Cap Reform Blog

April 9, 2014
by David Barnes

CAP on the big screen

I spend a lot of time working on and thinking about the Common Agricultural Policy, but even I like to take a break at times.  So imagine my surprise during a family trip to the cinema last weekend when, amongst the trailers and adverts before the film, I saw a full colour European Commission-funded advert promoting …… the CAP !

I suppose the Commission are trying to do the same as we are in Scottish Government, namely raise awareness of the CAP and get more people interested in its future.  That being the case, it’s really pleasing that we had record numbers of responses to both of the CAP consultation exercises that have recently closed.

For the Pillar 1 direct payments system, the final number of responses was 464, which is more than double the previous record.  94 percent of respondents used the online questionnaire, with only a small minority taking the alternative option of a paper copy.

For Pillar 2 rural development, the total was even higher at 947 – of which 597 were identical.  That’s because one organisation asked all its members to write to us saying the same thing, and many of them did.

A write-in campaign like this is by no means a new phenomenon.  In the old days before e-mail, organisations would pre-print letters or postcards and distribute them to their members to sign and send in to the government.  These days it’s even easier as all anyone has to do is cut, paste and press send. 

But it does mean that interpreting the results of consultation exercises has always been as much an art as a science.  It’s easy to say that on a particular proposal, a certain percentage of responses were in favour or against.  But a single response could represent a membership organisation with hundreds or thousands of members, or the individual point of view of one member of the public.  So we always take care to study not just the numbers but the detail of the responses, to give us the best possible picture of the range of views held.  That careful study is exactly what the Pillar 1 and Pillar 2 teams are working on now.

Since my last post, as you may have seen in the press, we’ve had some unwelcome news from the Commission on the future options for Voluntary Coupled Support under the new CAP.  Mr Lochhead has asked for an urgent meeting with Commissioner Ciolos: you can find more details here:  .

March 27, 2014
by David Barnes

Nailing down the options

Yesterday morning I was at the Scottish Parliament for the Cabinet Secretary’s session on CAP with the Rural Affairs Committee.  In about two and a half hours, the questions ranged over all the main policy and delivery aspects of Pillars 1 and 2.

The MSPs on the Committee were asking questions in light of the evidence they had already taken from various stakeholders in other sessions.  I was struck by how often the Members’ questions were along the lines: ‘one witness said the government should do one thing but another called for the opposite; what does the Cabinet Secretary think?’.  I suppose this reflected the fact that many of the witnesses were from representative organisations.  Their evidence will have been based not on the general interest, but on the specific interests of their members – that is their job, after all.

One point I would highlight is Mr Lochhead’s comment about the twin suggestions of splitting the rough grazing payment region into two, and of introducing a coupled support scheme for sheep.  Both of these could contribute to a policy outcome, but both come with a significant cost in terms of bureaucracy for farmers and for government.  What Mr Lochhead said was that he will consider both, but they are both targeting essentially the same policy question – and therefore, if he decided to take action, it seemed likely that this would mean adopting one or the other but not both.

This makes complete sense.  We often talk about the CAP giving us a toolbox of policy tools to choose from – well, you wouldn’t dream of paying for two hammers to knock in one nail.

March 24, 2014
by David Barnes
1 Comment

A fine balance

We’re into the last week of the consultation exercise on Pillar 1 direct payments.  I’m really pleased with the response rate so far, but the more the merrier – especially after the Cabinet Secretary extended the deadline to make sure everyone with an interest has a good chance to respond.  The new deadline is this Friday.  As Mr Lochhead said in a letter that went out to all CAP recipients last week, please do use this this opportunity to give us your views.

Included with that letter was a pack of information about the new CAP, both Pillar 1 and Pillar 2.  We were aware that the farmers’ representatives with whom we’ve been discussing the new CAP for years are atypical in terms of how much they know about the new policy.  The vast majority of farmers, even those who have been following the story closely, will be much less familiar with the detail.  To give just one example, the fact that the old Single Farm Payment entitlements will be voided and replaced by a brand new set of entitlements is old hat to stakeholder representatives, but there’s no reason why grass roots farmers would know it unless they’re told.  So we tried to make the information pack useful for everybody, not just those who already have a certain level of knowledge.

