The Irish Farmers' Association - IFA

Lobbying Organisation The Irish Farmers' Association - IFA

Date published 21 May, 2023

Relevant Matter Legislation

Public Policy Area Agriculture

Period 1 Jan, 2023 to 30 Apr, 2023

Specific Details Common Agriculture Policy (CAP) Strategic Plan 2023 - 2027 - first proposed amendment

Intended results To highlight that the new Common Agricultural Policy (CAP), spanning 2023-2027, is fundamentally different to its predecessor. To highlight that the EU policy and its Irish interpretation via the CAP Strategic Plan (CSP), will leave farmers, many dependent on their CAP payments for their income, faced with lower payments but having to fund more costly actions, including some which will challenge their productivity. To highlight that this CSP has focused on environmental sustainability with little or no consideration for the economic or social consequences for farm families. CAP must support farmers in vulnerable sectors, especially farmers in all beef systems, sheep and tillage farmers. There exists numerous new schemes and concepts too which bring considerably more complexity, administration and bureaucracy relative to past iterations, contrary to the touted ‘simplification' objectives for CAP from national and EU institutions. When combined with an increased reliance on third parties (farm planners/advisors etc.) and the emergence of a new monitoring infrastructure (AMS), increased flexibility and protection measures (including amongst others payment schedule & administration) must be afforded and granted higher priority within the CSP going forward, not only to preserve and maintain existing farm operations but also to protect and secure the fundamental privacy and data protection rights of Irish farm families. Farmers simply cannot be unduly disadvantaged / penalised from the implementation / governance of the CSP (either via constrained scheme participation; reduced budget allocation and/or delayed receipt of farm payments); and/or must not be prone to increased on-farm inspections following direct/indirect advances in available technologies; data collection or monitoring mechanisms. To point out that IFA reject the DAFM proposed delayed farm payment schedule for 2023 – suggested a consequence of required internal infrastructural re-design and new CSP requirements. If additional resources are required to meet new CSP requirements, the Minister involved needs to secure same. They cannot simply pass on the additional cost/disadvantage to the farmer Thousands of farmers have their businesses structured around receiving these payments on the dates they get them every year. Delaying them will affect bank repayments and cashflow to meet other bills which is simply unacceptable. Regarding the new data collection or monitoring mechanisms (including AMS), the rights of the farmer must be secured and protected at all times, with the sharing or transfer of data from one data source to another, even within individual entities, not permitted without the prior consent of the farmer. The level of ongoing monitoring/inspection of on-farm activities must also be proportionate and similar to that afforded to other employment cohorts In the case of the Area of Natural Constraint payment, why is 100% inspection now required when previously 5% was deemed satisfactory – for a scheme that is largely unchanged under the new CAP programme. Ultimately, it is imperative to that insights gleaned from the ongoing implementation & governance of the CSP are taken into consideration and necessary adjustments made to the CSP. Regarding specific proposed amends, as presented, to the current CSP, please see below • Correction to Section 2.3.3 Agree • Section 3.10.4 - GAEC 8 Biodiversity & landscape (protection & quality) - Buffer Strips (ASSAP) Agree, with provision that no farmer is significantly disadvantaged from any discrepancy that may arise between estimate & measurement • Section 3.10.4 - GAEC 8 Biodiversity & landscape (protection & quality) – Stonewalls Agree, with any additional advantage from inclusion provided to farmers for 2023 payments, most particularly those marginal cases surrounding required thresholds • Section 5.3 Dairy Beef Welfare Scheme updated to allow for 3-star DBI bull to be used, and word in eligibility section simplified Agree • Section 5.3 ACRES – Correction to the protection of Rare Breeds action Agree • Section 5.3 Update to Indicators for ACRES GR – Agree • Section 3.10.3.1 Amendment to GAEC 5 Tillage management, reducing the risk of soil degradation and erosion, including consideration of the slope gradient Agree • Section 3.10.3.3 - Amendment to GAEC 7 Crop rotation in arable land except for crops grown under water Agree • Correction to Section 4.2.1.4 Agree • Changes to the Fruit and Vegetables PO intervention Agree • Section 5.3 Changes and technical amendments to Suckler Carbon Efficiency Programme Agree • Section 5.3 Changes to ACRES Genetic Resources Agree • Correction to Section 7.3 Organic Farming Scheme Agree • Correction to Section 5.3 Sheep Improvement Scheme Agree • Section 5.3 Knowledge Transfer – Simplification of language used in eligibility criteria Agree • Updates to Sections 7.1 and 7.4.4 Agree • Amendment to Annex 7.3 EAGF / EAFRD – Subject to discussion and agreement at the Farmers Charter if Rights • Updated links to SEA report amd Ex ante report in Annex 1 Agree • Various updates to Indicators for Fruit & Vegetable Producer Organisation Support Scheme Agree • Correction to Table 6 in Section 3.4 Agree • Change to 7.3.1.1.4 Article 10 (4) of the Implementing Regulation on IACS requires that the AMS be operational for BISS and ANC from 1st January 2023. Given their scale and scope, implementing AMS for both BISS and ANC has resulted, potentially, in a delay to key on-farm payments. Ireland must resist and seek a derogation for 2023, with the aim of full implementation by January 2024 (in accordance with Article 68 (1) HRZ). • Change to 3.1.3 Agree • Corrections to AECMTR Agree • Correction to CIS-YF paragraph in Section 2.1.SO1.9 Agree • Correction to Section 7.2 Agree • Rectifying a technical error in the Planned Unit Amounts for the AECMGR Agree • Correction of a technical error in 53LEADER Section 13 Agree IFA insists that farmers cannot be disadvantaged from increased administration/bureaucracy in implementing CAP Strategic Plan That there would be no delay in farm payments That there would be a derogation against Article 10 (4) of the Implementing Regulation on IACS which requires that the AMS be operational for BISS and ANC from 1st January 2023, with the aim of full implementation by January 2024 IFA highlights the need for increased flexibility and greater protection measures (& priority to same) for farmers in new CSP To highlight that farmers cannot be exposed to increased inspections as a consequence of new data collection & monitoring instruments (e.g. AMS). To highlight that the level of ongoing monitoring/inspection of on-farm activities must also be proportionate and similar to that afforded to other employment cohorts IFA insists that Personal / Business data can only be shared with formal consent on the part of the farmer IFA recommends that insights gleaned from the ongoing implementation & governance of the CSP are taken into consideration and necessary adjustments made to the CSP To seek support from MEP's to minimise future changes to the Common Agricultural Policy (CAP) To seek improved working conditions on farm including economic and social sustainability. To seek support for IFA position against introduction of measures restricting food production.

