Scottish growers are to meet with Richard Lochhead to discuss the damage that current greening proposals will have on their business and to urge the Cabinet Secretary to pause for the sake of the sector.

At the meeting, scheduled to take place in the Scottish Parliament tomorrow (Thursday 2 October), the Union will call on Scottish Government to step back from recently announced rules on greening that go well beyond that currently required by Europe.  Instead, the growers, led by NFU Scotland’s Combinable Crops Chairman Andrew Moir, will urge Mr Lochhead and his officials to adopt a phased approach.  

That would see the simple greening measures proposed by Europe being adopted in year one of the new CAP, the impact that those measures have on greening objectives properly assessed, and then make any necessary adjustments to greening rules in the following scheme years.  Any new greening rules deemed necessary could be introduced in 2016, at the same time as the Scottish Government’s delayed adoption of the equivalence measures available under the EU scheme.

The growers will point out that by sticking with basic European requirements at the outset, it would minimise the compliance headache faced by both growers and Scottish Government inspectors, and reduce the likelihood of infraction proceedings were Scotland faced with an EU audit in the future.

Concerns over Scottish Government’s approach to greening came to a head last week when it took the decision to impose management restrictions on those hoping to grow nitrogen fixing crops in a bid to meet their greening obligations. That decision went much further than EU requirements and is in contrast to the way rules are being applied to growers in other parts of the UK.

A Union delegation in Brussels last week was informed by EU officials that, in their opinion, any Member State or region that place additional standards into greening requirements would be audited to those standards.  Were Scottish Government to introduce gold-plating, it would need its officers to inspect to those standards or run the risk of infraction.

Speaking ahead of the meeting, Andrew Moir said:

“European requirements on greening offer up a fair degree of simplicity and flexibility.  Bolting on additional greening requirements at a national level runs the risk of creating an intricate web of rules that will trap farmers, inspectors and auditors. 

“On principle, we are asking for the Cabinet Secretary not to gold-plate in year one of the new scheme and adopt the simple systems that are available.  

“Pausing would give farmers the opportunity to work within the basic rules and an impact assessment can identify if the base EU measures have delivered on greening objectives.  Then, if necessary, greening extras can be bolted on at the same time as the Scottish Government introduces equivalence measures.

“Taking time out to properly design Scotland’s greening menu can ensure it is workable at farm level, the standards fit with a simple audit process and simplicity and environmental benefits are delivered.

“As well as workable standards on nitrogen fixing crops, conversion factors were also built in to EU greening protocols to simplify the measurement of buffer strips and field margins.  These are all smart greening devices that would fit with farming in the real world but which the Scottish Government has so far excluded from its evolving package.  Defining Scotland’s greening measures has been a frustratingly protracted process at Scottish and EU levels where even basic concepts such as the definition of fallow have yet to be agreed.

“Unfortunately, the current approach in Scotland runs the risk of creating a platform of management and administration detail around greening that would be very difficult to fit into current farming practices and create the kind of compliance trap that the Commission has been trying to avoid.” 

Notes to Editors

• The NFU Scotland delegation meeting with Cabinet Secretary Richard Lochhead in the Scottish Parliament tomorrow (Thursday 2 October) are: Andrew Moir – Arable farmer in Laurencekirk, Chairman of NFU Scotland Combinable Crops Committee; Neil White – Arable farmer and contractor in Berwickshire, member of NFU Scotland Combinable Crops Committee; Willie Thomson – Arable farmer in East Lothian, member of NFU Scotland Combinable Crops Committee; James Logan – Arable farmer and potatoes producer in East Lothian; John Forbes –  Arable farmer in Aberdeenshire, joint owner of East Coast Viners; Allan Bowie – Arable farmer in Fife, NFU Scotland Vice President; Peter Loggie - Policy Manager (Arable), NFU Scotland; Jonnie Hall – Director of Policy, NFU Scotland.
• A photograph of Andrew Moir is available on request from media@nfus.org.uk
• “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.
• Ecological Focus Areas (EFA) - Farmers with more than 15 hectares of arable land will need to ensure that five percent 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/green cover (0.3 weighting)
  • nitrogen fixing crops (0.7 weighting)
  • land lying fallow (1.0 weighting)
• Conversion factors – As a simplification measure, the EU rules allow the use of conversion factors for landscape features such as buffer strips and field margins.  These apply a standard figure per linear metre of the feature to convert to area.  This avoids the need for farmers to accurately measure the width of the feature along its full length and for Government officials to have to check the measurement.
• 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 greening detail that growers and NFU Scotland are still pressing Scottish Government for includes:
  • 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
  • lists of crops acceptable for 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 Bob Carruth on 0131 472 4006