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11 MINIMUM THRESHOLD
11.1 Scotland has chosen not to enforce EU Regulations which required area holdings to exceed 0.3 hectares in order to receive Single Farm Payments. The Commission has now proposed simplification and a reduction of the cost of future payments with new minimum payment thresholds.
11.2 Members States are to apply either the minimum payment amount of €250 or a minimum size of eligible area per holding (at least one hectare). Whilst this remains optional at present, from 2010 Member States would be obliged to apply one or other of these minimum thresholds. Only a small number of Scottish businesses and SFPs will be effected by these threshold introductions.
11.3 The consultation asked "What are your views on proposals for setting a minimum threshold (by level of SFP or area of holding) below which no payments are made?"
11.4 There were 33 replies to this question. Of these, 22 were supportive of the need to set some form of minimum threshold; two farming respondents and an individual were against the idea.
Minimum payment
11.5 Six respondents supported minimum payments being based on a payment level; one agribusiness organisation thought this should be more than €250. A farming organisation felt this method would save more on administration costs than setting a minimum size threshold. A local authority felt that using size would exclude a number of small holdings.
Minimum size
11.6 Seven respondents supported a minimum payment based on size. One environmental stakeholder agreed with the minimum 1ha suggested in the proposal as it would not have a significant effect on Scotland's agricultural industry, though this respondent would like safeguards for those who receive special entitlements. Two others suggested it should not be below 3ha; the LFA threshold for support. A local authority and a wider interest organisation felt this would be the best method to ensure small crofts are included.
Crofters and small businesses
11.7 Eleven respondents stressed that the minimum threshold must be chosen so as not to negatively impact crofters and small producers. One farming organisation said that they did not support minimum thresholds and that there should be a minimum payment for all smallholders, they commented that this is the case under the LFASS.
11.8 An organisation from the special interest group was uneasy about the proposals, they commented that some small units have high environmental or social value and that these could perhaps be supported through Pillar 2 measures. An environment organisation wanted to see the amount of funds a farm receives related to the level of public benefit it delivers.
11.9 Four stakeholders believed it would be desirable to exclude hobby farmers or small claims, or that funding should be concentrated on larger enterprises or professional farmers and crofters. One supply chain/ livestock stakeholder perceived hobby farmers as posing a disproportionate risk in terms of animal health, while one environment stakeholder stated that agricultural activity on small holdings can be significantly environmentally beneficial.
11.10 An organisation from the wider interest group wanted to see SFPs paid only to land which is actively farmed.
Costs
11.11 Three stakeholders indicated that they appreciate proposals to lower administration costs and bureaucracy, while one farming stakeholder perceived cost savings as being minimal because of the costs of establishing eligibility; one environment stakeholder recognised the cost involved in implementing SFPs.
Key themes to emerge in relation to minimum thresholds: - Two-thirds of those responding supported the idea of some form of minimum threshold. - Most of the environment respondents did not specifically support or reject the proposals but wanted to ensure that there is no negative impact on small producers; a third of all those responding had similar concerns. - There were similar numbers in support of a minimum payment level (6) as supported minimum size (7). |
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