Farmers Being Let Down by Greening and Simplification Agendas

Scottish Government fails to respond to NFUS concerns

Scottish farmers continue to be let down by Scottish Government’s failure to address gold-plated rules around Common Agricultural Policy (CAP) scheme greening measures while Europe’s delivery of CAP simplification, scheduled to come into force in 2017, is disappointingly ponderous.

Following a stormy meeting at the AgriScot event held near Edinburgh in November, when Cabinet Secretary Richard Lochhead and his staff were taken to task by many attendees over Scotland’s gold-plated approach to greening, the Union wrote to the Cabinet Secretary outlining again the many concerns of its members. The letter reiterated points that have been consistently made by the Union over a two year period stating in clear terms that decisions taken at a Scottish level have left our growers at a serious competitive disadvantage.

No response to that letter has been received but a meeting on greening, set up at NFU Scotland’s request, will be held with Scottish Government officials next week.

Europe’s timetable to deliver much-needed simplification in CAP rules is equally frustrating.  With the consultation now open, European Commissioner Phil Hogan said recently that, despite Member States and organisations like NFUS providing their priorities for simplification in March 2015, Europe’s proposals for simplification will not emerge until summer of 2016 and not be brought into legislation until 2017.

NFU Scotland President Allan Bowie said: “I thought AgriScot would have left the Cabinet Secretary and his officials in no doubt about the strength of feeling amongst grassroots farmers about the damage that his gold-plated approach to greening rules has generated.

“But another week has gone by and we have had no official response to the long list of greening concerns that we have been bringing to its door for almost 24 months.

“Combined with the Scottish Government’s costly and ongoing difficulties on support payment delivery, it is fair to say that farmer frustration with policymakers is building daily. It is within the Scottish Government’s gift to make a difference to those farming the land by stripping out the additional greening requirements it has imposed on producers and let them compete on the same playing field as other producers in the UK and across Europe.

“When I have discussions with producers other Member States, they rightly view Scotland as one of the greenest countries in Europe and are astonished at our own Government’s drive to heap more and more requirements on our farmers.

“That said, Commissioner Hogan’s drawn out approach to delivering simplification of the CAP is equally frustrating.  When the Commissioner accepted our invitation to visit an East Lothian farm this summer, the desperate need for him and his officials to simplify the rule book was top of our list of priorities. While we welcome his acceptance of the need for change the timetable shows a worrying lack of urgency and the reality that there will be no discernible benefit from this review for Scottish farmers until 2017.

“As if trying to generate a fair return from producing food isn’t difficult enough at this time, politicians and policymakers in Scotland and Europe need to wake up and realise that their approach to rules and requirements is hindering food production at this time.”   

Notes to Editors


NFU Scotland’s priorities for changes to greening rules and simplification are:

The Scottish Government should:

  • remove additional requirements imposed on the Nitrogen Fixing Crop (NFC) Ecological Focus Areas (EFA) option – especially the new requirements to have more than one NFC crop and to ‘surround’ it with a field margin
  • take advantage of the flexibility available under the existing legislation to make full use of the conversion factors for field margins and buffer strips
  • take advantage of the option to allowing buffer strips to be grazed
  • progress meaningful Greening equivalence schemes that better address climate and environment issues in Scotland than the standard Greening requirements
  • remove the new requirement for mandatory incorporation of Green Cover
  • amend Good Agricultural and Environmental Condition (GAEC) requirements to revert to those in effect up to 31 December 2014 on the protection of landscape features.

The EU Commission should:

  • amend delegated and implementing acts to include detail only provided by guidance documents or by word-of-mouth –such as what constitutes agricultural production on land declared as fallow
  • adopt a less prescriptive approach to mapping requirements which has caused much re-mapping this year and removal of land that was eligible for support in the past
  • simplify/reduce the complexity of rules applying to various EFA options to reduce administrative burden on farmers and Competent Authorities (CA) and so encourage uptake – such as grazing
  • remove the opt-out allowing CAs to not implement some EFA options or at least allow Member States to amend their choice of options – so as to benefit from the dropping of the requirement to map all potential EFA
  • simplify the calculation of EFA areas by combining Conversion and Weighting Factors
  • simplify the definition of crop for the purposes of Crop Diversification (CD) and provide a list of crops considered to be separate – current anomalies lump several vegetable crops together
  • 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.


Contact Bob Carruth on 0131 472 4006

Date Published:

News Article No.: 229/15

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