Direct Payments (Pillar 1)
1. Do you agree with the stability approach described here? Please provide comments.
Do you agree with the stability approach described here? Please provide comments.
Yes in general as some certainty and stability is required in what could be a time of unprecedented change. Opportunities for improvement and simplification must not be overlooked.
2. How might the annual application process for direct payments be adjusted to deliver with a lighter touch for those with little year-on-year change in their business?
How might the annual application process for direct payments be adjusted to deliver with a lighter touch for those with little year-on-year change in their business?
Moving to a system which accepts that the gross areas of most farms and crofts does not change from year to year would reduce the need for individual reporting of parcels of permanent forage ie rough grazing and permanent grassland. Also is there really a need to map ever rock and stream etc can we not just pay on gross area given that this would move funding to the most disadvantaged .
3. Are there operational changes in our delivery of Direct Payments that you would like the Government to consider during the transition period?
Are there operational changes in our delivery of Direct Payments that you would like the Government to consider during the transition period?
Lets move to a much smaller payment window so we know when we will be paid.
4. Do you support the continuation of some or all CAP rules on inspections and compliance during the Transition period, bearing in mind that Scotland will still need to comply with the rules of the World Trade Organisation (WTO)?
Do you support the continuation of some or all CAP rules on inspections and compliance during the Transition period, bearing in mind that Scotland will still need to comply with the rules of the World Trade Organisation (WTO)?
Try to simplify and improve fairness ie if you get a boundary wrong the current system appears to penalise one field for being under area and the other for being over area when in fact the gross has not changed.
5. Do you have any suggestions for straightforward changes that would improve the environmental outcomes achieved through greening payments in Pillar 1?
Do you have any suggestions for straightforward changes that would improve the environmental outcomes achieved through greening payments in Pillar 1?
not sure what these are.
6. Considering how funding is currently distributed across CAP schemes, do you have initial views about how the balance between these schemes should change in future to maximise outcomes?
Considering how funding is currently distributed across CAP schemes, do you have initial views about how the balance between these schemes should change in future to maximise outcomes?
Not sure but needs to be some move from paying on "production or activity" which favours those who already have the best land. Some levelling of the amount paid per gross area would move the funding in the direction of those with more marginal land both in productive ability and geographic constraint. This combined with capping which would cut the amounts which would go to large land holder would improve the outcomes although i am sure the NFU etc would not agree.
7. Do you agree that changes to capping are a useful measure to enhance the positive social and environmental impact of agricultural policy?
Do you agree that changes to capping are a useful measure to enhance the positive social and environmental impact of agricultural policy?
Yes
8. Do you have any specific views on how capping should work including what a maximum cap should be?
Do you have any specific views on how capping should work including what a maximum cap should be?
Not really as it would depend on which schemes are included and the rules of these schemes. In General there should be separate capping for capital and revenue. A revenue cap of about £75000 with possible uplifts for extra labour input on holdings.
9. Should there be a maximum cap on the total funding a business receives from all schemes, or a scheme-by-scheme approach?
How can the aims of LFASS be better achieved/would you prefer to see alternative methods of providing support?
A total cap but with separation of capital and revenue.
10. How can the aims of LFASS be better achieved/would you prefer to see alternative methods of providing support?
How can the aims of LFASS be better achieved/would you prefer to see alternative methods of providing support?
Needs to be better targeted to reflect not only land issues but distance to markets etc the higher levels of payment must go to remoter areas and poorer land again this will not be championed by the NFU etc as they naturally want to protect their members who are getting this funding at the moment, but it is governments responsibility to get this right. The current scheme is torturously complex in an attempt to give the impression of paying the highest rate for the most disadvantaged areas but in fact keeping most of the money in more productive areas of the mainland.
11. Would you see value in directing future LFA support through other existing Direct Payment Schemes?
Would you see value in directing future LFA support through other existing Direct Payment Schemes?
Possibly but care would need to be taken to avoid the LFA support being lost in future if it was not a separate scheme.
12. Do you think there are administrative and operational simplifications that would benefit current or future LFASS claimants?
Do you think there are administrative and operational simplifications that would benefit current or future LFASS claimants?
look at uprating the minimum payment and use the same criteria for bps and lfass land also us gross area if possible.
14. Do you support the use of regional pilots to help tailor schemes to local circumstances?
Do you support the use of regional pilots to help tailor schemes to local circumstances?
possibly but must not frustrate the need to move funding to the most disadvantaged areas
18. Do you agree with the proposals to set a timescale of up to five years for transition? Please provide comments.
Do you agree with the proposals to set a timescale of up to five years for transition? Please provide comments.
Depending on the start date 3 years might be better if the direction of travel as i have outline is right.
20. Many of the measures described in this consultation will have co-benefits for both agricultural productivity and for reducing Scotland's Greenhouse Gas Emissions. Are there other practical and feasible measures that would have similar co-benefits that you feel should be considered?
Many of the measures described in this consultation will have co-benefits for both agricultural productivity and for reducing Scotland's Greenhouse Gas Emissions. Are there other practical and feasible measures that would have similar co-benefits that you feel should be considered?
Help and encouragement for the uptake of renewables and energy saving measures on smaller farms.
21. Do you agree to expanding the number and role of Monitor Farms or similar during the transition period? Do you have any ideas as to how Monitor Farms could be refined or adapted to better meet future needs?
Do you agree to expanding the number and role of Monitor Farms or similar during the transition period? Do you have any ideas as to how Monitor Farms could be refined or adapted to better meet future needs?
Yes
22. Do you agree with the proposal to look at moving towards a more performance based approach to compliance, using key performance indicators and better information?
Do you agree with the proposal to look at moving towards a more performance based approach to compliance, using key performance indicators and better information?
??
Scottish Rural Development Programme (Pillar 2)
24. Given the importance of continuity of support for the forestry sector and that the target for new woodland is to increase to 15,000 hectares by 2025, should the current the Forestry Grant Scheme continue broadly in its current form until 2024 or can you suggest other short-term changes that would better achieve these policy aims?
Given the importance of continuity of support for the forestry sector and that the target for new woodland is to increase to 15,000 hectares by 2025, should the current the Forestry Grant Scheme continue broadly in its current form until 2024 or can you suggest other short-term changes that would better achieve these policy aims?
More support for smaller schemes to meet local need in island areas.
29. Considering the CAGS in its current form, are there opportunities to improve the administrative efficiency of the scheme?
Considering the CAGS in its current form, are there opportunities to improve the administrative efficiency of the scheme?
Bring back standard costs which were simple and effective.
30. Should the scope of what can be funded be reviewed, for example in terms of adding in new elements and restricting total spend on some projects?
Should the scope of what can be funded be reviewed, for example in terms of adding in new elements and restricting total spend on some projects?
Yes
32. Would there be customer benefits if the CAGS, small farms capital grant scheme and the new entrants capital grant scheme were combined?
Would there be customer benefits if the CAGS, small farms capital grant scheme and the new entrants capital grant scheme were combined?
Dont think this would be a good idea as they address different areas.
36. Is the LEADER approach something that you could support?
Is the LEADER approach something that you could support?
Yes LEADER need to be simplified as many are put of by the very complex nature of the process of claiming.
38. Do you have initial views on the proposal that SRDP broadband support would cease?
Do you have initial views on the proposal that SRDP broadband support would cease?
Agree
45. Would you support a future approach that aims to deliver similar increases in efficiency through the direct payment support mechanisms?
Would you support a future approach that aims to deliver similar
Yes the BES was just not worth it for smaller producers.
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