5 ANNUAL CHANGES AND QUALIFYING REQUIREMENTS
Annual changes to eligible areas
5.1 Question 5.5 of the consultation asked, "The Inquiry suggests that it is essential that the area eligible for direct payments changes annually to ensure it reflects the reality and is not an historic base. Do you agree with this concept? For your information it could have implications for administration costs and, possibly, the date by which the full direct payment is made".
5.2 Seventy-four people responded to this question, with 47 of these agreeing. A further 15 gave a positive response but added caveats or queries, while 8 said they did not agree with this suggestion and 4 were undecided. There were no clear patterns in responses by sector.
5.3 The most common response to this question (given by 29 respondents, covering a range of respondent types) was a generally supportive comment relating to the need to move away from the historic base and update the system regularly so that payments are linked to activity.
5.4 Fourteen respondents argued that there is no reason why this approach would be more complicated to administer, since existing mechanisms such as the annual return of Integrated Administration and Control System ( IACS) forms could be utilised. Four respondents (3 of whom were from the Environment sector) also commented that any short term costs or delays would be outweighed by the longer term benefits.
5.5 However, 7 respondents noted that while they agreed with this suggestion in principle, they had concerns about the potential impact on administration costs and delays to payments.
5.6 Nine respondents suggested that a 3-5 year review period would be more sensible in order to reduce the administration burden.
5.7 Three of the 4 respondents who were undecided argued that they could not give a definitive answer at this stage because of various unanswered questions about how the scheme would actually operate.
Annual qualifying requirements
5.8 Question 5.6 of the consultation asked, "What are your views on the 'annual qualifying requirements' for future area based payments set out in the interim report? Are they sufficient to capture 'active' farming?"
5.9 Eighty-one the 149 respondents provided an answer to this question: 8 said yes (7 of whom were Individuals) and 23 provided a mixed response, i.e. they agreed but added caveats. Thirty-two respondents disagreed, while 18 did not provide a definitive answer (e.g. they were undecided, or they did not provide a comment because they did not support area based payments).
5.10 Respondents from the Farming sector, Livestock / Supply Chain group and Local Authorities were more likely to disagree with this question than agree or provide a mixed response.
5.11 The key themes emerging from responses to this question were fairly similar, regardless of whether respondents agreed with the annual qualifying requirements outlined in the report.
5.12 There was strong agreement that having annual qualifying requirements is important in order to promote active farming: 17 respondents reiterated their general support for this element of an area payment scheme, and / or emphasised the need to have stringent qualifying requirements in order to promote active farming only. Although this view was prevalent across a range of respondent groups, it is notable that 6 of the 7 Local Authorities made this point.
5.13 However, a common response was that the proposed requirements do not reflect adequate levels of activity or reflect 'active' farming: 17 of the respondents who disagreed with this question (including 5 from the Farming sector) requested changes to the suggested thresholds, arguing that the minimum stocking rate was too low.
5.14 Eleven other respondents also suggested that some changes might be appropriate, although most of these suggested lowering the minimum stocking rate rather than increasing it (arguing, for example, that sustainable stocking rates vary by type of land or geographical area).
5.15 Other themes included:
- Concerns relating to inactive farmers 'getting round' the legislation (raised by 5 respondents);
- Specific queries raised about the issues for arable farming (6 respondents);
- Concerns that this would be difficult to manage or complicated to administer (3 respondents).
Seventy-four respondents (50% of the 149 who responded to the consultation) answered Question 5.5, with 47 of these agreeing that the area eligible for direct payments changes annually. A further 15 gave a positive response but added caveats or queries, while 8 said they did not agree.
Key themes to emerge were:
- The need to move away from the historic base and update the system regularly so that payments are linked to activity (29);
- There were relatively few concerns about the impact on administration costs and delays to payments (14 respondents said there is no reason why this should be complicated to administer, while 7 raised concerns about this);
- Suggestions for a 3-5 year review period rather than an annual change (9).
Eighty-one respondents (54% of the 149 who responded to the consultation) answered Question 5.6, with 8 agreeing that the annual qualifying requirements for future area based payments are sufficient to capture active farming and 23 providing a mixed response. A further 32 respondents disagreed.
There was strong agreement that having annual qualifying requirements is important in order to promote active farming (17). However, there were mixed views about the requirements set out in the interim report. Seventeen respondents argued that stocking rates should be higher to reflect 'active' farming, although others argued the minimum stocking rate should be lowered to reflect sustainable stocking rates on different types of land.
Concerns relating to inactive farmers 'getting round' the legislation (5) and specific queries about the issues for arable farming (6) were also raised.
Respondents from the Farming sector, Livestock / Supply Chain group and Local Authorities were more likely to disagree with the annual qualifying requirements than agree or provide a mixed response.