The NFU has used an evidence session in the Scottish Parliament to lay out the many challenges faced by Scottish Government in delivering a new area-based support scheme to agriculture.
Speaking to the Rural Affairs, Climate Change and Environment Committee, the Unionâs Director of Policy Jonnie Hall said the delivery had to contend with limited financial resources, a very diverse agricultural landscape and large tracts of hill grazing of variable quality and productivity.
The Union welcomed announcements earlier this month that further measures will be adapted in order minimise so-called âslipperâ farming and the potential to use up to 13 percent of the Scottish budget for coupling to production.
Speaking at Holyrood, Mr Hall said: âOur members have given us a clear steer that we want a proper and robust farming activity test that strips out naked or unfarmed acres, and prevents them from draining scarce funding away from Scotlandâs limited direct support (Pillar 1) budget. We look forward to continuing to work with the Scottish Government as these rules get written into implementation plans.
âRealistically we consider that the most practical measure to rule out slipper farming will incorporate a level of stocking to reflect land capability as part of an activity test. We would like a process put in place by the Scottish Government where farmers can demonstrate that the stocking level of the farm is appropriate to the land.
âEvery effort must be made to differentiate the payments within Scotlandâs three million hectares of rough grazing (RGR) - a simple flat rate could decimate more productive hill units, while over-compensating very extensive grazing systems would divert funds away from better hill land.
âScotland must consider a coupled support system for hill farms so that different payment rates are available on the basis of different stocking densities. Targeting in this way in Scotlandâs hills is essential to focus the appropriate levels of support to different farm businesses, and to use Scotlandâs limited funds more efficiently.
âWe have long argued that Scotland should be able to use the UK ceiling to determine how much Scottish money is available for coupled payments. The flexibility granted by the EU Commission to use up to 13 percent of our budget will give the Scottish Government the option to boost coupled support payments if deemed necessary.
âWith 8 percent likely to be preserved for the beef sector, NFU Scotland will continue to discuss with the Scottish Government how best the extra 5 per cent headroom on coupling could be used to solve emerging issues, such as preserving activity in the RGR.
âWhilst we recognise that Scotlandâs environmental reputation requires protection, we maintain that the CAP greening requirements constrain our crucial spring barley production and reduce Scotlandâs cropping potential. The failure of European greening requirements to fit must not prompt Scottish Government to consider any gold plating of implementation standards.
âWhen looking at potential equivalence measures, it is clear there are no quick wins for Scotland but details of those standards are now urgently required by our growers. Rotation and land management requires clear guidelines from Scottish Government to ensure businesses can plan cropping ahead to deliver compliance in 2015.
âNFU Scotland is willing to work with officials to develop greening equivalence options to fit Scotlandâs arable area and climate. The present European Commission posture is not flexible, but energy must be applied to negotiate a solution that provides wins for the environment and safeguards production. Breaking away from rigid three-crop diversity requirements is fundamental for Scottish arable producers.
âOn transition to the new CAP, we believe that the most sensible approach for established businesses would be to use a âtunnelledâ method that would move support rates to within a range of the area payment by 2019. Whilst smoothing the way throughout what will be a turbulent period of adjustment, this approach would allow for the effectiveness of an area-based support system to be assessed and reviewed.
âThis approach would also require an effective and continuous National Reserve to operate in the interests of genuine new entrants and those who take on more land to develop an established business, moving them to an equal footing from day one of new arrangements.â