>ASA Submission on the draft E.C.'s Nitrates Regulations (July 2010)
>Submission by the ASA on CAP post 2013 (June 2010)
>ASA Submission on Agriculture Strategy 2020 (April 2010)
>ASA comments and recommendations on the Framework Directive 2009/128/EC on Sustainable use of pesticides (March 2010)
ASA Consultation document on the Socio-economic implications of the placing on the market GMOs for cultivation (February 2010)
>CAP 2013 Reform Submission
>Agri-environment Scheme Submission
>Rural Development Submission
>Phosphorus Derogation
>Prescription Only Medicines
Submission by the Agricultural Science Association (ASA) to the Department of Agriculture, Fisheries And Food on CAP 2013 Reform
30th September 2009
1 - Introduction
The ASA, founded in 1942, is the body representing graduates in agriculture, food, forestry, horticulture and environmental sciences. Its members work in every aspect of the agri-food industry and rural development as agricultural advisers/consultants, researchers, policy makers, regulators, educationalists, business operatives, managers, farmers, etc. This makes the ASA a key player in the agri-food industry with very significant expertise in all its aspects. It also means that ASA is a critically important stakeholder in the Common Agricultural Policy of the EU and the reforms scheduled to take place in it post 2013. We welcome this timely invitation by the Department of Agriculture, Fisheries and Food for submissions and wish to engage constructively in the process. Given the critical role of the CAP in setting the agenda for the agri-food industry, this reform process will have a major impact on the development of the industry in Ireland, and on the livelihoods of all engaged in it. We will support the Department in any way we can and hope that the Department will avail of our expertise through on-going dialogue during the process.
2 – Submission
2.1. CAP as the cornerstone of policy and agricultural development in the EU
The Common Agricultural Policy (CAP) post 2013 should be designed to encourage a strong food production capability in the European Union. The policy environment should aim to encourage and reward a market led, environmentally sound food production model. The family farm should be encouraged as the optimum operating structure.
Over the 50 years since its inception, the CAP has by and large been a successful instrument of policy and allowed the EU to largely achieve its goals of increasing productivity, achieving food security, ensuring adequate incomes for farmers while at the same time keeping food prices low to consumers, ensuring that agriculture operates in an environmentally sustainable manner, and contributing to rural development. It has supported the development of the European model of agriculture, where food is produced primarily on family farms, where higher environmental, animal welfare and food safety standards exist than in most other regions of the world, and where agriculture delivers other goods such as landscape, biodiversity, and conservation. These goods and services are demanded by EU consumers but normal market mechanisms will not pay farmers for them, so the CAP rectifies these market failures. Thus it is an integral part of the way EU citizens want agriculture to operate in the EU. There have been problems along the way such as production surpluses, and while the CAP was initially slow to react to these, the problem was eventually dealt with.
The reform of the CAP should continue this process by helping to deal with the main problems in the industry to-day such as price volatility and low producer incomes while at the same time ensuring that the European model of agriculture continues.
2.2. Budget
Agriculture receives a significant share of the EU budget, but it must be realised that the overall EU budget is quite small as a percentage of EU GDP (1%) or total EU public expenditure (2.5%). CAP reform has meant that its share of the budget is declining over time from 70.8% in 1985 to a projected level of 39.3% (including rural development spend) by 2013. Nevertheless, the EU budget and spending on agriculture is likely to come under pressure. Agriculture will face increasing competition for funds from other priority areas unless member states agree to increase their overall contribution. This will be difficult to achieve due to the poor state of public finances and indebtedness of EU countries resulting from the current recession. Given the benefits of the CAP outlined above, every effort must be made to maintain the spend on agriculture in real terms. The rising importance of food security must be stressed as must the role of agriculture in some of the new priority areas such as mitigating and adapting to climate change.
2.3 The Single Farm Payment (SFP)
Individual SFP based on historical production levels will become more difficult to sustain as the period since the reference years lengthens. There will be pressure to move towards a regional model with a flat rate payment system, but this will undermine the viability of the more commercial farms in Ireland. If any change is introduced, it should be phased in over a period as farmers are very reliant on the current system for income.
One alternative option would be to reward higher stocking rates up to environmental optimums. This would maintain the viability of commercial farms and overcome the possible damage of the move away from reference year payments. In a high proportion of Irish cases, the farms that earn the highest per hectare SFP continue to run higher stocking rates than low SFP holdings. This may be due to land type, farming skill or commitment to the enterprise (full versus part-time).
The SFP should remain tied to cross-compliance and we suggest that it could also be linked to elements of schemes like the Suckler Cow Welfare Scheme, or other schemes that promote good husbandry, animal welfare standards, and food safety (e.g. early weaning, vaccination, de-budding, milk recording, dry cow therapy). Again, this will help explain to society what it is getting for these payments. Such schemes should deliver genuine benefits and will need proper assessment by skilled professional agriculturalists.
