14 MINIMUM AND MAXIMUM STOCKING DENSITIES
Minimum stocking densities
14.1 The Inquiry is of the opinion that the only way to ensure that only land which supports some agricultural production is used to claim Single Farm Payment ( SFP) entitlements is to introduce new requirements into Good Agricultural and Environmental Condition ( GAEC). In particular, the Inquiry thinks that for livestock production, a minimum stocking rate of 0.08 LU/ha should be applicable from the 2011 scheme year. In the interests of equality, the Inquiry has also suggested an equivalent measure requiring minimum arable activity.
14.2 Question 6.4a asked "Given the low penalties, certainly in the first year (2011), of breaching these new GAEC requirements and the relatively high costs of implementing the livestock regulation, do you believe that what is proposed is sensible?"
14.3 Sixty-seven respondents provided an answer to this question. In relation to Question 6.4a, 34 of the 67 respondents provided a 'yes' response, 21 provided a 'no' response and 12 provided a mixed response (e.g. they agreed but provided a caveat).
14.4 The only pattern to emerge in relation to respondent sectors was that those from Local Authorities were more likely to agree than disagree with this proposal.
14.5 Points made in support of the proposal included:
- Anything making it more difficult to claim for naked acres is worthwhile (6 respondents);
- There should be a link between payments and agricultural activity and SFP should be limited to land in agricultural use (5 respondents);
- The approach suggested is sensible (3 respondents);
- This should only be done if it is cost effective, or concerns that it might not be a cost effective use of resources (3 respondents).
14.6 Among those who disagreed with the proposal, the following themes emerged (each mentioned by 3 respondents):
- This approach is not justified in the short term and / or the new scheme would not be introduced until 2014 at the earliest;
- The cost of enforcement would outweigh the advantages, or the introduction of a minimum stocking rate would not create significant benefits to justify the additional administrative costs;
- The proposed minimum stocking rate should not be applied across all types of land, since some land benefits from grazing at lower stocking densities.
14.7 A number of respondents suggested changes to the minimum stocking rates, regardless of whether they agreed with the proposed idea or not (7 said it should be lower, one argued it should be higher).
14.8 Question 6.4b asked, "Do you have an alternative suggestion (within EU rules) as to how to exclude barren hillsides from validating entitlements or should it be treated as unimportant?"
14.9 A total of 33 respondents provided comments to Q6.4b, although four of these simply gave an answer of 'no' without any further detail. Very few comments were made by more than one respondent, the only ones being:
- Barren hillsides fall outwith the Common Agricultural Policy ( CAP) and could dilute available resources, or that barren hillsides supporting no agricultural activity should be seen as ineligible for the purposes of SFP entitlement (4 respondents);
- Barren hillsides might not be cultivated or have livestock but they may still have significant environmental or landscape value and are important for non agricultural use (5 respondents).
Introduction of a maximum stocking density
14.10 Question 6.5 asked "To better define GAEC, the Inquiry has also considered introducing a maximum stocking density (2.5 LU/ha). What is your view on this suggestion?"
14.11 Sixty-five respondents provided an answer, with only 9 giving a positive response. Two thirds of those who responded to this question (43 respondents) disagreed with the introduction of a maximum stocking density, while a further 8 provided a mixed response (e.g. they agreed but provided a caveat) and 5 were undecided.
14.12 In terms of sector differences, it is worth noting that all of the respondents from the Farming sector who answered this question said they disagreed.
14.13 The main reason people gave for disagreeing with the introduction of a maximum stocking density was that this is unnecessary. For example:
- There needs to be a range of minimum stocking densities to be more effective and realistic, and that GAEC rules can be used for overgrazing, effectively negating the need for any further action (13 respondents);
- It is difficult to justify this suggestion because under both the current and future schemes, there is no incentive to overstock ground (6 respondents);
- This suggestion is not necessary and overstocking will not be an issue in relation to the future support arrangements that are envisaged (7 respondents).
14.14 Four respondents suggested that an approach via a reformed and adequate cross compliance regime targeted at preventing problems associated with high stocking rates was of greater priority than maximum stocking density. These comments came from respondents in the Environmental group (3 respondents) and the Special Interests sector (1 respondent).
14.15 Three Individuals noted that finishing units might find 2.5 LU/ha too low or that it could prove difficult for finishers who buy in lots of stock to finish over short periods.
Sixty-seven respondents (45% of the 149 who responded to the consultation) answered Question 6.4, with 34 agreeing and 21 disagreeing with a minimum stocking rate of 0.08 LU/ha being applicable from the 2011 scheme year.
Those who agreed argued that anything making it more difficult to claim for naked acres is worthwhile (6) and there should be a link between payments and agricultural activity (5). However, several respondents suggested changes to the stocking rates (7 said it should be lower, one argued it should be higher).
65 respondents (44% of the 149 who responded to the consultation) answered Question 6.5; two thirds of these (43) disagreed with the introduction of a maximum stocking density, arguing that this is not necessary.
Local Authority respondents were more likely to agree than disagree with the introduction of new minimum stocking requirements into GAEC. All of the respondents from the Farming sector who answered the question on maximum stocking rates disagreed with this proposal.