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5 ABOLITION OF SET-ASIDE

5.1 The draft new regulations allow for set-aside entitlements to become, in effect, standard entitlements on hectares which meet eligibility requirements. With the revision of GAEC some environmental benefits from set-aside land should be retained under Pillar 1; in addition Pillar 2 allows the targeting of environmental benefits where they are needed most and this could cover loss of set-aside.

5.2 The consultation asked "What are your views on the abolition of set-aside and set-aside entitlements? Please explain what measures you think should be taken to maintain the environmental benefits of set-aside."

5.3 Thirty-eight stakeholders commented on this question and 20 organisations specifically voiced agreement that set-aside is no longer necessary and should be removed.

5.4 Five respondents agreed that eligibility should be the same as for standard entitlements but felt that this needs to go further; all set-aside entitlements should become standard entitlements.

Use of Pillar 2 or other funding

5.5 A farming stakeholder commented that Pillar 2 adjustments should be used to continue the gains accrued from set-aside which, they felt would "help and reward land managers for the provision of non-market goods, and will encourage land based initiatives". This respondent felt that Pillar 2 should be used to fund Less Favoured Areas ( LFAs) and the Natura 2000 designated areas. A wider interest organisation agreed the use of Pillar 2 funding; they felt that, although this is not totally equitable, the funds available could be targeted where the need is greatest.

5.6 A stakeholder from the wider interest group suggested that if there are insufficient funds in Axis 2, environmental outputs would need to be reviewed, with priority then given to those that provide most environmental benefit. An agribusiness organisation agreed with the suggested move from Pillar 1 to Pillar 2 funding and commented on the importance of having land under environmental management.

5.7 While one farming organisation stressed the need to ensure sufficient funds to attract land out of agriculture for Axis 2, an environment organisation saw a possibility in using Article 68; retaining a proportion of set-aside entitlements and using funds for alternative environmental measures. They also suggested transferring funds to Pillar 2 to boost the agri-environmental payments under Axis 2.

5.8 Two organisations wanted to see a proportion of compulsory modulation ring-fenced for Pillar 2 environmental measures while an environment organisation wanted to see more funds moved into Pillar 2 in order to support agri-environment schemes.

5.9 A farming stakeholder saw the need to assess total costs in relation to available Pillar 1 funds against the relative importance to public benefit; they also felt costs must reflect the loss of income from agriculture.

Need to retain benefits from set-aside

5.10 There was agreement, across all categories of respondents, of the benefits that set-aside has provided and acknowledgment that these need to be retained.

5.11 Nine respondents suggested that a percentage of land should be managed, some suggested under GAEC, for environmental purposes. One environment organisation suggested this could be achieved under Land Managers' Options ( LMOs) and two farming organisations also suggested enhancing LMOs or Rural Development Contracts as possible mechanisms for payment for farming activity that provides environmental benefit.

5.12 Incorporating measures into GAEC was discussed by one research/ education organisation who concluded that this would not target funds at the areas where the loss of set-aside is felt the most. They also suggested the possibility of managing a proportion of land under GAEC in an environmentally sensitive way. Another alternative was converting set-aside to another form of entitlement with environmental obligations. They advised that more research would be required to decide which scheme would best suit Scotland's needs. A local authority also made similar suggestions.

5.13 An agribusiness organisation also commented on managing land environmentally under GAEC. They felt that this could be done through LMOs with the cap of 10% raised so that more land could be managed for environmental purposes; this would make the prospect more attractive and increase uptake. They suggested that GAEC be extended to all land, not just agricultural. In addition they wanted to see environmental support measures strengthened and increased remuneration in line with rising costs.

5.14 A special interest organisation thought the proposals would not be sufficient to offset the loss of set-aside. They wanted to see a requirement in GAEC not to cultivate field margins but to manage these for environmental purposes. An individual suggested the establishment of an Environmental Priority Areas scheme to replace set-aside.

5.15 The possibility of provisions within the SRDP to allow payment to offset any income lost due to buffer strips was raised by a wider interest organisation. This idea was supported by a supply chain/ livestock organisation and two local authorities; one of whom stressed the need for careful monitoring of the uptake of SRDP measures and for SRDP to be adequately funded.

5.16 One environment stakeholder stressed the need to monitor any set-aside replacement measures; another commented that loss of set-aside without any mitigating measures will compromise the target of achieving good ecological status of water by 2015.

Land in productive use

5.17 While two environment organisations welcomed the use of buffer strips, one farming stakeholder disagreed with changes to GAEC in this regard as, they felt, some planting does have environmental benefit.

5.18 An environment stakeholder also agreed that land in productive use can produce environmental benefits and pointed out that in England a percentage of land is left as over-winter stubble. They suggested that the type of environmental management used could be based on the farm location, for example land close to water could be managed for the benefit of wading birds, but acknowledged that agri-environmental measures could be expensive due to current high cereal prices. This respondent also mentioned the possible use of targets, especially in areas where loss of habitat is critical, they felt this could be funded through a National Envelope.

Implications for habitat and wildlife

5.19 There were concerns over negative implications for farming wildlife especially if changes occur alongside the ending of a number of existing agri-environment schemes. A farming organisation wanted to see Rural Priorities LMOs developed; this could include fallow land, sown pollen and nectar mixtures with the LMO option for winter stubble available under Rural Priorities. They wanted to see a degree of cross-compliance under GAEC to help mitigate the loss of set-aside; this was also suggested by another two organisations. However, a special interest organisation felt that under cross-compliance, SRDP wouldn't make a significant difference; they saw the need for long term commitment in relation to buffer strips.

5.20 Although a local authority felt that the loss of set-aside would not have an effect on agriculture in their own area they commented that it would "negatively impact habitats for particular species".

5.21 Two environment stakeholders voiced concern over the effect any loss of set-aside will have on the Corn Bunting; one also voiced concern over the future of the Twite. This respondent, while supporting proposals for buffer strips and landscape features, felt that the loss of management regimes associated with set-aside could have serious consequences for farmland birds.

Other issues

5.22 The need to encourage management of boundaries to allow public access to farmland was commented on by three organisations.

5.23 An environment stakeholder suggested:

• the need to clarify management requirements for field margins and suggested that these should be set at 2m from field boundaries and watercourses;
• the extension of protection of boundaries to include Tree Preservation Orders as in England, Northern Ireland and Wales.

5.24 A special interest organisation welcomed the proposals but asked for a new definition of landscape to include dry-stone walls, earthen banks and features of archaeological or historic interest. They suggested it would be useful to have online mapping of these features made available for land managers.

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