A cap on the size of individual payments could be considered or payments could be tiered so as to direct a high proportion of payments towards viable family farm scale units. For example, per cow payments for “public good” activities should be capped at 90-100 cows. The possibility of reducing payments to those with high off-farm income should be examined, so that “lifestyle blocks” or “hobby farms” that are not engaged in food production do not receive unnecessary payments. Such measures would help the image of the CAP with wider society.
The model could assign higher payments in vulnerable regions such as mountain areas and Special Areas of Conservation. Payments currently made for wildlife protection –(e.g. Hen harrier) should be integrated into the single payment regime.
2.4 Differentials in SFP between member states
If a flat rate payment system is introduced, there will be pressure from some states for a EU-wide flat rate, in particular those with low payment rates currently such as the Baltic States, Romania and Bulgaria. Even in the absence of a flat rate payment scheme, these countries will seek a greater share of the agriculture budget. Average per hectare payments in Ireland are in the middle of the range of payments, if above the average. Ireland should resist moves towards an EU-wide flat rate payment system, as differences between countries are to be expected given differences in agronomic and other conditions differ (farm size, market access, etc).
2.5 Dealing with current problems in CAP
Farmers are currently facing huge difficulties with price volatility, and market dominance of a small number of players, particularly in the retail sector. The family farm model of agriculture is not well designed to deal with these issues, particularly volatility and market dominance. The reformed CAP must address these issues.
2.6 National co-financing
Ireland should argue against further increase in national financing of CAP payments. Differential national supports have the potential to distort the market place.
2.7 Farm restructuring
Farm restructuring is a vital part of ensuring the continued viability of European agriculture. Schemes to aid farm restructuring such as Installation Aid and Early Retirement should be included in the CAP.
2.8 Rural Development
The Rural Development component of CAP is likely to grow in importance. This is a vital component of restructuring as there must be jobs for people who choose to leave farming. Rather than the current confusion regarding Pillar 1 and Pillar 2, a single Pillar should operate in future, with payments targeted mainly at agricultural activities which represent added value and are not rewarded by the market. These payments should support innovation in the sector in the areas of food production, leisure activities, environmental goods and services and renewable energy.
2.9 Perceptions of CAP
The public perception of payments made to farmers needs to be improved. Setting a cap on individual payments or tiering them and linking payments to environmental goods, animal welfare, food safety, etc through professionally assessed schemes will help consumers see the value of the payments made. The benefits of such schemes needs to be well researched and the value highlighted to consumers. Transaction costs need to be kept to a minimum, but not at the expense of professional involvement in the design and implementation of good plans to deliver these goods at farm level. Technology should be utilised to the best possible extent to minimise compliance costs, fraud and bureaucracy. For example, electronic recording systems such as HerdPlus operated by the Irish Cattle Breeding Federation (ICBF) can be efficiently utilized to efficiently monitor compliance with the requirements.
2.10 Maintaining a viable professional infrastructure to support the development of the agri-food industry
New knowledge and innovation are the key drivers of development in the agri-food sector as it seeks to improve productivity while at the same time dealing with more exacting environmental requirements. The agri-food sector has the potential to help Ireland emerge from the current recession but it needs to be fully part of the national Smart Economy agenda. It is therefore critical to maintain a strong applied agri-food research programme within Ireland and the EU to support research and innovation. This must be coupled with a strong technology transfer capability, both state-funded and private consultants, if the benefit of new knowledge generated is to be realised. A vibrant agricultural education sector is necessary to ensure the absorptive capacity of the industry for new knowledge is continually developed. Without this strong professional capacity, the industry will not develop to its potential, and the ability to influence the industry to adopt non-market measures and regulations such as water quality, climate change adaptation and mitigation, animal welfare, biodiversity, etc. will be greatly diminished.
2.11 Vision of CAP for the future
The central thesis should be that economically viable, food and agri-tourism family farms are the best custodians of the European rural landscape. It is also the most efficient means of maintaining vibrant rural communities, which is socially desirable.
The REPS model as operated in Ireland offers a basis on which to build this “Food Production for the Public good” model combining Pillar 1 and 2 payments.
o There should be compulsory participation by every landowner in the EU and compulsory compliance with some basic measures, such as animal welfare, food safety and environment. Each farmer would be required to enter a multi-annual contract that would include nutrient management planning.
o Additional public goods (which are not paid for by the market) over and above the basic measures should be paid for by additional payments – e.g. maintenance of hedgerows.
o There would be some additional payments for desirable farm management practices (e.g. milk recording, dry cow therapy, early weaning, vaccination, etc).
