European Commission CAP Reform Proposals Consultation Report

Transcription

1 European Commission CAP Reform Proposals Consultation Report

2 Contents Page 1 Page 2 Page 3-4 Page 4 Page 5 Page 6-7 Page 7-13 Page Page Page Page Page 19 Page 20 Title Page Contents 1 - Acknowledgements 2 - Executive Summary 3 - Introduction 4 - General analysis of responses 4.1 Direct Payments Main Findings Direct payments - Analysis of the questions inviting comments 4.3 Rural Development Main Findings Rural Development - Analysis of the questions inviting comments 4.5 Horizontal Regulation Main Findings Finance and Control - Analysis of the questions inviting comments 5 Conclusion 6 Feedback 2

3 1 - Acknowledgements There was a good response to the Scottish Government s consultation on the European Commission s CAP reform proposals for The number of responses was higher than for previous Scottish Government consultations on the CAP. Responses reflected the nature and breadth of the varied interests within Scottish land use management. They reflected the views of individuals and organisations concerned with farming, the environment, renewable energy, rural communities and the fabric of life associated with land use in Scotland. The Scottish Government would like to thank all those individuals and organisations who took the time to respond to the consultation. The Scottish Government would also like to thank its rural research division (RESAS) for its advice on this consultation. 2 - Executive Summary - Responses to each of the 3 main EC CAP Reform proposals, that is the Direct Payments, the Rural Development and the Finance and Control (Horizontal) Regulations, tended to support Scottish Government policy and its negotiating position on CAP reform. Many comments also confirmed the Scottish Government s understanding about where stakeholders stood on certain issues. There were a number of recurring themes, for example: Direct Payments concern about maintaining food production while, at the same time, supporting sustainable production and ensuring a quick transition to nonhistoric criteria for payment; the importance of Less Favoured Areas within Scotland; the need to consider variation in land quality in future payments; environmental and biodiversity concerns reflect the need to consider a land use strategy in Scotland which takes account of both market and non-market outcomes; whilst there was reaction against using Pillar 1 funds for greening there was also a degree of support for the greening concept from a wide range of interests; support should focus more on the outcome of activities, not on the activities themselves; support for new entrants to farming is important and should not be restricted by an arbitrary age limit; and access to entitlements is complicated and needs to be considered carefully to ensure good access. Rural Development Needs to be inclusive and the focus widened beyond just purely agriculture orientated activities, to encompass other aspects of the rural environment. Emphasis should be on local initiative, locally set priorities, strengthening rural development and sustainability in all its aspects. Member State should be able to decide options based on national priorities. 3

4 Finance and Control Need to maintain ability to receive payments in Euros. Broad support for expanding online systems. Calls for more proportionate cross compliance penalties either by greater use of warning letters for minor offences or stricter sanctions for breaches which cause environmental damage. 3 - Introduction On 12 October 2011, the European Commission published its draft proposals for the future Common Agricultural Policy (CAP) for the period The consultation sought views on the Commission s proposals. There will be further stakeholder engagement and a further consultation on how the new CAP should be implemented in Scotland, after the main regulations have been agreed and when the detailed implementing rules are known. The CAP provides the main forms of support to land-based sectors across Europe. It has undergone a number of changes over the years, most recently in the Health Check (mid term review) in These latest proposals from the Commission set out a completely new framework for Pillar 1 Direct Payments which will see major differences in the way this support is allocated in future. The draft regulations also propose revisions to the various market measures and make changes to the Pillar 2 Rural Development Regulation which provides the basis for the Scotland Rural Development Programme (SRDP). Previous Scottish Government consultations on the CAP Health Check and for the Brian Pack Inquiry have provided us with a good understanding of the main positions held by stakeholders. This time, the Scottish Government decided to use Questback to structure the consultation. Questback is an on-line survey-type questionnaire and is rather different to the usual written consultations the Scottish Government has used in the past. It uses tick box responses together with a number of boxes for additional comments. Using Questback helped the Scottish Government monitor views throughout the 12 week consultation period thereby informing its negotiating position in early discussions in Europe. The consultation was divided into three separate consultations because of the scale of the CAP reform proposals. This division was aimed at making the consultation more manageable and acknowledged that not all stakeholders would have an interest in all three proposals. The three consultations were: Consultation 1: Direct Payments which at present in Scotland consist of the Single Farm Payment (SFP) and Scottish Beef Scheme (SBS): Consultation 2: Rural Development which provides the basis for the Scotland Rural Development Programme (SRDP) including the Less Favoured Area Support Scheme (LFASS) Consultation 3: Finance & Control (Horizontal) issues common to both Direct Payments and Rural Development: 4

