The Irish Natura and Hill Farmers' Association (INHFA) has questioned the inclusion of two of the appeal requirements as part of the mechanism for the Good Agriculture and Environmental Condition 2 (GAEC 2).
It follows the publication of the details of the process by the Department of Agriculture Food and the Marine (DAFM).
GAEC 2 is the conditionality standard of the Common Agricultural Policy (CAP) related to the protection of peatlands and wetlands.
It formally entered into force on May 1, which means that any works carried out before that date do not come under the scope of the condition.
Under the condition, the maintenance of an existing drain is permitted and replacement is acceptable.
However, new drainage on never-drained parcels of land will require planning permission or an exemption from the local authority, as is currently the case under national legislation.
The two requirements which are of concern to the INHFA are:
The INHFA has written to DAFM indicating the need to remove both points claiming they are "not relevant".
The farm organisation said that those appealing are doing so because they believe the land has been incorrectly included under the GAEC 2 standard.
INHFA president Vincent Roddy said: "This is a point we have made to DAFM staff on a number of occasions and it is difficult to understand why they have pursued these options.
“For many farmers the issue around GAEC 2 lands isn’t necessarily about drainage, but the fact that the GAEC 2 standard has been incorrectly applied on non-peat soils (mineral soils).
"It is important to understand that for some farmers, the need to carry out land drainage may never feature. For these farmers the issue is that their land has been incorrectly mapped and now included under a standard that may have long-term implications, some of which may not even feature as of now.”
The INHFA has now stressed the need for DAFM to re-evaluate the appeals process and remove both of these points.
"[The] issue isn’t about land drainage, but the fact that land parcels were incorrectly mapped and there needs to be a simple appeals process to correct this," Roddy said.