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Scotgov Plans on Greening Still Short on Fine Detail

The fine detail on Scottish Government’s implementation plans for the new CAP regime has met with a mixed response from NFU Scotland however the coupled support push for beef and hill sheep is welcomed.

The details, submitted to the EU today (1 August) map out the voluntary coupled support schemes that will apply to specialist beef producers and sheep producers in the most fragile hill and island areas. That fits with one of the policy priorities pursued by the Union during recent CAP reform negotiations and is welcomed.

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However, detail provided on the planned Ecological Focus Area (EFA) requirements – a key element for farmers to meet if they are to qualify for the greening element of support payments – does not answer the burning questions that Scottish arable farmers currently have.

Just under one-third (30 percent) of Scotland’s direct support (Pillar 1) budget will be allocated to the greening payment and, to receive it, farmers will need to undertake standard greening practices where relevant or not exempt.

Last week, Scottish Government confirmed that standard greening requirements around crop diversification – the controversial three-crop rule – would apply for 2015 with the intention of introducing equivalence measures for 2016. However, farmers are also required to meet rules around EFAs and here frustration is growing and further clarity is needed.

NFU Scotland President Nigel Miller said:
“Submitting Scotland’s plans is a major milestone in the CAP process and we are starting to solidify Scotland’s CAP system for 2015 and beyond. This headline announcement doesn’t carry many major surprises and with Scotland locked into the core EU greening requirements, there was never a lot of space for a tailored package specifically for Scotland.

“With harvest underway, Scotland’s growers need to make decisions now and it is here that much more detail is sought. We had hoped such detail would have been available today. It is essential that it will be in the guidance that Scottish Government is intending to send to producers shortly.

“The fact that Nitrogen fixing crops have come through as an option may be an important EFA solution on many farms and the promised buffer strips and field margins open up some significant flexibility to draw in hedges and ditches and other landscape features under those prescriptions.

“These two boundary features carry a weighting of 1.5, which emphasises their value – not just as a biodiversity reservoir but underlines the vital role they play in connecting habitats across farmland.

“Unfortunately, the use of conversion factors, which have been put forward by Europe to ease the implementation and audit of EFA features such as buffer strips and field margins have not been adopted in Scotland. Defra will utilise these when working with growers south of the Border and Scottish growers would have benefitted from that approach. That will put extra compliance pressure onto Scottish producers and may mean more Scottish productive land is ruled out of production to meet EFA requirements.

“Any unnecessary costs and complexities associated with Scotland’s EFA requirements are an unwelcome burden. We recognise that the Scottish Government will be proactive in the European EFA review process and are looking for and seeking modifications which avoid these unnecessary tripwires to compliance. Using conversion factors in 2015 would have produced more immediate benefits on compliance.

“Detail also remains on outstanding changes to cross-compliance rules. Requirements surrounding uncultivated margins along hedges and dykes have not been confirmed by Scottish Government. Together with the lingering uncertainties on EFA, growers across Scotland will be second guessing and that can only result in greater compliance risk.

“There are other critical details which are yet to emerge around the greening requirements. Any additional environmental management requirements to be attached by Scottish Government to the growing of Nitrogen fixing crops as part of EFA requirements must be made available as quickly as possible if this is to be a viable option for growers. We note that Defra is not imposing any management restrictions on growers who choose to use this option south of the Border.

“The European Commission has signalled that if the fallow option is used as part of the EFA, the new crop year could click in from the middle of July – it is important that Scottish Government quickly confirms the dates to be attached to fallow land and avoids gold-plating.

“In contrast, confirmation that coupling options for our livestock sector are moving forward, with the support of Scottish Government and Defra, is welcome news and creates some confidence in the hills and islands that coupled support for beef calves and hill ewe hoggs will be part of the 2015 support package. That is a positive development and will help underpin activity across much of Scotland.”


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