5 4 - General analysis of Responses Each of the three consultations contained a series of questions on specific aspects of the Commission s proposals. In addition, comment boxes followed some questions where a more in-depth view was needed. The number of responses received for each of the 3 regulations covered by the consultation was: o Direct Payments 212 responses (198 electronic + 14 hard copy), of which 79.3% were from individuals and 20.7% were from organisations. o Rural Development 79 responses (71 electronic + 8 hard copy), of which 50.7% were from individuals and 49.3% were from organisations. o Finance and Control 67 responses (58 electronic + 9 hard copy), of which 55.2% were from individuals and 44.8% were from organisations. The issues raised in the hard copy responses were considered alongside the comments given in Questback. The majority of those who responded using Questback responded to all of the tick box questions. Not all respondents added comments in the comment boxes. The responses have been analysed as follows: 1) the results from the tick box questions on specific aspects of the reforms have been assessed and the main findings are given below; 2) the additional views that were provided in the comment boxes have also been assessed. The following 3 sections cover the analysis of the responses to the consultations on the Direct Payments (4.1 & 4.2); Rural Development (4.3 & 4.4); and Finance and Control (4.5 & 4.6) regulations. Each of these sections shows main points arising from the analysis of the tick box answers (sections 4.1, 4.3 and 4.5) followed by a summary of the additional comments (sections 4.2, 4.4 and 4.6). The analysis of tick box questions shown below makes no distinction between organisational responses and individual responses. The tick box answers were initially analysed by grouping the number of responses as shown below: Strongly Agree + Agree responses = Agree Strongly disagree + Disagree responses = Disagree Neither agree/disagree + don t know responses = Neutral The relative strengths of the answers were then compared. Questions were classed as having the strongest agreement where they had more than 66% strongly agree and agree types of responses and in addition, where the number of strongly agree responses was greater than the number of responses that agreed with the question. A similar exercise was performed to identify the questions which elicited strongest disagreement. 5

6 4.1 Direct Payments Main Findings There were 212 responses on the Direct Payments Regulation. Of those that responded using Questback, 150 said their main interest was farming, 30 had environmental interests with the remainder having either food, forestry, other business or community group interests. Strong agreement (More than 66.6% of responses agreeing with question): Minimum activity required for payment = 89% Scottish National Reserve (NR) = 80% Option of Voluntary Coupled Support (VCS) = 80% Option of Areas with Natural Constraint (ANC) = 76% Scottish regional rates = 76% Option of Young Farmers (YF) scheme = 76% Use NR to help YF = 68% The strongest agreement (More than 66% agreeing with question and where number of strongly agree responses was greater than agree responses): Minimum activity for payment = 89% (58 strongly + 31% agree) Option of VCS = 80% (43% strongly + 37% agree) Scottish regional rates = 76% (45% strongly + 31% agree) Agreement (50 66% of responses agreeing with the question) Option of Small Farmer (SF) scheme = 64% Active farmer (5% income + min activity) = 64% Use of NR to stop land abandonment = 59% Progressive capping = 57% Internal convergence = 53% Strongest disagreement (more than 66.6% of responses disagreeing with the question) 3 crop diversification requirement (73% responses disagree) Disagree (50 66% of responses disagreeing with the question) 30% funding for greening = 61% disagree Maintain permanent grassland = 58% disagree 7% Environmental Focus Areas (EFA) requirement = 56% disagree 5000 derogation from min activity = 56% disagree Questions eliciting highest number of neutral answers VCS limited to 5% = 34% of responses were neutral Pillar 1 (P1) to Pillar 2 (P2) flexibility = 24% of responses were neutral P2 to P1 reverse flexibility = 24% of responses were neutral 6