The other big challenge in drafting it was how much detail to go into.  We knew that if we made it too long then people would find it impenetrable and it wouldn’t get read.  On the other hand, these are very complicated and extremely important issues, and if we simplified and shortened it too much then farmers wouldn’t be getting the whole story.  So we tried to strike a balance – covering all the bases and including all the essential information, but pointing people towards other documents for the additional detail rather than including it in this one.  We tested it out on a couple of real people too, before it was finalised.

I hope we got the balance about right, that you found it useful, and that if you haven’t already responded to the Pillar 1 consultation, you’ll do so this week.

March 10, 2014
by David Barnes
1 Comment

CAP journey continues

I was on my travels last week, to Glasgow and Inverness.  I’ve got a new Scottish Government laptop, and the rail journey home from Glasgow gave me the opportunity to test it out with on-train WiFi.   I’m hoping that I can stop carrying around great heaps of paper in future – although it remains to be seen whether I can discipline myself to ditch my faithful dog-eared CAP regulation texts, and rely solely on electronic versions!

I’d been in Glasgow to speak on CAP reform at the Rural Law Conference.  We spend a lot of time thinking about and talking to farmers, but there’s a whole other community of folk who need to know all about the CAP – the professionals who advise and work with farm businesses.

In Inverness the following day I was with the Minister for the Environment and Climate Change (and crofting), Paul Wheelhouse, for meetings with NFU Scotland’s Highlands and Islands Committee, and the Crofting Commission.  Naturally there was particular interest in the proposals for crofter and small farmer grants in the new SRDP.

But the biggest news of the week was the decision to extend the deadline for responses to the consultation exercise on Pillar 1 Direct Payments.  So those of you who haven’t responded now have until the 28th to do so.


February 24, 2014
by David Barnes

New Entrants: looking forward, not back

To make a bit of a change, every so often, I am going to invite a guest blog.  This time it is the turn of David Steel who farms in Perthshire and sits on the Scottish Government’s New Entrants panel.  The view expressed are his own and don’t represent mine or the Scottish Government. This comes ahead of the Scottish Government New Entrants Gathering to be held in Murrayfield, Edinburgh later this week, on the 26th February.

It has been a real eye opener representing new entrants during CAP reform negotiations and now as a member of the New Entrants Panel. It was a real step forward for Richard Lochhead to ensure we had proper representation within the stakeholder group, and by setting up the New Entrant Panel which discusses and advises on a whole range of matters that affect New Entrants. Nobody can know the requirements better for getting new blood into the industry than newcomers that have been through the mill themselves.

There is nothing like CAP reform discussions to get the various stakeholders retreating into their entrenched positions. As a new entrant, I have taken a view that fairness to all farmers is what CAP reform should deliver. We New Entrants don’t want special treatment, just fair treatment compared with our contemporary established farmers. An example of where this doesn’t look likely, is adopting a gradual change to the new CAP system. This doesn’t deliver fairness, as we new entrants have to stand at a ringside bidding on livestock or tendering for land against farmers who will have much higher single farm payments due to their historical element. So any new entrants reading this needs to complete the CAP consultation and make your views on CAP reform known.

The one thing we find within the New Entrants Panel is that we are all practical, pragmatic people who put the dogma of the various organisations we represent in a backseat, to arrive at common sense, pragmatic positions and solutions.

The single most important issue we presently have to deal with is making sure that the National Reserve for the new CAP picks up all those disadvantaged by the old scheme. This will include many businesses that had small scale activity during the last reference period and have expanded significantly since then. It will also need to pick up those who have started business since then and have bought low levels of entitlements and need to have this made up to the basic area payments levels at least. You can be assured that we know the problems and hopefully we will arrive with a National Reserve Scheme that is inclusive and doesn’t repeat the errors of the past and exclude New Entrants from the subsidy system.

