Greening, beef and sheep coupling, the mandatory Young Farmers’ Scheme, the operation of a National Reserve and phased-in transition to area-based payments were all highlighted as issues of concern in the new CAP by NFU Scotland president Nigel Miller.
However, he said that Scotlandcould adopt positive initiatives to help mitigate these 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.”
He said that EU officials had been convinced of the difficulty in mapping these features in Scotland’s rough grazing areas on a recent visit to Scotland:
“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,” he added. “That is a very useful device which provides flexibility and should be at the core of our area-based support system.
He said that the use of the co-efficient would allow rough grazing parcels with consisted of 90 per cent or more eligible land to be claimed in their entirety without the need for further complex mapping – a welcome simplification which Mr Miller said Scotland should adopt.
He also said that there was a chance of some movement on a more proportional approach to the penalty system which could currently see producers hit hard for simple errors or omissions.
He said that the European Parliament had proposed a move away from the current blunt use of a minimum 3 per cent penalty for breaches which was seen as both disproportionate and inappropriate where genuine undeliberate errors are made.
“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,” said Mr Miller. He added that providing an advisory element to inspections would also be a route to reaching desired policy outcomes without necessarily incurring penalties during every farm inspection.
It was also proposed that the policymakers and the auditors got together to agree on how schemes should be implemented, rather than the current situation where they looked at it independently.
On a visit to the show, European Commission director Tassos Hanioti said that an EU working group was looking at simplifying some of the more complex policies.