All payments would be on a per hectare basis.
Consumers and wider society would buy into this vision because they would see the added benefits delivered by the payments.
Transaction costs and bureaucracy would be minimised by using technology such as available electronic data.
There is a key role for professional agriculturalists in the design and implementation of schemes that will be part of the revised CAP and in working with farmers to ensure that the benefits of these schemes are delivered.
Submission by the Agricultural Science Association (ASA) to the Department of Agriculture, Fisheries and Food on a new Agri-environment scheme
4 September 2009
1 - Introduction
The ASA, founded in 1942, is the body representing graduates in agriculture, food, forestry, horticulture and environmental sciences. Its members work in every aspect of the agri-food industry and rural development and a large number are involved in the Rural Environment Protection Scheme (REPS) – as planners, environmentalists, REPS inspectors, agri-environmental researchers and advisers. – making ASA a critically important stakeholder in the design and detail of any proposed new agri-environmental scheme.
The ASA is of the view that the scheme offered for consultation and submitted to the European Commission has an inadequate budget, is too simplistic and is lacking in thought and detail to merit a worthy successor to REPS. A new agri-environmental scheme must deliver long term environmental benefits in water quality, biodiversity and climate change. We believe measures must have the ability to show impact and value for money. It is our opinion that the draft scheme offered for submissions does not adequately meet these aims and objectives. Our submission offers suggestions on drafting an alternative approach along with comments on the draft scheme published by DAFF.
2 – Submission
2.1. Consultation
The ASA is of the view that the scheme outline proposed by DAFF requires significantly more thought and design. We urge a much greater level of consultation with all stakeholders to ensure a scheme that has the widest possible acceptance and would position Ireland well in terms of securing the maximum funding for a new scheme in the Rural Development Programme 2014-2020.
2.2. Budget
The ASA believes that the budget of circa €130 million outlined for the proposed new scheme is totally inadequate if the aim is to have a scheme which has a demonstrable and positive effect on the broader agri-environment and which can be ‘bought into’ by both farmers and agri-environmental specialists. For an agri-environmental scheme to be successful in such aims, participating farmers require detailed, expert advice from scientifically qualified specialists. Measures must be realistically costed and payments must reflect the balance of impact and effort. For each participating farmer in the new scheme, a critical level of money should be available for the scheme to be of interest and maintain the ongoing positive message associated with agri-environment schemes in Ireland over the past 15 years.
2.3. Role of Agri-Environmental Specialist Advisers
The ASA contends that agri-environmental specialist advisors must play a central role in the professional operation of any new agri-environmental scheme.
· The objective of any new scheme must be to provide measurable and targeted benefits to our agri-environment. A suitably qualified agri-environmental specialist advisor has a key role to play in providing professional and practical advice to farmers. This role would involve setting objectives for individual farms, prescribing appropriate and targeted measures and providing professional development to participating farmers.
· If the proposed scheme was implemented in its current form, farmers would sign up to the easiest options for them rather than options that would have a larger environmental benefit. For example, in protected areas designated under the Water Framework Directive, there should be strong emphasis on measures associated with water quality. Therefore, professional targeting of options by agricultural advisers will be essential so that full environmental benefits can be realised. Measures must be targeted and result-orientated to deliver maximum environmental benefit. Ensuring this proper match between local conditions and selection, local threats and local priorities will result in the selection of appropriate measures.
· In relation to measures such as hedgerow establishment, species rich grassland, etc, farmers that sign up to these measures need to be educated through workshops and farm walks. Agri-environmental specialists are best qualified in providing these services. We have learned that agri-environmental education was effective when carried out in a practical manner by agricultural advisers with relevant material and demonstrations.
· A significant bank of technical knowledge and expertise on environmental issues has been built up over the last 15 years. The ASA fears that much of this will be lost if the proposed new scheme is implemented.
· Agri-environmental advisors have carried out an extremely important agricultural technology transfer function. Indeed, for many REPS participants, it was their first time to have a professional agriculturalist on their farm. The ASA believes that this has led to significant improvements in the technical efficiency of Irish farmers in areas such as nutrient management planning, grassland management, animal breeding as well as business advice. Therefore, it is crucial that professional agriculturalists continue to be involved in any new agri-environmental scheme.
2.4. Range of Actions
The ASA recommends that all existing options in REPS be included in any new scheme. We also believe there is scope to include innovative measures such as carbon credit trading, water harvesting and measures to increase soil organic matter. While this list is not exhaustive it provides a basis for exploring further actions that can provide real environmental value. The ASA believes that there are few new ideas or principles contained within the range of actions outlined in the DAFF proposal. The measures should be based on ideas and principles that can be carried forward into the Rural Development Framework 2014-2020.
