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.