Minister for Agriculture,
14 December 2011
Doubling of stocking rates in Disadvantaged Areas; Exclusion of non breeding horses
We are greatly concerned about your recently announced decision to double the stocking rate in Disadvantaged Areas from 0.15 LU/ha to 0.30 LU/ha and to hold this stock for six months rather than the previous three months.
These increases in stocking rates are entirely contrary to good environmental practices are appear to be a return to the 'good old days' of high stocking rates to qualify for grant payments. Under your stewardship, there appears to be a resistance at the highest levels to payments based on areas farmed rather than stocking rates, a policy that the European Commission has been pursuing in an effort to reduce the environmental damage caused by the industry.
You implicitly recognise the potential damage that these new rules will bring by suggesting that you might consider exemptions for farmers in sensitive areas such as commonages and areas designated for nature protection. In fact there should be no question whatsoever of increasing stocking rates in these areas, let alone on the other uplands with their vulnerable soils.
High stocking rates have led in the past to a host of environmental problems, including erosion, eutrophication, soil degradation, and increased carbon emissions as well as an adverse judgment from the European Court of Justice in 2002. The Directive under which this case was brought requires "upkeep and management in accordance with the ecological needs of habitats inside and outside the protected zones".
The exclusion of non breeding horses from stocking density calculations is another retrograde step, encouraging breeding at a time when there are so many unwanted horses across the country.
Taken together with your announcement that REPs rates are to be cut again and that no funding has been allocated to its replacement, AEOS, there is a clear danger that the factors which brought Ireland before the Court of Justice ten years ago may arise once more.
We urge you to reverse the requirement for any increase in stocking rates in Disadvantaged Areas.