You may have read in the press about the official opinion of the European Court of Auditors (ECA) on the future CAP proposals, which came out on Tuesday.
What is the ECA? Just like national governments have independent audit bodies whose job is to keep them on the straight and narrow (in Scottish Government’s case, Audit Scotland), so the EU has the ECA. It both scrutinises the past and expresses views on plans for the future, and this opinion is of course an example of the latter.
There’s much in it that’s music to our ears. The ECA reiterates many of the concerns we’ve been expressing, about complexity and administrative burden, and its comments should carry particular weight because they come from a body both expert and independent. However, the opinion also demonstrates the old maxim that it’s far easier to criticise someone else’s proposals than to come up with better alternatives.
The best example is on the ‘active farmer’ rule. You’ll remember that the Commission proposes we look at every farmer’s non-agricultural income, and anyone whose CAP direct payments are less than 5% of their non-farming receipts would be deemed not to be an active farmer. On that, the ECA says it “has doubts as to whether some of these proposed measures can be implemented effectively without imposing an excessive administrative burden on national managing agencies and on farmers”.
That’s helpful support for Scottish Government’s position. But what’s the solution, according to the ECA? It’s “adopting a general and simple definition of what constitutes an ‘active farmer’…”. You don’t say! That’s what the Commission, the Member States, Paying Agencies, stakeholders and everyone else with an interest has been trying to come up with for the last two years, without success so far. So whilst the ECA’s criticisms are helpful, they don’t really take us any further forward.
Meanwhile the Scottish Government’s view on that particular issue has been that we should focus on the land, not the person or business. This would mean that if land is being managed in a way that deserves farm payments, then those payments would be made regardless of what other business interests the claimant has. And conversely, if a given piece of land is not being managed in a way that justifies the CAP payments, then we wouldn’t pay on that land even if that claimant is a genuine farmer somewhere else.
If there was an easy answer, no doubt someone would have found it already. If you’ve got thoughts on this, do let us know.
April 22, 2012 at 9:05 am
Under the New Entrant installation measure, there is a well defined labour unit calculation, Standard Labour Requirements built by number of stock, acreage etc. These could be augmented to provide for diversification that contributes to CAP targets and any conservation/ afforestation/ environmental work that goes on. Then rather than capping or defining active farmer, payments could be made on whatever basis (i.e land type, area average, region flat rate etc) but total payments could be based on a maximum amount per SLE. There would be a bit of work to start with but by taking an average of 2 census and an IACS spot checks and ongoing average would not be too difficult, especially if farmers could keep their own records up to date by online census.
In summary, if we said say 40,000Euro per SLE, then if a farmer has 1000 eligible ha, but only has 0.25 SLE on that unit then they would get 10,000 Euro. The upper limit would be whatever the normal decided SFP hectare rate is, so if he had 10hectares but 10 SLEs he would not get 400,000 Euro but probably around 3000 Euro. I know farmers may try and manipulate this, but it does not restrict to commodities and allows market forces to dictate which enterprise you run, and encourages rural employment/ agricultural production and or environmental active management to generate full subsidies.
Once everyone has their allowance set, many will not meet their SLE’s, so that money could be put into Rural Development funds, top ups or reserves, but the budget kept each year in case claimants up their activity.
April 24, 2012 at 5:06 pm
This is an interesting thought, and a different take on anything else that has been proposed. There is some real logic here around encouraging rural employment. However, whilst there is indeed a well defined labour unit calculation for Full Time Equivalents (FTE) I would question the accuracy of the rates that are in place. Not too sure about requirements for livestock, but with regard to crops, it implies that one man looks after 95 hectares of cereals – I would have thought there’s plenty examples where one man is farming more that 95 hectares of cereals. In my own example, for field vegetables it gives one man looking after 19 hectares. I grow 10 hectares and employ one full time, one part time and work on the farm myself full time. On that basis 4 units per FTE is what is possible, quite a difference from 19 that is used by the SRDP.