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16 CONCLUSIONS
16.1 Across many questions respondents asked that there be adequate notice given and, where appropriate, assistance in planning for businesses in advance of any changes. Respondents also wanted to see clear evidence as a basis for any changes and for funding objectives to be clear and transparent.
Pillar 1 and Pillar 2
16.2 More than half of all respondents wanted to retain some form of Pillar 1 payments, either through the current system or by way of a revised version. Respondents were concerned about the viability of businesses if Pillar 1 support is withdrawn.
16.3 Pillar 2 measures were seen as complex and overly competitive and respondents reported that payments were hard to access, especially for smaller businesses.
16.4 There was agreement that the historic model for calculating SFPs is no longer appropriate but respondents felt that a simple flat rate system would not be suitable because of the variation in land types across Scotland. Respondents felt that payments should be linked to agricultural activity or potential, or subject to cross-compliance measures.
The CAP Health Check
16.5 Most of the CAP Health Check proposals met with support from respondents with the exception of the proposal for progressive modulation.
16.6 Respondents welcomed the proposals aimed at simplifying cross-compliance and the proposed changes to GAEC.
16.7 There was agreement amongst respondents that set-aside is no longer necessary and should be removed. In particular, respondents stressed the need to:
- retain the environmental benefits of set-aside;
- ensure that there is no negative effect on habitat and wildlife.
16.8 There was widespread support for the proposals for further decoupling although some respondents felt that coupled support should be retained at least in some areas, especially for the grazing sector and hill and upland farmers.
16.9 The consultation document introduced a raft of proposals relating to the National Reserve, including help for new entrants to farming, increased flexibility in the use of the national reserve, simplified payment entitlements, transfer of payment entitlements, twice yearly payments and clarifications of the meaning of a farmer and the definition of 'eligible hectare'.
16.10 Respondents supported the proposals on the use of the National Reserve to help new entrants into farming and also agreed the need for new entrants to have access to support. There were, however, a few queries over whether the National Reserve should be used if area-based payments are to be introduced as well as some comments on the need to move away from SFPs or towards area-based payments.
16.11 There was also support for additional flexibility in the use of the National Reserve and for the proposal to make payments twice a year. Some provisos were included in comments, the most common being:
- the need to ensure that support is given only to those actively involved in farming;
- the need for a clear definition of 'active farmer';
- that the definition of an 'eligible hectare' should include some link to active production.
16.12 The consultation included proposals for increased flexibility in the National Envelope and while respondents supported the proposals they also voiced concerns over the SBCS which was seen as ineffective and inflexible. Respondents again commented on the need for support to be targeted at hill and upland areas and especially for cattle and sheep livestock farmers.
16.13 Although respondents agreed with the proposal to increase compulsory modulation, they did not agree with proposals for progressive modulation. These were viewed as potentially discriminating against larger businesses and there were comments that this could result in larger businesses restructuring. Some respondents also felt that progressive modulation might lead to a reduction in SRDP funding.
16.14 There was support for setting some form of minimum threshold, although neither the €250 nor the 1ha minimums suggested attracted majority support. The main comment to emerge with regards these proposals was the need to ensure that any threshold set did not result in a negative impact on small producers.
16.15 The small number of respondents who commented on mechanisms for intervention in commodity markets agreed with the proposals, although there was a small measure of support for intervention options to be retained, at least in some areas.
16.16 There were few comments on the proposals relating to milk quotas; amongst those who did respond there was agreement with the proposals to gradually increase milk quotas with a view to ending them in 2015.
16.17 Again, there were few comments on changes to small schemes. Respondents who commented mostly supported proposed changes to the Protein Crop Premium ( PCP) and Energy Crop Scheme ( ECS) although a small number of respondents had concerns over the proposals for the PCP.
16.18 Across responses and questions there were a number of key themes which recurred.
16.19 Respondents commented frequently on the need for support for hill and upland areas; the risk of land abandonment and the consequent environmental, economic and social impacts were a major concern.
16.20 Respondents wanted proposals to guard against any further decrease in livestock numbers or to reverse the trend in decreasing numbers.
16.21 Respondents identified a need to ensure that existing funds are targeted where they are most needed and also to ensure that payments are targeted where most needed. Continued support for those businesses which would not otherwise be viable was also seen as important.
16.22 Finally in relation to the Health Check, respondents wanted to ensure environmental benefits are retained alongside ensuring production and food security.
Other comments
16.23 When asked whether they had any further comments to make in relation to the CAP, many respondents took the opportunity to reiterate comments already covered at previous questions. The main points which emerged were in relation to:
- the need for fairness and uniformity both within Scotland and across the EU;
- support for hill, upland and remote or fragile areas;
- support for stabilising, or increasing, livestock numbers;
- the review of the Less Favoured Areas Support Scheme ( LFASS) and/ or the Scotland Rural Development Programme ( SRDP) being looked at alongside the Health Check;
- a need for adequate funding to ensure successful implementation of proposals.
16.24 These topics reflect many of the key themes which emerged across questions and from all sectors through the consultation.
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