Scottish Land & Estates has provided its views to the Scottish Government on the three consultations currently open on the draft CAP regulations.
With regard to direct payments, Scottish Land & Estates:
- supports a regionalised approach to direct payments
- supports minimum activity requirements to be eligible for support
- supports greening in principle, but has major concerns over the specific measures on the table
- supports the use of the National Reserve, but argues that it should be sufficiently widely drawn so as to catch all those excluded from direct support
- supports the use of coupled support
- supports the principle of having the option to transfer funds from Pillar 1 to 2, but would prefer not to have to utilise the option; we need a better Pillar 2 allocation to begin with.
- disagrees with the proposed definition of ‘active farmer’ opposes capping disagrees with the proposed ‘double gate’ principle that only those that claimed at least one entitlement in 2011 will be eligible for support in 2014
- disagrees with the proposal that initially at least 40% of direct payments will be area-based with 60% being historic; the phasing should be more gradual.
With regard to rural development, Scottish Land & Estates welcomes the fact that the draft regulations effectively provide Scotland with the tools to continue to support the same sorts of activity as it does now, but has highlighted the potential impact of the removal of income foregone in relation to forestry and farmland premium, which could have a significant impact on meeting Scotland’s woodland expansion targets. Scottish Land & Estates also highlighted that, with partner organisations and Scottish Government support, it is leading the development of the Wildlife Estates Scotland (WES) initiative and would like to see some form of support included in the next SRDP that would encourage engagement with the WES process with its focus on key agri-environment and biodiversity standards.
With regard to finance and controls, Scottish Land & Estates supports the possibility of making support payments in two instalments, an expanded advisory system and a holistic approach to inspections, but disagreed that the Water Framework and Pesticides Directives should be included in cross compliance on the basis that we should be developing a more collaborative approach, rather than a regulation-focused policing approach.
Andrew Midgley, Senior Policy Officer, said: “There is still a very long way to go in these negotiations with major decisions on the budget required before we can make much headway. Greening is a key issue. While Scottish Land & Estates supports the move to green the CAP, we need to make sure that the specific greening measures are appropriate and practical. The other critical issue, that we in Scotland will be able to decide, relates to the regionalisation of area payments and what that means for the redistribution of support. Scottish land & Estates is fully involved in the process of helping the Scottish Government make decisions about the structure of support going forward and will continue to play a constructive role”.