Mr. David Scallan:

I thank Mr. O'Toole. He has set the tone well against a backdrop for the need for an upland agri-environment scheme.

I shall quickly outline the background. The interest of the National Association of Regional Game Councils has emerged mainly at grassroot level with our gun clubs getting involved in red grouse management in partnership with commonage owners. Since then we have built fruitful partnerships with a range of NGOs. It is from that platform that we have become interested in ways to deal with the uplands and we can see a real unique opportunity with CAP reform.

I shall outline where the scheme should fit. It would be ideal in Pillar II and in the next rural development programme post-2013. A scheme would target mainly extensive farming and directed at farmers with a significant proportion of semi-natural habitat on their farms. My organisation likes to use the better term of "high nature value farmland".

It is essential that we have an outputs driven scheme and move completely away from proscriptions and penalties. Such a move would simplify the administrative process and I shall talk a little about that later. It would also be above and beyond what is currently available in agri-environment schemes such as REPS, AEOS and the greening measure proposed in Pillar 1 of CAP reform. Our main objective is to encourage farmers to manage their land in a way that will improve the ecological conditions of the habitats. The NARGC has put together a range of options for this and some of them have gained a lot of energy because we are also a part of the national uplands working group which comprises 21 organisations. That has set the tone for a unified vision for the uplands.

We need to introduce a targeted output payment scheme. It is essential because the uplands are farmed landscapes and living landscapes which have been farmed for centuries. The most important compiler of knowledge is the farmer. We should design a simplified scoring scheme that rewards the farmer based on his or her management. Therefore, he or she will be rewarded for good agricultural practice that improves the condition of the habitats. This is a bottom-up approach and it will give the farmer more ownership of his or her farming methods. It would use the farmer as a resource. The scheme could be a lot simpler than the current agri-environment scheme and it could be adapted to suit various habitat types. Obviously sustainable grazing management will be key.

At present there are a range of issues concerning the commonage minimum and maximum grazing levels. My organisation would see this scheme as being a good way to examine site specific ways to develop sustainable grazing patterns. We want the scheme based more on the carrying capacity of the habitats in comparison with what some would argue is a blind approach in terms of identifying grazing rights.

We have listed a range of targeted options, for example the reintroduction of traditional breeds of cattle. This is a way of farming that has been lost in recent years through various policies. We think it could be quite productive in terms of improving specific habitats, grasses competing with heather. We also listed the option of targeted grazing with sheep. This is a return to the old process of shepherding. It is a way of incentivising the farmer to be more active in moving his sheep from areas that are ecologically sensitive through a large berm into areas where there may be tall, old rank degenerative heather than could do with grazing. We would see it as important to have annual heather regeneration. We are discussing the importance of controlled patch burning or heather cutting. I will elaborate more about that. It is to create the culture for heather management. I think this is a skill that has been lost very much in recent years. We know from some of our successful red grouse projects we know that if one can rejuvenate heather and succeed in growing a diversity of young heather stands it is very beneficial for the farmer and for wildlife and good from the point of view of sheep and upland birds. The control of bracken, scrub, rhododendron and non-native species is a major issue mainly associated with land abandonment. Again we think farmers should be incentivised to deal with this issue. Molinia control is also listed and can be quite problematic and a little complex but there are ways either mechanically or through traditional breeds of cattle and sheep to deal with this issue and return habitats to more favourable states. The restoration of areas damaged by over-grazing or illegal burning, one could incentivise the farmer to fence the area temporarily and to move sheep from sensitive ecological areas.

We see the regeneration of heather as essential and we stress the controlled nature of the habitat. There are many local groups that are very interested in getting heather in good condition for red grouse. The gun clubs are a key example. One will see from the image on the screen the controlled nature of what we are talking about. One needs experience and to act in a controlled manner. If one creates the right culture of heather patch burning, it will remove the incentive for large scale illegal burning, which is causing significant damage in the Irish uplands.

My colleague, Mr. Lorcán O'Toole touched on many of the economic issues of tourism. If one can get people to use rural areas, it will be beneficial for rural economies. There is scope to develop paths and walkways and erect stiles to improve access. This would keep pressure off more sensitive habitats and keep farmers happier about access issues and keeping people in the right places at the right times. Heritage infrastructure has a major role to play by directing people with signage with a focus on local placenames.

Under the heading management for specific species, I have listed an example, to encourage the hen harrier, one could breed the curlew or red grouse. One example is predator control. For all red listed bird species, habitat prescriptions is not enough. In some cases, we have evidence from our own projects in which extra options could be put in place, such as the protection of breeding and nesting birds from certain predators, it could be very beneficial. Enhancement work for Natura 2000 will be a major issue. We see this scheme as being very complementary, as it will give the farmer much more ownership of the way he can farm in a sustainable way to achieve results. The current approach is prescriptive and there is not much communication with the farmer. Under the new scheme the farmer will have more ownership of how he works. Selling Natura 2000 is a very good opportunity for farmers. that offers good rewards. We also have an option for supplementary feeding of birds of prey. This is an interesting idea and is used in a variety of EU countries in which there is a possibility of placing fallen stock up on the hill in a controlled manner and it would provide supplementary feeding for birds of prey. It may address some of the other complex issues around birds of prey and improve the environment for them.

There is a range of financial instruments at European level that would allow for an uplands agri-environmet scheme to develop. Article 8 - thematic sub-programmes is specific and could be used very well for more targeted schemes in specific areas. The Irish uplands would fit very well within that category. One will see from Article 36 on co-operation, which is a very good measure that could be used in areas of commonage in particular and would incentivise commonage co-operation with State agencies and local community groups. What is key is knowledge transfer and advisory services. Much work may be required in terms of planning and training in order to get local groups up and running and facilitated. There are a variety of ways in which EU funding could be targeted to achieve this.

The National Association of Regional Game Councils, NARGC, proposes that the Department of Agriculture, Food and Fisheries takes this scheme on board in the next rural development programme. The national uplands working group has also made a submission to the Department. There is a great deal of energy and interest in an agri-environment scheme to address the issues associated with the uplands, which up until now have been neglected in rural development policy.