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15 GENERAL COMMENTS

15.1 Finally respondents were asked "Do you have any other general comments or views?"

15.2 Twenty nine of the respondents made comments at this question; three also attached policy documents or annexes.

15.3 Five respondents referred to the issue of fairness and equitability in farming issues. Mentions were made of the following:

• area-based payment of SFP and strong level of support would ensure all with a genuine aim of having a successful Scottish agricultural industry would be fairly treated (individual);
• the need for a fair and equitable agricultural future integrated with other rural land use and where the public benefit is the primary objective (special interest organisation);
• a supermarket ombudsman must be put in place ASAP to ensure fair returns for farmers (wider interest organisation).

15.4 In connection with this, two supply chain/ livestock stakeholders pointed out problems caused by the non uniformity of policy implementation across EU states; one stated that not all EU states adopted fully decoupled CAP in 2005 and the other said that the non uniformity had the potential to disadvantage Scottish livestock producers, albeit with reduced capacity for this under the Health Check proposals.

15.5 Four respondents said that support was particularly needed in remote, upland or fragile areas to maintain farming and rural activity viability, and six intimated that support/ funding should be more specifically targeted or area-based. Particular areas of concern stated were:

• the need for more developed regional priorities within the Pillar 2 SRDP Rural Development Contract, linked to the establishment of regional budgets so that regional priorities can be targeted. This is particularly important for measures supporting the environment and rural economic and community development (local authority);
• Pillar 1 support should be better targeted at farm business development and increased business viability. There is an opportunity to use SFPs and SRDP support to achieve this (local authority);
• crofters need improved support for the remainder of the transition period to a market economy. Measures intended to support the suckler cow herd are inadequate. There is a need to redistribute aid based fairly on a land based payment in the order of the £70 per hectare in order to reverse the decline in agricultural activity (local authority);
• a need to support land management in remote/ upland areas to help businesses survive and preserve high quality environments dependent on certain types of land management. A scheme that delivers higher levels of targeted support to upland and remote land management units would be supported (environment organisation).

15.6 Two respondents emphasised the importance of encouraging or supporting indigenous livestock production and processing, with three pointing out that stock/ ewe/ cow numbers have been declining post decoupling with the potential for resulting problems. For instance a supply chain/ livestock stakeholder commented that there is a need to avoid the forecast of 3% herd reduction by 2009 by sensitive adjustment of the CAP.

15.7 Four respondents urged the Scottish or UK Governments to take a positive role and an environment stakeholder suggested extra government funding would be helpful.

15.8 Seven respondents pinpointed areas which they viewed as being very important to include as part of the CAP or the CAP Health Check, or to take account of other schemes alongside the proposals within the Health Check. In particular four respondents said the Health Check should be seen in conjunction with the LFASS, and four in conjunction with the SRDP. Other specific areas that could be considered as part of the Health Check included the following:

• working towards a two Tier system (farming stakeholder);
• CAP addressing failures of the current support regime to guarantee food security and production (farming organisation);
• market prices failing to provide sufficient return for farm business profitability (farming organisation);
• more recognition given towards mixed rural businesses and the need to favour them above a level playing field (agribusiness organisation);
• the animal welfare payment scheme to farmers making contributions to animal welfare standards over and above mandatory standards (supply chain/ livestock organisation).

15.9 Five respondents were concerned about the provision of adequate funding or additional funding to implement successful delivery of Health Check priorities, specifying the following issues in particular:

• disappointment that there is unlikely to be additional money available for tackling climate change, renewable energy, etc. (environment stakeholder);
• deferral of support paid to deer farmers until the introduction of flat-rate payments being unfair on those deer farmers currently receiving support at less than the parish average (supply chain/ livestock stakeholder);
• ensuring better use of a shrinking budget (wider interest organisation);
• existing instruments under both CAP Pillars not being adequate to respond to the challenges (environment organisation).

15.10 Four respondents talked about the possibility of modulating funds, or transferring funds from Pillar 1 to Pillar 2, or more use of Pillar 2 funds, in two cases stating specifically:

• to allow access to rural development funding (environment stakeholder);
• to encourage livestock systems which deliver high levels of animal welfare as well as environmental goods and rural development objectives (supply chain/ livestock organisation).

15.11 One environment organisation, however, suggested that in the longer term Pillar 2 should be swept away and replaced with an integrated European sustainable land management policy.

15.12 Two environment stakeholders raised cross-compliance issues commenting on:

• ensuring proper implementation of cross-compliance;
• a more detailed review or evaluation of cross-compliance is required in Scotland to take account of policy changes since cross-compliance was introduced in 2005;
• integrating Agricultural Environmental Impact Assessments as part of SFP cross-compliance;
• penalties for breaches of cross-compliance to include restoration where environmental damage has been caused.

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