7 NR used to stop land abandonment = 22% of responses were neutral Simplified procedures for SF = 20% of responses were neutral Note: there may be several reasons why neutral types of answers have been elicited. For example, a respondent may not understand the precise detail of a particular issue or they may have felt that a particular proposal from the Commission either went to far or did not go far enough. Some observations 1) Greening 33% of responses agree with the Commission s proposal that 30% funding goes towards Greening the CAP and a similar percentage agrees with 7% EFA.; 28% of responses agreed with requirement to maintain permanent pasture; 14% of responses agreed with 3 crop diversification requirement. This suggests that there was support for the principle of Greening but concern over how the Commission was proposing to put the idea into practice. Some observations 2) Capping 57% of responses agree with the idea for progressive capping of direct payments with 33% of responses disagreeing and 11% of responses being neutral. A slightly lower percentage (47%) of responses agreed that direct payments should be capped at 300k (excluding greening payment and salaries), with 38% disagreeing and 15% of responses being neutral. Some observations 3) Internal convergence flattening of payments 53% of responses agree with proposal to average payments within a region by 2019, 29% disagreed and 18% were neutral. It is difficult to draw too many conclusions from these observations, however, due to the nature of the questions. For example, those disagreeing with 30% funding for Greening or that direct payments should be capped at 300,000 might agree in principle but think these figures are either too high or too low Direct payments - Analysis of the questions inviting comments The 5 opportunities to provide additional comments under Direct Payments. The following section shows a summary of these additional comments. Comments were not always confined to the question in hand. Q3. What might be a suitable definition for minimum activity in Scotland? The question attracted comments from 143 respondents. The most frequent responses referred to stocking density or minimum cropping levels; meeting GAEC requirements; a focus on outcomes rather than activity, area-based as opposed to 7

8 historic payments; entitlements and new entrants; capping; land quality; public goods and greening; income from farming activity. Stocking density and minimum cropping - the main points made were: Should be a minimum stocking rate/cropping level (there were different ideas about what this rate/level should be); Stocking/cropping rates should reflect land quality/capability possibly needs to be defined at regional level not Scotland level; Should include compliance with animal welfare and farm assurance; Should be minimum numbers of livestock on the farm. Meeting GAEC requirements - the main points made were: GAEC should include very extensive grazing systems; Minimum activity definition should include agri-environment participants; Need recognition of non market benefits. Focus on outcomes rather than activity - the main point made was: Minimum activity can only be defined in terms of outcomes. Area based payments as opposed to Historic payments - the main points made were: Timing Quick transition to area based payments; A small minority favoured a lengthy transition. Historic The majority favoured a move to area based payments; Small minority opposed such a move. Entitlements and New Entrants - the main points made were: Link between entitlements and new entrants (NE) recognised with a need to safeguard the position of new entrants; Need to identify appropriate activation date; Age limit for new entrants was contentious; Entitlements should not be traded. Capping - the main points made were: The capping level should be lower; A capping level is required. Land Quality - the main points made were: Payment should reflect land quality/regional variation; Definition of a region was critical - avoid averaging ; Need to consider market and non market factors. Public Goods and Greening - the main points made were: All farmers must comply with greening; Need to focus on rewarding environmental services arising from land management where the market fails to do so; Payments should be based on delivery of public goods; 8

