permit applicants to progress with NPI/LA, at their own risk, once valid applications have been submitted. Payments to follow on receipt of geo-tagged photo and vouched expenses. This too will enable actions to be undertaken quicker, and more time for actions to yield greater environmental benefit and improved scoring/payments overall.
- To minimise lost time, afforded resources and constrained environmental action, opportunity to amend minor infringements within individual applications should be permitted, rather than reject individual measures entirely. For example, moving a water trough outside the required 20m perimeter of a watercourse, where currently its location is within the excluded area. Approval on condition is provided for within the NPI specifications
- Culverts are included within eligible NPI's to provide a safe drain crossing point for livestock, people, and vehicles to cross drains without fording them and prevent regular discharges of sediment and nutrients to watercourses. However, culverts are not permitted on natural watercourses (incl. OSI waterline and Single Stream line) or on arterial drainage channels. This will considerably limit the potential benefit of this NPI and should be reviewed
- Consideration should be given to supporting complementary investments to those listed (e.g. gate pillars where required), and ensuring individual NPI eligibility criterion do not prohibit individual livestock type (e.g. min 317 litre water trough and its suitability for sheep operations).
- Clarification is needed on whether there will be opportunity provided to seek an extension to NPI completions to the following year, and submit a payment as a single application then. By way of context, it may be more practical and cost-effective for farmers, who applied for NPI's in 2023 and 2024, to combine / action categories of investments rather than proceed in sequence of NPI application.
- To aid resource efficiency, consideration should be given to utilising excess interim payments, in full/part, as advance payment for the completion of approved Non-Productive Investments where applicable.
Penalties
- Penalties applied to non-compliance must be proportionate and fair. A complete disregard of positive environmental action undertaken and the application of a full 100% penalty on total yearly payments is excessive (plus potentially complete removal of individual actions for payment in subsequent years), most particularly where only minor infringements occur, with perhaps no direct correlation on the overall environmental outcomes achieved (e.g. failing to pay membership to a breed society).
- Aligned with above, the methodology / correlation between penalty severity and the Tiered Structure should be reviewed and reduced, most particularly given 100% approval was provided to all ACRES applicants and rank/selection made redundant. By way of example, many farmers selected ‘priority Tier 1 actions' to increase their probability of acceptance into ACRES.
It is disproportionate that a participant would get no opportunity to correct and secure payment for an individual Tier 1 in future years of the scheme (as provided for re Tier 2 actions).
- Where, during scoring activities, there appears evidence of invasive species on Commonage from Coillte/Stateowned lands (e.g. Sitka Spruce/Pine saplings from adjacent Coillte land), it's specific location should be noted by the planner/consultant and the penalty imposed passed on to Coillte and/or the State where applicable for payment
- Inspections should follow the Farmers Charter of Rights protocol, with all farmers, irrespective of whether inspected or not, provided with a detailed list of annual requirements for scheme participation.
In addition, at least 48hrs hours advance notice should be provided (incl to planner), with a written summary of the inspection provided to the farmer before leaving the farm. A streamlined appeals mechanism should also be put in place, with details provided to the farmer and adjudicated on n in a timely and efficient manner.