Name of person primarily responsible for lobbying on this activity Liam McHale IFA Director of European Affairs,Shane Whelan IFA Senior Policy Executive, Rachel Moloney IFA Policy Executive

Did any Designated Public Official(DPO) or former Designated Public Official(DPO) carry out lobbying activities on your behalf in relation to this return? You must include yourself, and answer Yes, if you are a current DPO or a DPO at any time in the past. (What is a Designated Public Official?) No

Did you manage or direct a grassroots campaign? No

Was this lobbying done on behalf of a client? No

Lobbying activity

The following activities occurred for this specific Subject Matter Area.

Submission (1)

Meeting (2-5)

Informal communication (2-5)

Email (2-5)

Designated public officials lobbied

The following DPOs were lobbied during this return period on this specific Subject Matter Area. These DPOs were involved in at least one of the Lobbying Activities listed above, but not necessarily all of them. As returns are specific to a Subject Matter Area the above Lobbying Activities may be associated with multiple returns.

Barry Andrews MEP (European Parliament)

Chris MacManus MEP (European Parliament)

Ciarán Cuffe MEP (European Parliament)

Clare Daly MEP (European Parliament)

Colm Markey MEP (European Parliament)

Deirdre Clune MEP (European Parliament)

Frances Fitzgerald MEP (European Parliament)

Grace O'Sullivan MEP (European Parliament)

Luke Ming Flanagan MEP (European Parliament)

Maria Walsh MEP (European Parliament)

Mick Wallace MEP (European Parliament)

Paul Savage Assistant Secretary (Department of Agriculture, Food and the Marine)

Sean Kelly MEP (European Parliament)

Billy Kelleher MEP (European Parliament)