The Rural Development Programme (RDP) cannot be used to "mitigate the environmental impacts of Food Harvest 2020", the EU Commission has stated in a series of comments and questions on Ireland's RDP proposals which were lodged by the Department of Agriculture with authorities in Brussels.
Worryingly for the Department and Government, the Commission questions whether the Beef Data and Genomics measure was compatible with a programme whose primary aim is rural development. It also raises concerns regarding the new LEADER programme which gives an expanded role to local authorities in supporting rural enterprise.
In addition, the Commission asked why the Department required a minimum of 50pc of active farmers to enter collective management plans for commonages in order to qualify for GLAS.
In all 266 questions and comments have been detailed on the Commission's response to Ireland's RDP proposals.
On Food Harvest 2020, the Commission raises concerns that the RDP is being used to support Ireland's ambitious agricultural expansion plans.
"The Irish authorities are asked to clarify the role of the Food Harvest 2020 strategy in relation to the strategy of this rural development programme," the document states.
"It seems that a number of needs [in the RDP proposals] are derived directly from Food Harvest 2020," it adds.
"Food Harvest 2020 cannot be at the centre of the RDP strategy," the document insists.
A statement in the Irish proposals that the GLAS scheme had been designed to "mitigate the environmental impacts of Food Harvest 2020" is singled out as raising "concerns" and requiring "explanation".
Regarding the GLAS proposals, hill farmers opposed to the Department's requirement for collective agreements for the management of commonages, will be encouraged that the Commission queries the approach taken on commonages.
"What is the reason for specifically targeting commonages and for the required 50pc minimum participation in a commonage plan?" the Commission response asks.
Hill farmers have been strongly opposed to the requirement for collective agreements on commonages since they were first announced.
A series of meetings across the west and northwest have attracted thousands of hill farmers and a further rally is planned outside the Taoiseach Enda Kenny's constituency office in Castlebar this Friday.
However, the Farming Independent understands that the Minister for Agriculture, Simon Coveney, is to meet with a delegation from the Hill Farmers for Action group tomorrow to discuss the issues involved.
Meanwhile, the level of payments available under GLAS, were also questioned by the Commission. It describes the maximum payment of €5,000 or €2,000 as "not justified" and cautioned that the per-hectare ceilings under the RDP "must be respected".
On the Beef Genomic initiative, the Commission said it would require more information "on the precise objectives and scope of the intended support" in order to establish where "this scheme could fit into the [RDP] prpgramme."
The level of support for organic farmers and those working on land designated as Areas of Natural Constraint (ANC), formerly known as Disadvantaged Areas, is also questioned by the Commission.
"The need for support to organic is clearly mentioned, but only a very small amount is reserved for organic farming. The case for ANC payments is not clearly justified, whereas one third of the entire programme is supposed to go to this measure," the Commission states.
Interestingly, the Irish authorities are challenged to justify why no attempt is made in the programme to support producer groups even though the situation of farmers as price takers is identified in the irish proposals.
In relation to LEADER, the Commission questions how the new model involving local authorities, which was introduced by former environment minister Phil Hogan, will work in practice.
It identifies the former community-based structure as a "strength" and asks how the new model will build on this strength - "a more detailed description would be useful," the Commission states.