Up UNTIL now, most of the discussions on the next Common Agricultural Policy (CAP) have centred on what these policies will be, but yesterday the man currently conducting a review into the amount of bureaucracy in the farming industry weighed in with some hefty considerations on how any new policies are introduced and how they should be regulated.
In an open letter to the Scottish Government’s rural affairs cabinet secretary, Richard Lochhead, Brian Pack suggested that the development of the detailed implementing rules of the next CAP by the EU must be subject to impact assessments.
These assessments would then have to be properly scrutinised by the European Council and Parliament as well as having been subject to “stakeholder consultation”.
Pack – who had, prior to his “red tape review” work on behalf of the Scottish Government, carried out another review into how best the next CAP should be shaped to support Scottish agriculture – also said the timescale of introducing the next CAP would be vitally important.
“Member states and regions must have realistic timescales for transposition and implementation,” he said, adding it had to allow for full stakeholder consultation on the proposed legislation including consideration of the impact assessments.
He suggests that “at least a year” would be required for the efficient implementation of a radically reformed CAP once the articles are published.
Another critical point for Pack is the amount of regulation the new CAP could bring with it. He quoted an EU document that points to small and medium-sized businesses playing a vital role in getting Europe back on the path to sustainable growth. Failure to achieve this aim should result in the implementing European Institutions being held to account, he claims.
To emphasise the need for good regulation and to avoid mistakes that have highlighted previous CAP reforms, Pack suggests all EU legislation should be subject to review after a suitable period in operation.
With a number of Scottish producers still smarting over penalties imposed under the current CAP, Pack suggested there should be no question of producer penalties or member state disallowances in the early years of implementation to allow for both regulators and producers to fully understand the EU requirements.
He said that he wants the whole culture of audit to be changed from a “penal environment to a positive, helpful one”, where achieving compliance is the objective, not raising penalties.
There should also be an end to unannounced on-farm inspections unless there is evidence of malpractice. This would form part of a deal where Scottish farmers worked positively to achieve the outcomes desired by Europe.
Lochhead yesterday endorsed Pack’s views and sent them on to the UK farm minister, Owen Paterson.