CAP reform process can reduce compliance burden
With Scotland’s announcement on CAP implementation made by Cabinet Secretary Richard Lochhead last week, the NFU said that the welcome flexibilities built into Scotland’s plans can be underpinned by Scotland adopting a more pragmatic approach to land eligibility rules.
The Union has already approached the European Commission on these issues and will raise them with DG Agriculture’s Director for Economic Analysis, Evaluation and Communication, Mr Tassos Haniotis when they meet with him today (Thursday 19 June) at the Royal Highland Show, near Edinburgh. NFUS is already in discussions with the Scottish Government to identify how positive aspects on simplification can be built into the new rules.
Speaking from the Highland Show, NFU Scotland President Nigel Miller said: “There are genuine fears from grass roots Scottish farmers that the complexities of greening, beef and sheep coupling, the mandatory Young Farmers’ Scheme, the operation of a National Reserve and phased in transition to area-based payments may overwhelm the simplification agenda of the new CAP.
“Scotland has the ability to adopt positive initiatives to help mitigate those fears. Many Scottish farmers already live in dread of breaching existing European rules on land eligibility and have to undertake complex mapping to accurately identify and remove ineligible features such as scree, stands of trees, wetlands, ponds and impenetrable stands of gorse or bracken from their Single Farm Payment applications.
“On visits by EC officials to Scotland, we demonstrated that accurate mapping of all such features is not deliverable over much of Scotland’s rough grazing region (RGR).
“Europe has since given Scotland the option of using a coefficient principle to recognise natural complexity and diversity, to be applied to land parcels where a complex mix of hard and soft features makes accurate mapping impossible. That is a very useful device which provides a cushion of flexibility and should be at the core of our area-based support system.
“The basic coefficient principal outlined by Europe is accepting that RGR parcels which are 90 percent or more eligible land can be claimed in their entirety without complex mapping. The Commission has provided flexibility at MS or Regional level with potential for further tiers of coefficient to be used. That is welcome simplification that Scotland must adopt.
“Helpfully, on enforcement, the European Parliament has also prioritised the introduction of a more proportionate enforcement approach. A key component is the penalty system, where the European Parliament has proposed a move away from the current blunt use of a minimum three percent penalty for breaches which is seen as both disproportionate and inappropriate where genuine undeliberate errors are made.
“The review of the penalty system can change the CAP in Europe into a more positive vehicle that drives best practice but also helps allay many of the justified fears held by Scottish farmers that innocent errors can result in swingeing cuts to support payments.
“Clearly, when intentional breaches and fraud are identified severe penalties should apply. The 2015 review should therefore focus on the inadvertent failures which occur in complex businesses.
“The European Parliament has suggested a reduced penalty or warning letter on a first offence. This is a good starting point. However, to build on that, a new penalty matrix should be developed to differentiate non-compliances and attach appropriate and proportionate penalties to those non-compliances based on the impact.
“In some cases, authorities should introduce support for systems and management development on-farm in a response to breaches to raise standards and future compliance levels. Delivering higher standards on-farm is more positive than compliance being driven by fear and financial penalty.”
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