4 ALLOCATION OF AREA PAYMENTS
4.1 Question 5.4 of the consultation asked, "Is the goal of trying to achieve an objective system for the allocation of area payments using a constant criterion, which is not dependent on management, like the Macaulay Land Capability for Agriculture ( LCA), worthwhile?"
4.2 Of the 98 respondents who answered this question, 18 agreed and 26 disagreed. Just over half of those who answered the question (50 respondents) gave a mixed response (e.g. yes but with a caveat added) and 4 were undecided. There was no clear pattern in responses by sector.
4.3 The most common response in favour of using the LCA, mentioned by 15 respondents, was that this is the fairest or best available system.
4.4 However, 20 respondents (across a range of sectors) argued that land management should be taken into consideration and support must be based on how the land is used.
4.5 Eight respondents, across a range of sectors, arued that while they agreed an objective system for the allocation of area payments is necessary, there are issues or drawbacks of the LCA.
4.6 The most common criticism made of the LCA (made by 29 respondents) was that it is inaccurate, particularly at the field by field level, and will need upgrading or 'tidying up' in order to work as a basis for area payments. Ten respondents also commented that the Macaulay system is out of date and therefore not a true reflection of land capability. These comments were made by a range of respondent types. As one respondent from the Farming sector noted:
"Utilising the existing Macaulay Land Classification system is an obvious option but… we would like to see data on whether [it] can operate at the field level and, if as the case is now it does not, what time and resources would be required in order for this to be done. In addition… we believe that an examination needs to be conducted on whether the classification system is a true reflection of land capability or whether in light of improvements done to the land and changing farm practices the basis for the Macaulay Land Classification now needs to be updated".
4.7 Fourteen respondents queried the use of the LCA because of its focus on the production of agricultural commodities rather than the delivery of public goods or benefits (6 of the 7 respondents from the Environment sector made this point).
4.8 Ten respondents, 4 of whom were from the Environment sector, disagreed that better quality land should receive an increased subsidy, arguing that the most disadvantaged areas should receive support, since those with the most productive land are also likely to receive the highest returns from the market.
4.9 Eleven respondents commented that this system would be complicated to administer, particularly since the LCA classification does not follow existing field boundaries and in many cases single fields will have several different LCA classifications.
4.10 Nine respondents raised specific concerns relating to the example table in the interim report, and 16 suggested alternatives to using the LCA, such as the old Less Favoured Area ( LFA) classification or the existing Integrated Administration and Control System ( IACS) categories of Arable, Temporary Grass, Permanent Grass, and Rough Grazing.
Ninety-eight respondents (66% of the 149 who responded to the consultation) answered Question 5.4. Of these, 18 agreed that using an objective system for the allocation of area payments such as LCA is worthwhile, and 50 gave a mixed response. Twenty-six did not agree.
The most common reason given in support of this suggestion was that the LCA is the fairest or best available system (15).
Among those who did not agree, several key themes emerged:
- Land management should be taken into consideration (20);
- The LCA is inaccurate, especially at the field by field level (29);
- The LCA is out of date (10);
- This system focuses on the production of agricultural commodities rather than the delivery of public goods (14);
- Better quality land should not receive an increased subsidy (10);
- This would be complicated to administer (11);
- Alternatives to using the LCA were suggested, such as the old LFA classification or the existing IACS categories of Arable, Temporary Grass, Permanent Grass, and Rough Grazing (16).
Respondents from the Environment group were the most likely to argue for the need to focus on public goods rather than production, or that the better quality land should not receive greater funding.