9 Providing economic benefit to the community. Active farmer tests and percentage income from farming activity - the main points made were: A definition based on a minimum percentage income from farming (e.g. 50% and 60% was suggested); Should be based on farm accounts. Other points made by respondents included Tenant/landlord relationships; Move from universal income support to targeted payments; Link payments to food production; Minimum farm size. Q12 Do you have any further comments to make on Section 1: Basic Payments? The question attracted comments from 123 respondents. The most frequent responses referred to the 2011 eligibility rule; historic versus area based payments; transition to area based payments; activity and capping eligibility rule the main points were: Large number of comments many linked to new entrant issue; Evidence of farming activity should be enough to qualify for entitlements; Discriminates against active farmers who had no entitlements in 2011; Discriminates against new entrants; Entitlements should not be just for young farmers - should be no age discrimination; Some support for double gate principle but based on proof of activity not necessarily activation of entitlements. Transition to area based payments the main points made were: Majority of comments fell into two camps of roughly equal numbers i.e. o those calling for move to 100% area basis on day 1, and; o those who thought there should be a transition period but that this should be faster than that proposed. A minority said historic element of Basic Payment should be higher than 60% at start of scheme and that transition period should be longer than that proposed. Historic versus area based payments the main points were: Most supported a move away from the historic basis for payments to area based payments e.g. o Historic payments are no guarantee of future activity; o Historic payments are a barrier to entry and should be phased out sooner rather than later. A minority supported retaining historic payments. 9

10 Activity the main points were: All active farmers should be entitled to payments; Slipper farmers shouldn t get payments; A few said there should be no automatic derogation for those receiving < 5,000 e.g. all farmers should be subject to the same requirements. Many were opposed to the 5% income test e.g. o Expressing concern about the impact on farms that had diversified; o Saying it would discriminate against new entrants who have to borrow or generate external income to get established; o Active farmer definition should be about activity not income. Capping the main points were: Lot of support for capping in principle although not necessarily the detail; Quite a lot of those who supported capping said the capping maximum should be lower e.g. 100,000 or 50,000; Some said capping should start at a lower level; Quite a few said they preferred compulsory modulation with a shift of funds to P2 to capping; A minority were opposed to capping; Capped funds should go to the National Reserve. Other points made by respondents included: Quite a few were in favour of regionalisation in principle (very few who commented were against); Some supported a shift in support towards the poorer quality land (best land shouldn t need as much support); No trading of entitlements entitlements should transfer with land or go to fund National Reserve; Some support for VCS. Q20. Are there any other criteria you think should be included under greening? Overall, there were 94 responses to this question. As well as more general responses about greening, the most frequent responses referred to ecological focus areas (EFA); 3ha threshold; permanent pasture and carbon emissions. Greening - the main points made were: More of those who answered this question supported than opposed the idea of greening; Those opposed often said that Scottish farmers were green enough or that greening should be carried out under Pillar 2; Need to focus effort to those areas best able to deliver benefits i.e. through regionalisation/land type; Need to ensure farmers are given credit for areas of the farm that are already green ; 10

11 Many responded that membership of agri-environment agreements should not count towards greening (minority responded that they should); Proposals too restrictive need more flexibility; Scottish Government should call for a menu of options; Small farmers shouldn t be exempt. Ecological focus areas (EFA) - the main points made were: Semi natural areas, grasslands and woodland to be included in eligible area; Minimum EFA area should be 10% (although some thought 7% was too high); Existing agri-environment areas should count towards EFA; Should be options to allow farmers to work together to link EFAs across landscape; Should include overwinter stubbles/cover crops. Crop diversification - the main points made were: The proposed 3 hectare threshold is too low; Uneconomical to grow three crops on such a small arable area. Permanent grassland - the main points made were: Need to maintain long rotation reseeding in Scotland; Use definition to protect areas of ecological significance; Keep permanent grassland rules in cross compliance; Definition must include heather. Carbon emissions/climate change mitigation - the main points made were: Use minimum tillage; Use of forestry; More efficient use of resources should be considered; Reduction in fossil fuel usage. Other - the main points made were: Addressing fuel use on farms; Compulsory soil testing to ensure appropriate targeting of fertiliser; Water course protection. Q24. Do you have any further comments on "Section 2: Further schemes which Scotland would have to offer" Overall, there were 94 responses to this question. The most frequent responses referred to national reserve; new entrants; small farmer exemption; greening; the 3 crop rule and permanent grassland. National reserve - the main points made were: Strong link with new entrants needs; Categories other than young/new entrants should benefit; 3% is insufficient to fund NR; NR must be on-going. 11

