Commissioner Hogan’s actions welcomed on direct payment guidance

NFU Scotland has welcomed statements on CAP simplification, made by EU Agriculture and Rural Development Commissioner Phil Hogan as the first steps towards a more workable system.  However much more remains to be done.

The comments come following a meeting which took place in Brussels on Monday between EU Agriculture Ministers where a list of priority actions that could help ease the burden of the new rules for 2015 was agreed.

Included in the list is the Commission’s intention to allow member states to only map declared Ecological Focus Areas (EFAs) rather than all potential EFAs.  This will reduce a huge burden on the Scottish Government, a move strongly supported by NFU Scotland as a precursor to opening up new EFA options in the future.

The Union believes strongly that it would be extremely unfair for payments to be withheld from those farmers who have done their best to comply when rules were either unclear or not provided in the first place.

NFU Scotland recognises that the focus on greening is necessary at this stage, but simplification must not stop there – other aspects of the direct payments regulations and their implementation can be simplified without altering the policy intention or disturbing fragile finances.

Some complexity has been necessary to provide flexibility to tailor the CAP to Scottish conditions.  However when options for simplification are offered they should be seized by the Scottish Government.  This will help to reduce the potential for mistakes.

NFU Scotland’s Chief Executive Scott Walker commented: “The efforts made this year by Scottish farmers, to comply with the new greening requirements while at the same time adapting to a completely new support system must be recognised.

“We will be working hard to make sure no farmer, who has attempted to deliver greening under the guidelines that so far have been given loses out.  We need strong recognition from the Government that it will adopt that approach.

“The Scottish Government needs to accept that it has added complexity too, for example by its refusal to use EFA conversion factors that would have greatly simplified measuring some features, both by farmers and SGRPID alike and by its gold-plating of rules on Nitrogen Fixing Crops (NFCs).   It must avoid any further gold-plating, including on permanent pasture, that go beyond the existing EU requirements.

“For Scotland we need a further package of simplification actions to cover elements not just greening, but also the voluntary coupled support schemes, aspects of the administration and control system, cross-compliance requirements and penalties, and for changes to be in place as quickly as possible.

“Much of what’s been announced and the apparent direction of Commissioner Hogan’s travel is in line with NFU Scotland’s extensive submissions to the Scottish Government and European Commission at the end of February.”

Going forward, NFU Scotland urges the European Commission to:

• amend delegated and implementing acts to include detail currently only provided by guidance documents or by word-of-mouth
• adopt a less prescriptive approach to mapping requirements, especially of the ‘reference layer for EFAs’ so as to reduce the administrative burden on Competent Authorities (CAs).
• simplify/reduce the complexity of rules applying to various EFA options to reduce administrative burden on farmers and CAs and so encourage uptake
• remove the opt-out allowing CAs to not implement some EFA options or at least allow Member States to amend their choice of options.
• simplify the calculation of EFA areas by combining Conversion and Weighting Factor
• provide greater latitude for measures that provide equivalent value for the climate or environment despite not being targeted at the same issues as the three standard greening measures
• amend regulations relating to ear tags to include reference to the slaughter tag derogations permitted in Scotland
• amend regulations on spot-checks to minimise the risk of multiple inspections
• accept all forms of evidence as proof of CD compliance
• amend rules on application of reductions and penalties to make these more proportionate and fairer to larger farms.

And for the Scottish Government to:

• remove additional requirements imposed on the NFC EFA option
• take advantage of the flexibility available under the existing legislation to make full use of the conversion factors for field margins and buffer strips
• progress meaningful greening equivalence schemes that better address climate and environment issues in Scotland than the standard greening requirements
• amend Good Agricultural and Environmental Conditions (GAEC) requirements to revert to those in effect up to 31 December 2014 on the protection of landscape features.

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Contact Ruth McClean on 0131 472 4108