Wednesday, 10 October 2012


NFU Scotland has urged the Scottish Government to proactively devise a new system to determine what land is eligible to receive public support. With CAP Reform gathering momentum, the opportunity exists to put in place a new set of rules that takes a more pragmatic approach to land deemed suitable for grazing and cropping. Issues raised by EU auditors in 2010 saw the Scottish Government apply more rigorous eligibility criteria to land and, as a result, many Scottish farmers have fallen foul of the rules when inspected. It has also resulted in penalties being imposed retrospectively on some claimants. NFU Scotland supports a new system that allows producers to consolidate their support payments onto the area of their land deemed to be eligible. It also supports producers having the option to move to gradient rather than flat mapping of eligible land. Finally, it asks that maps also take into account the grazing that beaches and coastlines provide for livestock in island areas. In a letter to Scotland’s Cabinet Secretary for Rural Affairs, Richard Lochhead, NFU Scotland President Nigel Miller wrote: “As a result of the EU audit, the changes in the criteria which determine land eligibility for support payments and how soft landscape features like bracken and gorse should be treated for claim purposes has created a great deal of uncertainty within the farming community. “Despite many producers being proactive in checking the accuracy of the information provided to them by Scottish Government on their field data sheets and deducting ineligible features from previously defined areas, inspections continue to reveal errors and trigger penalties. The deductions in eligible areas are, in some cases, being applied not just for a single scheme year but also retrospectively to the three previous claimed years. “The definition of eligible land is key to the future of agricultural support and it is now imperative that systems are put in place to recognise Scotland’s diverse landscape and avoid increasing conflict which could erode the viability of many units. It is important that the Scottish Government is proactive in developing workable eligibility standards. “In our view, the present penalty system is disproportionate and with support payments in Scotland currently being determined by historic coupled payments, the enforcement and penalties are, in many cases, unfair. Some form of consolidation option would break this destructive cycle and would be of value not just to Scotland but to other parts of the UK and the EU. “Land eligibility and the definition and mapping of ineligible features like bracken, scree or gorse, will continue to be a trip wire post CAP Reform. The European Parliament is being asked to consider tolerances or a coefficient in the new CAP rules to allow a level of flexibility that recognises some ineligible areas may be found within rough grazing and permanent pasture. “That approach will reduce mapping complexity, avoid unnecessary auditing costs, avoid inappropriate penalties and protect soft features which deliver ecological benefit. I hope the Scottish Government will be proactive in supporting this amendment and commit to introducing this flexibility under the reform process. “The impact at farm level of determining what is and isn’t eligible land may be minimised if the total landscape area is taken into account. With rock, scree and wet areas all now having to be assessed and mapped, it should be an option for claimants to take slope into account in defining the eligible area of a land parcel. “Clearly, in some landscapes, the gradients will more than balance ineligible features. We accept that Scottish Government IACS mapping should be provided on a ‘flat’ basis but, in line with other parts of the UK, the option for producers to utilise physical or gradient mapping should be available. If accepted, then those deemed in breach on land eligibility should have enforcement action frozen until the option to upgrade to physical mapping is considered. “The other area where Scottish Government must intervene is in the assessment of beach and tidal zones. These areas clearly are not pasture but the seaweed provides a critical grazing resource and can be fundamental to island sheep systems. That provides a strong case for these areas to be deemed eligible.”