12 Young Farmers Scheme - the main points made were: Should be a new entrants scheme no age discrimination; Should be for new farmers regardless of age; 54ha limit is too small. Small Farmer Scheme the main points made were: Small farmers should not be exempt from cross compliance; SFS payment should be higher so that small active farmers avoid bureaucracy; Even smallest crofts, e.g. 1ha, should qualify. Greening - the main points made were: Need for flexibility within Member States; Greening must deliver across all farmland; Use GAEC rather than duplication through 30% of budget. 3 crop rule - the main points made were: Unsuitable in much of Scotland due to climate, soil type etc; Could be negative consequences for the environment. Permanent grassland - the main points made were: The 5 year rule does not fit well with the permanent grassland rotation in Scotland lot of respondents suggested figure should be higher e.g. 8 or 10 years; Long term reseeding must be allowed to maintain productivity. Other - the main points made were: One size does not fit all. Q31. Do you agree there should be an option to allow the transfer of up to 5% of Rural Development funds from Pillar 2 to Pillar 1 where Pillar 1 payment rates are currently less than 90% of the European average rate? Overall there were 84 responses to this question. Respondents were split roughly 50/50 about whether they agreed or disagreed with the proposal. The most frequent responses referred to a need for flexibility. Respondents that agreed with the proposal - the main points made were: Flexibility value of having the option; More payment to food production; Good if the money could be used to support Beef Calf Scheme. Respondents that disagreed with the proposal - the main points made were: No logic to this and inconsistent with Scotland arguing for greater share of Pillar 2 funds; Already insufficient funds in Pillar 2; 12

13 Any transfer of funds should be in opposite direction; Pillar 2 produces public goods with public money. Q32. Do you have any further questions you wish to make on this section? Voluntary Coupled Support (VCS), ANC and transfer between Pillars Overall there were 52 responses to this question. Respondents commented on the various optional schemes set out in the Commission s draft Regulation. Voluntary Coupled Support - the main points made were Could be one way of protecting and sustaining farming systems that are delivering high environmental benefits; Should be used to support extensive livestock grazing in High Nature Value farming and crofting; Scotland should push for 10% to be used for VCS (not 5% as proposed); VCS should be used to support sectors other than beef e.g. deer, sheep; Provide financial incentive for rare/ancient breeds. Area of Natural Constraint - the main points made were: Support for ANC in principle but less consensus about whether support would be best under Pillar 1, Pillar 2 or both; If ANC in P1 there was concern about complexity and conflict with P2 ANC; Payments need to be regionalised; Call for mountain and island categories. Transfers between Pillars - the main points made were: Some support (though not universal) for transferring funds from P1 to P2 to increase spending on agri-environment measures; No support for reverse modulation (P2 to P1 transfer); Lot of support for ensuring Scotland gets fairer share of P2 budget. 4.3 Rural Development Main Findings There were 79 responses on the Rural Development Regulation. Due to the smaller sample size the analysis of these responses cannot be used to give a definitive Scottish view and as such the detail below should be seen as information only. Of those that responded using Questback, 35 said their main interest was farming, 15 had environmental interests with the remainder having food, forestry, other business and community groups interests. 14 classed themselves as other which included public sector and had an interest across all categories. For each of the four tick box questions, the majority of the responses fell into the agree/strongly agree category and the percentages are shown below: Do you agree with the objectives and priorities of EAFRD (European Agricultural Fund for Rural Development) as set out at article 4 and 5? = 79% Do you agree with the proposals regarding thematic sub-programmes which 13

