Specific Details
TAMS 3 (Targeted Agricultural Modernisation Scheme 3)
Intended results
That further expansion should be considered, alongside greater TAMS (Targeted Agricultural Modernisation Scheme) allocated funding from unused RDP ( Rural Development Programme) funding, to yield even greater dividend with regard to on-farm efficiencies; farm safety; water quality; reduced emissions etc.
TAMS has contributed considerably to the upgrading and modernisation of Irish farms, improved on-farm safety and efficiencies through the purchase of new and innovative equipment and technology for many years. This has been aided considerably most recently in TAMS 3 with increased investment ceilings, grant rates and qualifying items
The underlying context within much of the documentation provided is that the luxury of having sufficiently available funds, which saw 100% approval of eligible applications through Tranches 1-4, is waning, meaning greater utilisation of Ranking and Selection criteria will likely be required into the future.
To query, to aid knowledge and understanding, to get a comprehensive outline/update on where the overall TAMS 3 budget is at currently - i.e. overall allocations and expenditure of the €370m fund to date (by scheme); typical conversion rates; average investment amounts (all by scheme); how much of allocated funds is coming from ‘new money' from the CSP; or ‘reallocated money' from RDP funding; and where will funding for the new Nutrient Storage Scheme come from?
To question why, as Per Department of Agriculture, Food and the Marine (DAFM) website, entering the first week of 2025, only €36.538m out of a possible €100m allocation for years 2023/2024 to TAMS 3 has been paid out thus far. It isn't therefore automatically obvious why the output of Ranking and Selection would become more critical in the short-term than that to date.
To propose the following amendments
1. Removal of negative marking for payments received under TAMS 2 schemes.
The removal of the negative marking for payments received under TAMS II schemes is a positive and logical development given TAMS 3 is a new independent scheme with investment ceilings etc reset to 0.
2. Removal of 20 negative marks under the Nitrates criteria where an applicant has Nitrates per Hectare at or above 170kgN/ha prior to export.
To propose that the Nitrates metric be removed entirely from the Ranking and Selection criteria for all TAMS 3 schemes, with the exception perhaps of the Nutrient Importation Storage Scheme as such data is particularly pertinent.
3. To provide details of the proposed ranking and selection for the Nutrient Importation Storage Scheme (11th Scheme under TAMS).
That greater clarity and consistency of application is required with regard to what is proposed
- Why is negative marking assigned for more intensive livestock operations within DES (Directorate of Economics & Statistics); AWNSS (Nutrient Storage Scheme); NSIS (National Sheep Identification System); YFCIS (Young Farmers Capital Investment Scheme); OCIS (On Farm Capital Investment Scheme); WFCIS ( Women Farmers Capital Investment Scheme); FSCIS (Farm Safety Capital Investment Scheme) yet a positive score assigned for more intensive operations in LESS; PPIS; SCIS?
- While it is proposed that the negative 20 marks for those at or above 170kg N/ha is being removed, it is not clearly outlined what will now apply. Is it proposed that -0.01 marks would run even beyond the 170kg level (so a farm at 210kg would be scored -2.1 marks) or is a 0-score assigned (which would be a disadvantage to those operating below 170kg level)? Clarification is required.
- Within the NSIS marking sheet, the 160kg example should be removed or amended as it is inconsistent with the -20 marks at or above the 150kg N/ha threshold suggested. More broadly, to question removal of -20 marks for marking sheets of existing schemes and then introducing it for the new scheme.
To acknowledge that the 150kg threshold is part of the eligibility criteria for the scheme, but if breached, the applicant will be excluded from the scheme entirely rather than scored negative 20marks? There is a need to be consistent also re units assigned (i.e. Kg N/ha or NPH) within the marking sheet also.
To highlight additional Ranking & Selection observations
- It is referenced within the document that each scheme will be assessed independently of each other within a given tranche, and that it is also possible to apply a different % cut-off per scheme within a specific tranche. It is important that a protocol, methodology and governance system is clearly outlined and agreed with farm organisations in advance of its implementation.
As currently provided, is it suggested that one TAMS scheme (e.g. Solar) could be given precedent over another TAMS scheme (e.g. Farm Safety)? Who / how would that prioritization be derived? Even within individual schemes, there are investment items (e.g. around animal welfare etc) that should naturally take precedence over others. An open and honest discussion is required to establish an agreed protocol.
