Decisions being taken without all information available

With the harvest completed for most, farmer focus is on cropping plans for the 2015 season.

Unfortunately, uncertainty remains over what all the rules will be on the so called ‘greening’ measures that they must meet as part of the new CAP.

Frustration with Scottish Government continues to build as increasingly farmers are asking what they should do to ensure that what they plant is compliant with the rules and does not jeopardise their single farm payment.    In the absence of Scottish Government providing a full set of guidance on greening, our members are having to move ahead and make their own choices without all the facts available.   

Farmers are choosing to make some planting decisions now but are leaving some decisions until the spring in order to have some flexibility and the ability to make adjustments to ensure compliance with the greening rules.

NFU Scotland Vice President Allan Bowie said:
“For months, we have been seeking answers to a significant number of questions on the greening aspects of the new CAP but have received insufficient information from Scottish Government.   Now members are making their own choices and hoping that what they do will comply with the rules when they are eventually published in full.   

“While most arable farmers know that if they have more than 30 hectares of arable land - whether crops, temporary grass or fallow - that they will need to plant three crops with rules on the percentage mix of each crop.  A number of farmers, particularly those with temporary grass, don’t realise that the three crop rule applies to them also.   It doesn’t matter if your main activity is arable, livestock or dairy, if you have 30 hectares of arable land including temporary grass then the three crop rule applies to you.

“While the three crop rule causes some confusion, the biggest headache is on how to comply with the Ecological Focus Area (EFA) rules which means that any farm with more than 15 hectares of arable land will need to ensure that five per cent of their arable area is managed in a certain way.   

“This means choosing five per cent of your land and managing it in a way that complies with the EFA rules on field margins or buffer strip if it is along a water course, complies with eligible catch crops, eligible nitrogen fixing crops or is left fallow.

“While there are some exemptions from the three crop rule and the EFA requirements, the default position for all farmers should be the need to comply unless they check to make sure that an exemption will apply in their specific circumstances.”

In the absence of clarity from Scottish Government on all greening requirements, farmers are making choices now that they hope will comply.   Some of the choices being made by Board members of NFUS are the following:

• Board Member 1 - Keeping ground in stubble until spring with the intention of then planting spring barley or spring beans.  Planting beans is the preference but this will depend upon the management rules when they are published.   Just now I am maintaining grass margins and will use them to count towards my EFA requirement if I go down the spring barley route.
• Board Member 2 - Between whole crop triticale and spring barley for combine, I am at about 40 hectares arable.   I also have more than 60 hectares temporary grass which must be taken into account when determining EFA requirement.   The possible management rules for nitrogen fixing crops to qualify for EFA means that my temporary grass acreage will rack me up a significant EFA requirement which will pull precious ploughable land out of production.  As primarily a beef and sheep producer that grows both spring barley for feed and triticale for whole crop, the three crop rule isn’t a problem but to get away from a new form of set-aside and the compliance traps of greening, becoming exempt looks attractive. Unless the EFA package is user friendly, it looks as if walking away from growing my own feed barley and ducking under the 30ha threshold for cropping is the smart way forward. With more than 75 percent grass, I will be exempt from crop diversity and EFA.
• Board Member 3 – I will use field margins and hopefully plant some beans or peas in spring- the fallow option is not good for us.   On river courses, dykes, burns etc. I will already have a two metre GAEC requirement so I believe I will use this to count towards my EFA requirement.
• Board Member 4 - In order to conform to my greening obligations, I have decided not to plough a strip around the headriggs of the grass fields being sown into cereals.    My intention is to mow the grass and take a few silage bales from the buffer strips/margins once the restriction date is passed – assuming there will be a restriction on the grass that can be taken. The advantage as I see it is that the land won't become a weed bank and may provide some good animal feed.  This option should also provide useful wildlife corridors during the growing season and be one of the more environmentally friendly measures.

Notes to Editors

• “Agricultural practices beneficial for the climate and the environment”, known as ‘greening’ are mandatory requirements of the CAP reform coming into force on 1 January 2015.   They require farmers to comply with rules on Permanent Grassland, Crop Diversification and Ecological Focus Areas (EFA).   Thirty percent of the entire budget for direct payments is dedicated to greening.
• Crop Diversification - Farmers with between 10 and 30 hectares of arable land will be required to grow at least two arable crops, with the main crop accounting for a maximum of 75 per cent of the arable area. Farmers with more than 30 hectares of arable land will be required to grow at least three crops, with the main crop accounting for no more than 75 percent of the arable area and the two main crops together not exceeding 95 per cent
• Ecological Focus Areas (EFA) - Farmers with more than 15 hectares of arable land will need to ensure that five per cent of the arable area is managed as one or more of the following

-    field margins and buffer strips along water courses (applying a 1.5 weighting factor)
-    catch crops (0.3 weighting)
-    nitrogen fixing crops (0.7 weighting)
-    land lying fallow (1.0 weighting)

• Farmers who fail to abide by the requirements are subject to reductions in farm support.   In 2015 this could mean the loss of more than 30 percent of their direct payments.   That potential loss increases during the lifetime of the reform.
• The detail that growers and NFU Scotland are still pressing Scottish Government for includes:

-    management rules for Nitrogen Fixing Crops
-    the start and end dates for EFA Fallow
-    what will be required for land to be deemed to be at a farmers ‘disposal’ (important for rental/tenancy issues)
-    any changes on the rules concerning cultivation next to landscape features
-    the rules for catch/cover crops claimed as EFA
-    lists of crops acceptable for crop diversification, ‘permanent’ crops and ‘leguminous’ crops
-    Rules on crops sown as a mixture of species.

Copies of NFU Scotland’s ‘Rough Guide to CAP’ and a guide to greening measures as we understand them are available on the NFU Scotland website at: http://www.nfus.org.uk/node/15466  Members can also contact regional and head office staff for guidance.

Ends

Contact Ruth McClean on 0131 472 4108