14 are set out in article 8 and annex III? = 68% Do you agree with the proposal re LEADER in articles and the proposed minimum spend of 5% of budget set out in article 65(5)? = 71% Do you agree with the proposal that EAFRD comes under a Common Strategic Framework (CSF) as set out in the CSF regulations? = 79% Rural Development - Analysis of the questions inviting comments Respondents were invited to comment on the measures which the Scottish Government are able to choose investment priorities from. A summary of the comments received for each measure is given below; where the measure is not listed no comments were received. It should be noted that the majority of comments received were on what we will actually do under our next Scotland Rural Development Programme, rather than comments on the proposed European Rural Development Regulations, however these have been included as the purpose of this report is to reflect the comments received. General comments may have come from one or more respondents, where multiple respondents gave the same comments, this is highlighted. Q. Comments on the specific wording of the measures which Scottish Government are able to choose investment priorities from. Article 15: Knowledge transfer and information actions Potential beneficiaries of this measure should be widened, and the sectors covered should also be increased to include environmental and game management training. It was also highlighted that there should be an integrated approach which could be linked with cross compliance and direct payment requirements. Article 16: Advisory services, farm management and farm relief services It was questioned whether multiple access to this measure was permitted. It was felt that the potential beneficiaries should be widened. In addition environmental, historic environments and landscape scale conversion advice should be included. Article 17: Quality schemes for agricultural products and foodstuffs The focus should be widened to include environmental, biodiversity and forestry standards with no time limitation. Other respondents questioned the value of this measure. Article 18: Investments in physical assets Should be inclusive of wider rural development, rather than only agriculture. Should be for the promotion of progressive farming and to include pollution control and management of slurry systems. Article 19: Restoring agricultural production potential damaged by natural disasters and catastrophic events and introduction of appropriate prevention actions Should include forestry and support for heather beetle and overgrazing of heather. It was highlighted that this was an unpredictable, and potentially expensive measure. 14

15 Article 20: Farm and business development Should include training facilities and recycling. Article 21: Basic services and village renewal in rural areas Three respondents felt that non-public bodies should be included as potential beneficiaries. It was suggested that the title should include reference to infrastructure and the use of management plans, and reference to Local Nature Conservation Sites should be included. Article 22: Investments in forest area development and improvement of the viability of forests Should include support for production of forest management plans and forest thinning. Environmental considerations should be included. Article 23: Afforestation and creation of woodland More detail and clarification was required, while environmental considerations should be included. It was also requested that income forgone payments were reinstated and the measure should include establishment and maintenance of woodland by natural colonisation. Article 25: Prevention and restoration of damage to forests from forest fires and natural disasters and catastrophic events Further clarification was required on what can be supported through this measure. Article 28: Setting up of producer groups Organic farming should be prioritised Article 29: Agri-environment- climate Eleven respondents felt that 25% of funds should be allocated to this measure, and two respondents felt this measure should be prioritised or compulsory. Recognition must be given to commitments that could be made for climate mitigation and adaption in agricultural landscapes e.g. relating to habitats such as high nature value grassland and peatlands. Article 30: Organic farming Two respondents felt it should be compulsory to include this measure. Article 31: Natura 2000 and Water framework directive payments Should be prioritised and include capercaillie and black grouse. Article 33: Designation of areas facing natural and other specific constraints An ecological services approach should be adopted which incorporates biodiversity, landscape, cultural heritage, recreation and community benefit. Six respondents felt this measure should support High Nature Value farming and crofting systems, and maintain extensive livestock grazing. It was highlighted that the mountain areas definition does not reflect conditions in Scotland Article 34: Animal welfare Should include medicated grouse grit. 15

