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Cross Compliance

08 February 2019
Type Media Article

By Glen Corbett, B&T Drystock Adviser, Teagasc Galway/Clare

Cross Compliance – Background:

It’s fair to say that CAP has benefitted Irish farmers financially since we joined the EU. Even with the next round of reforms likely to be affected by Brexit, we still expect Irish farmers to be supported within their different sectors by CAP. The 2005 change to the Single Payment Scheme (SPS) was significant and has continued to evolve since; the ANC is undergoing changes at present. There are two types of checks carried out for the purpose of implementing these and other schemes; they are Eligibility checks and Cross Compliance checks.

What’s involved?

Cross Compliance involves two key elements:

A  A requirement for farmers to comply with 13 Statutory Management Requirements (SMRs) set down in EU legislation on public health, animal and plant health, animal welfare and the Environment.

B  A requirement to maintain the land in good agricultural and environmental condition (GAEC).

List of SMRs:

So, there are 13 SMRs and it’s possible for any farmer to get inspected under one or more SMR headings. But which ones are relevant to most farmers?

SMR 1 – Relates to Nitrates:

Inspections under this SMR 1 will involve checks that livestock manures and other organic fertiliser storage facilities have sufficient capacity and are constructed and managed properly. That organic and chemical fertilisers are spread according to regulations (dates etc). Fertilisers and slurry are not applied during prohibited spreading periods.  As an Adviser, I would say to all farmers, watch out for the amount of chemical P use on holdings in particular. Every farm has a maximum allowed limit to stay under (this will be in your Nutrient Management Plan) based on soil sample analysis. I’ve seen much more farmers go over the allowed P level than the allowed N level for example over the last number of years. Ask your Adviser to work out your fertiliser allowances each year.

SMR 10 – Relates to Plant Protection Products (PPPs):

This has become more topical recently due to issues with use (misuse) of MCPA, glyphosates etc. as it appears in groundwater. Only authorised or registered plant protection and biocidal products can be stored and used on a farm. These products must be handled and used properly. Records of purchase and usage must be completed and kept up to date. Are you a registered sprayer user? Is your sprayer calibrated? Have you a professional user number that allows you to spray on your own land or for other farmers?

SMR 7 and 8 – Relates to Cattle and Sheep Identification and Registration: 

Most issues with non-compliance and penalties fall under these 2 SMRs. The big misdemeanour here is missing tags. A certain low number of animals with one tag can be accepted, but animals missing 2 tags, automatically leads to a 1% penalty on payments.

As regards farm to farm movements, please remember that it’s the Buyer’s responsibility ultimately to get documentation sorted. There is a seven day deadline to get this done.

SMR 7 Cattle:

Firstly here, an inspection will involve determining are all animals tagged and registered properly. Is the Bovine Herd Register up to date? (from inspection reports we are hearing there is a good standard of Blue Books amongst farmers). Do the animals on the farm match the Department’s Herd- Profile? Is there a passport for each animal on the holding and is it signed by the Keeper? For example as recently as 2016, 61% of non-compliances under SMR 7 related to tagging irregularities - something very much within every farmers control and therefore it is avoidable.

SMR 8 Sheep:

A check here will try to determine that sheep are tagged according to requirements. (New tagging regime in 2019). Is the Flock Register and dispatch book up to date? Is flock reconciliation completed at the end of the year?

GAEC – Good Agricultural and Environmental Condition:

This may be a term that is new to some farmers. It’s the heading used to generally cover the overall condition of your farm holding, covering the soil, any habitats and also how you are ensuring that there is no encroachment of invasive species.

As we move into spring, one of the possible sanctions farmers may get is in relation to poaching around Ring Feeders. This is the process whereby we get liquid soil (mud) around these feeders as a visible sign of damage to land. Also it is a very likely source of point source pollution. Watch out for this, it will be penalised. Keep these feeders at least 20m away from drains/watercourses and rivers.

Another issue I would like to mention is that of hedgerow removal. These hedgerows are considered landscape features. If you plan to remove a hedgerow, you should plant the equivalent amount in advance elsewhere on your holding. The Wildlife Act applies here – no hedge cutting or burning of vegetation from 1st March – 31st  August each year.

Are you reclaiming land or planning to remove scrub or re-contour land? If so and if the land area involved is over five acres, then this will require screening by the Department of Agriculture. This falls under what’s called EIA (Environmental Impact Assessment). Please check the Department’s website www.agriculture.gov.ie under Rural Environment and Sustainability for more details on this.

Cross Compliance Event:

Teagasc and DAFM are holding a Cross Compliance Event in the Ard Ri Hotel, Tuam, Co. Galway on Wednesday, 20th February at 6.00pm. All are welcome and One to One Clinics will be held afterwards for farmers that may have any further issues or queries.