David Steel

New Entrants Panel member

February 17, 2014
by David Barnes

Consulting on the issues

There’s now only a couple of weeks left to get your responses to us on the SRDP consultation. If you want to influence the shape of the new programme, now’s the time to do it.

For the consultation on direct payments, the deadline is a little later – there’s about a month to go on that one.

I”m writing this in Brussels, as I listen to the new Greek Presidency going through the formalities at the start of the Council of Ministers meeting. At today’s meeting one of the most significant agenda items is a mere Any Other Business point. Virtually all the member states have signed up to an AOB item asking the European Commission to be more communicative about its draft for the detailed implementing rules for the new CAP – the so-called Delegated Acts.

But more important for Scotland than anything on the Council agenda is Cabinet Secretary Lochhead’s meeting later today with Commissioner Ciolos, about slipper farming and coupled support. Lack of clarity isn’t helpful for anyone, and I hope we come out of the meeting with a clearer understanding than when we went in.

It sounds like the Greek minister is getting to the end of the formalities – yes they really do go on that long (!) – so I’ll sign off ready for the start of the Council meeting proper.

February 5, 2014
by David Barnes
1 Comment

CAP update

Responses to our two CAP consultation documents are coming in, on both the SRDP (CAP Pillar 2) and Direct Payments (Pillar 1). This is a really important part of the policymaking process, so I’d encourage everyone with an interest to send us a response.

The consultation documents can be found at  (SRDP) and  (Direct Payments).

At this stage, in mid-consultation, government officials (and ministers) have to be careful what we say, so that we don’t inadvertently influence the final consultation results. But I can give a factual update on some things that have happened or are about to happen.

A couple of weeks ago our New Entrant Panel met. New entrants have a special interest in how the National Reserve for direct payment entitlements will operate, so we kicked off some detailed work with them on the kind of criteria we might use. Last week we published farm income estimates for 2013 ( On the same day, the Government gave MSPs an opportunity to set out their views on implementation of the new CAP, in a debate in the Scottish Parliament. Cabinet Secretary Richard Lochhead’s speech in the debate is at

And today, 5 Feb, our CAP stakeholder group is meeting for the first time in 2014.

One of the issues on the agenda is the so-called ‘Scottish clause’ under which we will be able to apply activity requirement to future farm payments. It was Mark Twain who said ‘the reports of my death have been greatly exaggerated’, and a similar comment could apply to the Scottish Clause. The European Commission’s first draft of the detailed implementing rules wasn’t acceptable, and we had to lobby to get it changed; but we succeeded, and now we can put together a plan that will mean if there’s no activity on the land, then it won’t be eligible for payments. We’ve identified at least two alternative ways to do this, on which we’ll get stakeholders’ views at today’s meeting before working them up further.

December 20, 2013
by David Barnes

Capping off the year

In more than two years since the CAP negotiations began, there’s been more to write about some weeks than others.  This has been a bumper week.

On Sunday I set off for Brussels for the final step at Council of Ministers level, namely the formal adoption on Monday of the package of CAP regulations.  As always there was an opportunity for useful discussions in the margins, and I was present when Cabinet Secretary Richard Lochhead spoke with Commissioner Ciolos about the Scottish Clause.

Monday was also the closing date for our ‘mini-consultation’ on the Pillar 1 to Pillar 2 budget transfer.

Then on Tuesday we launched the second of our two big consultation documents, on the new direct payments system.  On occasions like this, when we publish complex information, we appreciate that journalists can face quite a challenge to analyse and write about it the same day for the next morning’s papers, so we sometimes offer them the opportunity to be briefed directly by officials. This is a chance to seek clarifications, or ask technical questions.  We did that on Tuesday by teleconference and quite a few journalists took part.