16 Article 36: Co-operation Should be widened to include social enterprises, local NGOs, third sector and civil society organisations. Should include landscape scale co-operation, while organic farming should be prioritised. Article 37: Risk management Ten respondents felt this measure should be deleted. Article 38: Crop, animal, and plant insurance Ten respondents felt this measure should be deleted. Article 39: Mutual funds for animal and plant diseases and environmental incidents Ten respondents felt this measure should be deleted. Should include sheep dipping strategies and healthier beetle management Article 40: Income stabilisation tool Ten respondents felt this measure should be deleted. Article 55: National Rural Network Focus should be widened from agriculture to rural enterprises. General comments on measures There was a keenness for a simple structure with consistent wording. Many respondents highlighted the need for collaborative working across all actors that takes local strategic planning and development into account. A holistic approach at landscape scale that is driven by an ecological service approach has also been suggested. While the EU priorities were supported, there was a keenness to retain flexibility to allow Scotland to translate these priorities into specific actions, supported by evidence based assessment. Q. Comments on the Common Strategic Framework There was general support for a Common Strategic Framework with a need to ensure that this adds value and does not just add another layer of bureaucracy. More information is required to prevent confusion, and to clarify how priorities, sub priorities, axes and funding streams link together. A number of respondents felt that local decision making and targeting of funds was important, with more LEADER-style bottom up approaches. Other comments on European Commission Rural Development reform proposals The objectives were supported, the emphasis on knowledge, learning innovation and co-operation were welcomed. However, simpler, non-competitive schemes were sought. There was concern about the impact of reduced budgets, and the bridging between programmes. 16

17 A number of priority areas were suggested: delivery of public goods; Scotland s food and drink industry; agricultural land to be protected and worked; sustainability of natural resources and climate change; landscape and the historic environment; infrastructure investment by farmers; and, sustaining rural communities. Further comments were received on individual measures including greater use of LEADER, reinstating competitiveness of forestry and prioritising infrastructure investment by farmers. Finally, it was suggested that there should be provision of environmental and landscape information to land managers which should form part of the cross compliance requirements; and the public should be able to see farm environmental maps. 4.5 Horizontal Finance and Control Regulation Main Findings - There were 67 responses on the Horizontal Regulation - considerably fewer than the responses on Direct Payments. Due to the smaller sample size, the percentage analysis should be treated with caution. Of those that responded using Questback, 30 respondents said their main interest was farming, 14 had environmental interests with the remainder having food, forestry or public sector interests. The analysis of tick box questions shown below makes no distinction between organisational responses and individual responses. Strong agreement (More than 66.6% of responses agreeing with question): Payments available in Euros = 70% Availability of online application systems would aid accuracy and timeliness of processing = 79% Expand and target Farm Advisory System = 71% Holistic approach to inspections = 81% Monitoring and Evaluation should be all embracing and apply to direct payments, market measures, rural development and cross compliance = 78% Agreement (50 66% of responses agreeing with the question) In favour of an advance and final payment of Direct Payment = 60% Sustainable Use of Pesticides should be included in cross compliance = 66% Strongest disagreement (more than 66.6% of responses disagreeing with the question) Exempt participants in small farmers scheme from cross compliance penalties = 73% disagree Disagree (50 66% of responses disagreeing with the question) Remove requirements relating to wild birds (SMR 1) from cross compliance = 57% disagree 17