- Within the Tillage Capital Investment Scheme, does there need to be any reference or acknowledgement of the opportunity for farmers to avail of the Baling Assistance Payment rather than the traditional Straw Incorporation Measure in 2024 in the provision of marks? It currently assigns no marks for area not in SIM
- Regarding the ‘Age of applicant', it currently assigns a 0-mark for companies. Is there a logic/justification to same? Why discriminate a farm operated by a young farmer (i.e. <41) that is set up as a Limited company relative to those operating as a Sole Trader; Registered Farm Partnership or Joint Venture?
Broader TAMS considerations
- Implementation and efficiencies involving TAMS have improved considerably through 2024, which is to be acknowledged, however further advances are required, most particularly with regard to direct engagement and communication with farm organisations where amends to existing arrangements are required/foreseen.
As an example, IFA understands, based on recent Department of Agriculture, Food and the Marine (DAFM) communications and updates at the Farmers Charter of Rights meeting at the end Dec 2024, was that TAMS Tranche 6 was opening for applications on January 9th and that all was on track for same. It was only on receipt of supporting documentation for this action (i.e. Amendments to Ranking & Selection criteria) that we learnt that the date was pushed out to January 23rd.
To emphasise that this is not acceptable, and to avoid a slippage in administration gains secured, it is essential that no further delays occur and the Tranche opens as soon as possible.
- Per Farmers Charter of Rights agreement, ‘the opening and closing dates of each Tranche will be provided at the Final Monitoring Committee meeting each year'. These have yet to be received for 2025
- Justification for the delayed opening of Tranche 6 was to accommodate necessary infrastructure build for new Nutrient Storage Scheme. There is no reference to this scheme (i.e. 12th Scheme under TAMS) within the documentation provided, nor any insight provided surrounding the ranking & selection criterion under consideration, which would be beneficial.
- TAMS reference costs remain below prevailing costs, most particularly for cement; sand & gravel (both +c10% Nov '24 vs. base reference Feb '23 prices per CSO data). In line with inflation levels, further investment ceilings must be increased, and costs should be index-linked or updated annually
- Dribble bar technology should be re-instated among the list of eligible items within the Low Emissions Slurry Spreading (LESS) scheme. The dribble bar is scientifically proven to reduce emissions relative to the traditional splash plate method, and while perhaps not as efficient as the trailing shoe option, it was better suited for smaller powered
tractors; heavier type soils and uplands; was cheaper; lighter; and capable of being retro-fitted onto existing tankers – all pointing to an increased uptake among farmers where LESS technology was required. Grant aiding only the trailing shoe option within TAMS significantly disadvantages those farmers in low-margin enterprises, those on heavy soils and in upland areas.
With increasing focus on the agri sector to meet its emission reduction targets, and greater numbers required to utilise LESS as per the nitrates directive, the dribble bar must be added back once again to the list of eligible items within TAMS to support best practices.
- Increased, proactive communication from DAFM regarding changing thresholds and compulsory LESS applications, will allow impacted farmers apply for grant aid for essential items while still in scope. Failing to do so, given the investment costs involved and limited on-farm margins may mean such investments prove cost prohibitive.
- The funding of solar panels should be provided independently of TAMS. The vast majority of the emissions reduction arising from solar panels and anaerobic digestion will be allocated to other sectors, not agriculture. A new ‘Roof-top Solar Scheme'(RTSS) and a new ‘Anaerobic Digestion Support Scheme' (ADSS) should be established and financed by the Departments whose sectors are getting the associated emissions benefit.
- The documentation provided states that only four applications were received under the Nutrient Importation Storage Scheme, a scheme that was almost a year in the making. For such low uptake, you would have to question its continuation. Is there any reason for such a low uptake in the scheme? Is the limit on eligible investments / scheme requirements a constraint? Greater insight and adjustment around the scheme is required to boost its attractiveness among farmers.
Amii McKeever
Adviser to Minister (Department of Agriculture, Food and the Marine)
Charlie McConalogue
Minister (Department of Agriculture, Food and the Marine)
Martin Heydon
Minister of State (Department of Agriculture, Food and the Marine)