2.5. Monitoring and Inspection
To maintain high standards in the scheme, inspections should only be carried out by personnel that are appropriately qualified in the relevant areas (Agriculture and Environmental Science) and to the right standard (level 8 degree at a minimum). In addition, all plans and proposals submitted by farmers should be assessed by similarly qualified staff.
2.6. Scheme Evaluation
Evaluation commitments are set out under Article 84 of Council Regulation (EC) No. 1698/2005. The ASA recommend that a baseline is set for indicators for each measure at the start of any new Agri-environmental scheme and that they are then evaluated over the life of the scheme. These indicators should not alone provide for quantitative data on the new Agri-environmental scheme but qualitative data on the scheme providing evidence that habitats are being returned or maintained at 'Good conservation status', for example. Equally for water quality, indicators should be chosen that describe the contribution of agriculture to improving water quality.
By being able to show qualitatively that the scheme is achieving these environmental goals and contributing to what society wants, it will make it easier in the future for Ireland to compete for funding from Europe.
ASA members are the most appropriately qualified and have the optimum experience and skills to carry out such evaluations.
Ireland Rural Development National Strategy Plan 2007 - 2013
Submission by the Agricultural Science Association (ASA) to the draft strategy as circulated for consultation by the Department of Agriculture and Food.
Overall, the ASA welcomes the commitment of €7 billion to the strategy and looks forward to its members playing a lead role in its promotion and implementation. This submission outlines the views of ASA under each axis of the strategy.
Axis 1: Competitiveness
Structural Improvement
The continued support for the Scheme of Installation Aid and the Early Retirement Scheme is greatly welcomed. Uptake of both schemes is vital to the future competitiveness of the primary production sector of farming. Targets should be set that quickly pick up the reaction to both schemes. The ratio of farmers under 35 years to those over 55 years is given as 0.26. A target figure should be published for each year of the strategy. Careful monitoring of such a target would allow a rapid reaction to affect necessary changes to both schemes if uptake is falling below target.
Education and Training
This measure is welcomed and funding in total from the national exchequer is noted. Courses must be attractive to ensure the widest possible participation. The recent Review of Education and Training as published by Teagasc must be fully implemented. All courses offered should be accredited and all trainers should have professional training to ensure the highest standards of tuition and up to date course content. Registration of tutors should be considered.
On Farm Capital Investment
The ASA estimate that in excess of €1.5 billion will be invested by farmers over the lifetime of the Farm Waste Management Scheme. This upgrading of on farm facilities will ensure that food can be produced to the very highest standards on Irish farms in to the future. As exports of farm produce accounts for over 20 percent of net exports, it is crucial that our export markets are protected to ensure the long term viability of farming. The massive investment in upgrading should be used as a promotional tool abroad to demonstrate that facilities on Irish farms are ultra modern to ensure the production of food in a safe, clean environment.
The Forestry Sector
The attention to the forestry sector and in particular farm forestry throughout the strategy is welcomed. Improvements in forest infrastructure are a pre requisite for a competitive forestry sector. This issue must be quantified fully and resourced to ensure the maximum participation by existing forest owners in the development of forest roads etc. Clear targets are needed e.g. kilometres of roadway installed each year.
Axis 2: Environment
ASA members play a key role in the delivery of professional advice on the environment and related schemes. Targets for participation levels in the rural Environment Protection Scheme (REPS) should be set. ASA suggests that a target figure of 65,000 participants by 2010, covering well in excess of 50 percent of the land mass of the country, is realistic.
An environment scheme that links forestry and environment is necessary .The present position where REPS payments are competing with afforestation payments is having a detrimental effect on the uptake of forestry as an alternative land use option. This should be rectified by including forestry in REPS or a linked scheme.
Axis 3: Diversification
The encouragement of diversification within the farm gate is welcomed. Special emphasis should be placed on equipping farmers with new business skills such as selling techniques. Any non agricultural activity that farmers engage in will require new skills. Technical skills are essential but modern business skills are even more critical. Farmers must be mentored to develop new ideas and be taken through the stages of new business development. Adult training with a large component of communication and sales development skills should be put in place. DAF is urged to consider further consultation with ASA on this issue.
Axis 4: Leader
Leader Groups have been central to the delivery of rural revelopment measures over the past fourteen years. Their level of local involvement is very high and must be maintained. The roles of Local Authorities, Enterprise Boards and Leader Companies should be redefined as the new strategy is launched. This will ensure clarity in the minds of rural dwellers as to who is responsible for what action and will ensure that duplication is avoided.
ASA Calls for Expert Group on Phosphorus Derogation
The President of the Agricultural Science Association (ASA), James Fitzgerald, has highlighted the major risks to agricultural output and the agri-food industry following the implementation of the Nitrate Action Plan.