Final CAP post-2027 submission · Part III

The sectors the system forgot — and how the books balance.

Forestry, sheep and wool, the hills, horticulture, pigs and poultry, farm energy, and the dairy-beef bridge. A funding line beside every proposal — because a submission that will not show its sums is asking someone else to do its arguing.

Submitted by Brendan Kennedy  ·  Working farmer, Co. Tipperary  ·  July 2026

⬇ Download Part III (Word)

Part I proposed quality-linked coupled support for beef within the available coupled-support ceiling. Part II applied the retirement and transfer package across sheep, tillage and dairy — reward the movement, not the birthday. Part III finishes the job by addressing sectors the current system has overlooked and putting a named funding source or regulatory route beside every proposal.

The coupled-support ceiling is already allocated in Part I. It is not spent again here.

Everything in Part III is funded from a different named pot, a redesign of an existing measure, private capital, or a regulatory change. Where a genuine trade-off exists, it is declared rather than hidden. There is one: sheep.

Forestry — plant for the family, not the fund

Ireland's Forestry Programme for 2023–2027 is funded separately from the main CAP direct-payment envelope. The core problem is not simply the size of the budget. It is design and delivery.

Long licence delays can undermine the value of forestry as a retirement or succession asset. At the same time, premium structures and land competition can make it harder for younger farmers to compete for suitable ground. The policy should support long-term family ownership rather than create a system in which public support unintentionally strengthens institutional land buying.

Front-loaded premiums for farm-family ownership

Premiums should be strongest where forestry remains part of an active family farm or passes to a genuine successor. Standard rates should remain available elsewhere, but public support should not allow institutional buyers to outbid young farmers for the same land.

Agroforestry that works on real farms

A drystock farmer should be able to plant a shelter belt, a field corner, a riparian strip or a low-density agroforestry system without automatically losing all agricultural payment eligibility on the wider parcel. Any retained BISS, CRISS or ANC eligibility should be based on the final adopted rules and verified land use.

A statutory clock on licences

Afforestation and felling decisions should operate within clear legal time limits. A licence system that takes years to deliver a decision destroys planning certainty and weakens the asset the farmer was encouraged to create.

Sheep and wool — pay for flock quality, publish the price

The Sheep Improvement Scheme provides a basic support structure for active flocks. Part II already proposed a flock-transfer measure to help sheep enterprises move to genuine new entrants. The remaining issue is quality and value. A sheep payment should reward measurable flock outcomes rather than simply count animals.

Wool presents a different failure. For many Irish farmers, the return from wool does not cover shearing and handling costs. Prices vary by grade, quality and market, but the farmer often has little dependable public information before the merchant names a figure. IrelandCattlePrice.com has begun publishing a weekly Irish wool price, but one independent publication is not a substitute for a complete national reporting system.

A quality-scaled ewe payment

The payment should build on the Sheep Improvement Scheme and reward outcomes such as flock health, genotyping, lambing performance, maternal quality and reduced mortality.

This is the one declared trade-off in the submission. A coupled ewe payment inside the same ceiling used for cattle would reduce the available cattle rate. For that reason, the sheep measure should be funded through the rural-development or exchequer-supported side of the system rather than by spending the coupled pot twice.

Mandatory weekly wool-price reporting

The Irish Grown Wool Council, or another designated national body, should collect and publish weekly wool prices by wool type, grade, region and sale channel. The aim is not to set the price. It is to let farmers see the trade before they sell.

A demand floor through public procurement

Where technically suitable, public retrofit and construction programmes should allow or specify natural-fibre insulation, including suitable grades of Irish wool. That would create a dependable demand route for coarse and crossbred wool that is otherwise difficult to market.

Scouring, grading and processing capacity

Ireland needs domestic or all-island capacity for washing, grading and preparing wool for higher-value use. Raw wool should not leave the farm system with most of its potential value still unrealised.

The hills, commonage and walks — pay for the public good

Hill farmers maintain grazed uplands, commonage, tracks, paths and landscapes that support tourism, biodiversity, fire management and rural access. The Walks Scheme helps in defined areas, but it reaches only part of the land and part of the farmers doing the work. Where grazing disappears, scrub and fire risk can increase and access can deteriorate.

An upland eco-scheme action

Farmers and commonage shareholders should be paid for verified management of grazed uplands, controlled vegetation, fire-risk reduction, maintained access and agreed biodiversity outcomes. The measure should pay the people carrying out the work rather than treat the hill as an unmanaged backdrop for tourism.

An expanded Walks Scheme

Where public walking routes cross farmland, the scheme should reach more landowners and provide payments that reflect maintenance, access, liability and lost use.

Horticulture — the fewest hands, the thinnest price

Ireland has very few commercial growers relative to the importance of domestic fresh food production. They sell perishable produce into a concentrated retail and wholesale market, often under terms that are not publicly visible. Perishability leaves growers with very little time to hold out for a better offer. That weakens their bargaining position before price is even discussed.

Full enforcement of Unfair Trading Practices rules

The Agri-Food Regulator should actively enforce written terms, payment deadlines, rejection rules and prohibited trading practices. Penalties should be large enough to change behaviour.