Then on Wednesday Mr Lochhead announced his decision on the budget transfer, by confirming the rate of 9.5 percent – in time to meet the EU notification deadline.

This will be my last blog before Christmas, so a very merry one to all.

December 9, 2013
by David Barnes

Consulting on the CAP

Last Thursday, Rural Affairs Secretary Richard Lochhead attended one of our CAP stakeholder group meetings, to launch our short consultation document on Pillar-to-Pillar budget transfers under the new CAP.

We’ve called it a ‘mini-consultation’ because it only covers one issue, and because the EU’s deadline for our decision means we can only give stakeholders a couple of weeks to reply on this occasion.  Having said that, we already carried out a full two-month consultation on this same issue earlier in the year.  What’s new is that we now know Scotland’s allocations in the two Pillars, enabling us to make the question specific rather than general.

Mr Lochhead’s comments explain the rationale for the proposal to which responses are sought, and I won’t attempt to paraphrase them.  But they highlight a couple of the issues we’re grappling with on the new CAP.

One is about balance.  In an ideal world, it would be possible to pursue every one of our desired policies to the maximum.  But the world isn’t like that, so we’re constantly having to reach judgements on where the best balance between competing considerations lies – in this case, between the need to have a big enough budget for the new Scottish Rural Development Programme (SRDP), and the wish not to have to reduce Pillar 1 direct farm payments.  It’s that balance on which we would now like views.

The other issue is about focus.  A common criticism of the current CAP, and especially the current SRDP, is that it tries to be all things to all people.  Indeed, when the 2007-13 SRDP was designed back in about 2006, there was a deliberate decision to offer an open menu of options, in the expectation that local decision-making by project assessment committees would sort out the best projects from the rest – in other words, the correct focus would be applied at local level.  In the event, that system didn’t work out as planned.  So for the new programme, in a couple of years of discussions with stakeholders, we’ve often heard the message that clearer top-down focus would be a good thing, especially if the budget is going to be less than we would have hoped – if there’s little jam in the pot, it’s important not to try and spread it too thinly.  So you’ll see that spirit reflected in the illustrative SRDP budget allocations in the mini-consultation.

But the allocations are just there for illustration at this stage.  The mini-consultation is about the single issue of the size of the funding transfer.  Those budget allocation proposals will be fleshed out later this week in the full SRDP consultation, for decisions to be taken next year.

November 21, 2013
by David Barnes

EU developments

Unusually, there’s no meeting of the EU’s Council of Agriculture Ministers this month.  But there have still been important developments at EU level.

The decision on ‘financial discipline’ affecting the 2013 Single Farm Payment has been formally adopted.  This is the mechanism which says that if the EU’s expenditure elsewhere in Pillar 1 goes up (Eg if spending on market support measures for farm products is higher than planned) and there’s a risk of the overall Pillar 1 budget being exceeded, SFP has to be cut in all member states in order to stay within-budget.

This has been part of the CAP for several years but this is the first time it’s been triggered.  The cut of just over 2 percent is of course not welcome, but is considerably lower than was originally proposed, and we successfully negotiated down Scotland’s share of the cut.

There have also been two important votes in the European Parliament, confirming formally its approval of the budget deal for 2014 to 2020, and the package of CAP regulations.

You may well have thought that these were both agreed months ago. Indeed, in the case of the CAP regulations, nearly everything was agreed in June and the final details were negotiated in late September.  But formally speaking the regulations had not been through the necessary voting procedures.

Now that the Parliament has had its vote, the final step is for the Council to formally adopt the regulations, probably in December – just a few days before the new CAP was originally supposed to take effect on 1 Jan 2014.  Clearly it’s impossible to implement things in that timescale, which is why transitional arrangements will apply in 2014.

If Europe learns lessons from this CAP reform round, I hope one of them will be that either the process has to start earlier, so that new rules can be introduced on time, or alternatively that transition arrangements must be part of the reform process and not a late afterthought.