18 Remove requirements relating to protected plant species (SMR 5) from cross compliance = 56% disagree Questions eliciting highest number of neutral answers Remove requirements relating to certain animal diseases = 34% neutral Remove requirements relating to sewage sludge = 25% neutral SG should advance submission date of SAF = 30% neutral LEADER expenditure should be paid out by SGRPID = 36% neutral Some observations 1) payments and submission of SAF (Single Application Form) 88% of responses were either neutral or supportive of LEADER expenditure being paid out by SGRPID (Scottish Government Rural Payments and Inspections Division). 95% of responses were either neutral or supportive of payments being available in Euros Some observations 2) cross compliance The majority supported bringing the Water Framework Directive and the Sustainable Use of Pesticides Directive within cross compliance. Also a majority were against removing the protection afforded to wild birds and plant species. There was no clear view on of the proposed changes e.g. on animal disease, sewage sludge, machinery use on soils, burning stubble, protection of wetland and carbon soils, with almost equal numbers both for and against Finance and Control - Analysis of the questions inviting comments Q. Do you agree that the impact of the CAP should be measured against the three objectives shown? Objectives are: a) viable food production, with a focus on agricultural income, agricultural productivity and price stability; b) sustainable management of natural resources and climate action, with a focus on greenhouse gas emissions, biodiversity, soil and water; c) balanced territorial development, with a focus on rural employment, growth and poverty in rural areas. The majority of respondents who expressed an opinion supported the view that the impact of the CAP should be measured against the three objectives shown. However, there were a variety of views expressed. Some suggested that the focus should be on food production while others suggested that food production should be left to the market and that the focus of CAP should be on (b) and (c). Some wanted the objectives to mention the historic environment and to make a more overt reference to forestry. Some questioned how it would be measured. Q. Please comment on specific SMR's/GAEC's you would wish to include or remove 18

19 A range of views were expressed ranging from suggesting the removal of a number of SMRs and GAEC measures from cross compliance to retaining and adding to the current measures. Some common themes included concern about the agricultural impact of the proposed GAEC measures protecting carbon soils and wetlands, including the ban on first ploughing and a ban on burning stubble. Some suggested that the GAEC measures relating to encroachment of vegetation should be relaxed in order to recognise the environmental benefit of scrub. There was support for including the Water Framework Directive and the Sustainable Use of Pesticides Directive within cross compliance, and some support for extending the protection of historic and archaeological sites within cross compliance. Some suggested that enforcement of cross compliance should be strengthened. Q. What changes, if any, would you like made to the cross compliance penalty regime? Comments fell into 2 main camps those that suggested the penalty regime should be more proportionate by, for example, reducing or removing penalties for minor breaches, and those who felt that the regime should be strengthened in particular for breaches of environmental regulations and GAEC or for repeat offenses. The latter group also called for effective enforcement and talked about incentivising compliance. 5 - Conclusion There was a good response to the three consultations, in particular the one on direct payments. The responses have been, and will continue to be, useful for informing the Scottish Government negotiating position within the UK and in Europe. There were few surprises in the responses overall a fact that reflects the high level of engagement the Scottish Government has previously had with stakeholders on CAP reform. While the views of the different interest groups were at times polarised, for example, regarding what should be in or out of GAEC, there was a also lot of consensus. There was a lot of support for setting a minimum activity requirement, that all active farmers should receive direct payment entitlements and that those in the Small Farmers Scheme should be subject to cross compliance. Rural development respondents highlighted the need for inclusivity and the widening of focus beyond purely agriculture oriented activities. Flexibility was a word that cropped up regularly in the comments boxes across all three consultations. For example, direct payments respondents wanted the greening proposals to be more flexible; rural development respondents wanted Scotland to have the flexibility to select options on the basis of national priorities; and finance and control respondents wanted Scotland to have more flexibility to decide the appropriate level of penalty that should apply to breaches. 19

20 6 - Feedback This was the first time the Scottish Government had used an on-line Questback survey to consult stakeholders on the CAP. Feedback from stakeholders has been quite positive with most finding it accessible and easy to use. The main criticism has come from organisations that found the Questback survey too restrictive for their purposes. In particular, the limited space for comments was criticised. However, that said, most users made very economical use of the comments boxes - comments were therefore more concise and focussed than they might otherwise have been. 20

21 Crown copyright 2012 You may re-use this information (excluding logos and images) free of charge in any format or medium, under the terms of the Open Government Licence. To view this licence, visit or Where we have identified any third party copyright information you will need to obtain permission from the copyright holders concerned. ISBN: (web only) The Scottish Government St Andrew s House Edinburgh EH1 3DG Produced for the Scottish Government by APS Group Scotland DPPAS13560 (10/12) Published by the Scottish Government, October 2012 w w w. s c o t l a n d. g o v. u k