Published price and margin data

Farm-gate, wholesale and retail price information should be published regularly by product. The aim is not to control prices. It is to show where value is created, lost or retained along the chain.

Support for producer organisations

The EU fruit and vegetable regime provides co-funding for growers who organise to market, plan production and invest together. Ireland should make far greater use of it. Growers negotiating collectively have a better chance of dealing on equal terms with national buyers.

Pigs and poultry — transparency, not headage

Pig and poultry farms receive relatively little land-based support compared with more extensive sectors. They operate through concentrated processing and contract systems in which individual producers may have limited price visibility.

Pig producers often sell against a weekly processor quote. Poultry growers commonly operate under integrator contracts, with limited public information on payment structures and contract terms. The issue is not the absence of another headage payment. It is the absence of a transparent market.

Mandatory price and contract reporting

The Agri-Food Regulator should collect and publish anonymised information on pig prices, poultry growing payments, contract terms, bonuses and deductions, payment periods, and major changes in processor conditions. This is a regulatory measure, not a new direct-payment scheme.

Capital and energy support

Pig and poultry farms have large energy needs and extensive roof space. Existing capital and solar measures should be designed so these farms can invest in renewable electricity, heat recovery, ventilation, storage and energy efficiency.

The farm as power station — energy income on every holding

Farm buildings and suitable agricultural land can generate income as well as consume energy. TAMS solar support operates through a separate investment ceiling from the general farm-investment ceiling, allowing eligible farmers to invest in farm-scale generation without using the full general ceiling on the same project.

Agricultural payment eligibility on land containing solar infrastructure should depend on the actual eligible agricultural activity and the final scheme rules. Where grazing continues and the land remains genuinely agricultural, the payment system should recognise that use rather than automatically treating the parcel as lost.

A roofs-first farm-energy policy

Priority should go to farm sheds, yards, existing structures, brownfield locations and genuinely dual-use grazed systems before productive farmland is removed from food production.

Faster grid access for farm-scale generation

Small and medium farm projects should not be trapped behind long grid queues designed around utility-scale developments.

A farmer ownership stake

Where renewable projects are built on farmland, farmers should have the opportunity to hold an ownership or revenue stake rather than receiving only a fixed lease payment. For a retiring farmer under Part II, the shed roof could become a dependable pension supplement even after livestock numbers fall.

The dairy-beef bridge — quality from birth

A growing share of Irish beef originates in the dairy herd. Whether those animals can finish efficiently and meet market specification is strongly influenced by breeding decisions made at the start.

Dairy also demonstrates the value of price transparency. Milk prices are routinely published, compared and discussed across processors. That has not prevented competition. It has given farmers a clearer view of the market.

A dairy-beef breeding measure

Support should encourage high Commercial Beef Value beef AI, sexed dairy semen where appropriate, stronger beef merit in non-replacement matings, and verified breeding decisions through ICBF. The aim is to ensure that calves entering the beef system have a realistic route to efficient finishing and acceptable carcass performance. The measure should be paid at AI-subsidy scale and verified through existing breeding records.

How the books balance

Not one euro in Part III is drawn from the coupled-support allocation used in Part I. The books balance because most of the sectors discussed here do not primarily need another headage payment. They need better rules, visible prices, enforceable contracts, targeted redesign, and support drawn from the pots already intended for those purposes.

The structure is:

• Part I — beef coupled support. Sized to the coupled-support pot available under the final rules. Rates adjust to the pot. The first 25 cows remain the priority.
• Part II — retirement and establishment. Funded through the final generational-renewal allocation, national co-funding and any establishment framework ultimately adopted. Any reference to packages of up to €300,000 should be treated as a proposed maximum framework, not a guaranteed payment to every entrant.
• Forestry. Funded through the existing Forestry Programme outside the beef coupled-support allocation.
• Sheep. Funded through rural-development and exchequer support. This is the submission's one declared trade-off.
• Wool. Delivered through reporting rules, public procurement and processing support.
• Hills and commonage. Funded through eco-scheme reallocation and Rural Affairs measures.
• Horticulture. Funded through EU producer-organisation support and existing national schemes.
• Pigs and poultry. Funded through existing capital and energy supports, with transparency delivered by regulation.
• Farm energy. Funded through existing solar supports and private capital.
• Dairy-beef breeding. Funded through small-scale reallocation within existing breeding, welfare or environmental measures.

A smaller CAP budget would reduce the payment-based measures. It would not reduce the value of transparency, contract security or better design. Those become more important when money is tighter.

The common thread — transparency

A pig farmer taking a weekly quote he cannot verify, a poultry grower working under private contract terms, a sheep farmer handing over wool below the cost of shearing, or a grower selling into a market where the buyer's margin is unknown all face the same basic problem as the beef farmer at the factory gate. They are negotiating with less information than the buyer.

Every measure in this Part does one of three things: publishes a price; enforces a contract term; or pays openly for a public good.

That is not an extra theme added to the submission. It is the principle the submission was built on.