Response 180642283

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1) Basic Payments

1. The Scottish Government proposes that Payment Regions should be based on historical land type designations. Do you agree?

Please select one item
a) Yes;
b) No;
c) No view.

2. The Scottish Government proposes that having two Payment Regions will allow sufficient account to be taken as regards to the difference between land of differing quality without causing undue complexity for farmers and officials. Do you agree?

Please select one item
a) Yes;
b) No;
c) No view.

3. The Scottish Government proposes that Region 1 should be arable, temporary grass and permanent grassland and Region 2 should be rough grazing. Do you agree?

Please select one item
a) Yes;
b) No;
c) No view.

4. In considering future Payment Regions, please rank your top 3 options in order of preference (1 = first priority, 2 = second priority etc.).

a) Proposed Scottish Government approach of 2 regions based on land type;
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b) 3 regions based on land type;
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c) 2 regions based on LCA;
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d) 3 regions based on LCA;
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e) Single payment region;
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f) Other type of payment region designation;
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g) No view.
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5. The Scottish Government thinks the final area rate for mandatory direct payments (i.e. Basic Payments plus Greening Payments) on land in the Rough Grazing Payment Region should be between €20-25/ha. Do you:

Please select one item
a) Support the Scottish Government’s proposal;
b) Support a lower rate since any rate over €20-25/ha would overcompensate large holdings;
c) Support a higher rate since any rate under €20-25/ha would undercompensate smaller active mixed farms;
d) Not support the proposal for other reasons;
e) No view.

6. How quickly should we move to average payment rates in a region?

Please select one item
a) Flat area rate from Day 1 (2015);
b) Standard internal convergence to achieve a flat area rate in 2017;
c) Standard internal convergence to achieve a flat area rate by 2019;
d) Irish tunnel so that the range of payment entitlement values is narrowed but does not reach the flat area rate by 2019;
e) No view.

7. How would you prioritise the following factors which we need to take into account in deciding how to move to area based payments (1 = first priority, 4 = lowest priority etc.)

a) Simplicity;
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b) Clear and accurate forecasts of future payments to each farmer;
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c) Allowing farmers time to adjust to change;
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d) Avoid undue delay to those seeking fairer payments;
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e) No view.
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8. The Scottish Government proposes that the value of future Basic Payments be calculated based on the value of the SFP entitlements held by farmers in 2014 rather than on the amount of SFP paid to a farmer in 2014. Do you agree?

Please select one item
a) Yes;
b) No;
c) No view.

9. The Scottish Government proposes to keep the minimum threshold at the present level, so that control of at least 3 hectares of eligible land would be needed to claim future direct payments. Do you agree?

Please select one item
a) Agree – the minimum threshold should remain at 3 hectares;
b) Disagree because the minimum threshold should be 1 hectare;
c) Disagree because the minimum threshold should be 5 hectares;
d) Disagree because the minimum threshold should be €100;
e) No view.

10. The Scottish Government is not minded to add further business types to the negative list, to be automatically excluded from payments unless they can demonstrate that they are active farmers. Do you agree?

Please select one item
a) Yes;
b) No;
c) No view.

11. If the detailed rules allow, the Scottish Government intends to require land that is naturally in a state suitable for grazing to have a minimum stocking density in the region of 0.05LU/ha (i.e. roughly 1 sheep on 3 hectares) with derogations, for future direct payments. Do you agree?

Please select one item
a) Agree that a stocking rate of around 0.05 LU/ha (with derogations) should be required under the active farmer requirement;
b) Disagree because any minimum stocking density should be lower than 0.05LU/ha;
c) Disagree because any minimum stocking density should be higher than 0.05LU/ha;
d) Disagree for some other reason;
e) No view.

12. If we are not able to use a minimum stocking density requirement to meet the minimum activity requirement, should we instead require farmers to demonstrate that they are “active” famers by having plans to ensure a structured flock or herd, for example, plans showing a replacement strategy?

Please select one item
a) Yes;
b) No;
c) No view.

13. What should we be aiming for when considering an appropriate minimum activity requirement –please rank your top 3 options in order of preference (1 = first priority, 2 = second priority etc.).

a) Stop slipper faming even if this imposes burdens on active farmers;
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b) Balance the wish to stop slipper farming against the likely burden on genuine active farmers;
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c) Do the minimum necessary to meet European requirements even if this means slipper farming continues in Scotland;
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d) Workable and easy to understand rules for farmers;
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e) Appropriate procedures for environmental sensitive land;
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f) No view.
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14. Comment Box on the minimum activity requirement (200 word maximum)

There needs to be a method of ensuring that the actual land (each FID) which is claimed is actively farmed, not just that a claimant has some livestock on some eligible land somewhere in the country. Otherwise we will see arrangements whereby a slipper farmer "rents" sheep on an active farm somewhere but claims payments on a large area elsewhere which is still not being actively farmed.

15. The Scottish Government does not propose to use the reduction coefficient that can be applied when payment entitlements are allocated. Do you agree?

Please select one item
a) Yes;
b) No;
c) No view.

16. The Scottish Government does not propose to use the reduction coefficient that can be applied when payment entitlements are activated. Do you agree?

Please select one item
a) Yes;
b) No;
c) No view.

17. Which one of the following options for degressive reductions do you prefer?

Please select one item
a) Apply the mandatory 5% degressivity when a business’s Basic Payments are greater than €150,000;
b) Apply the mandatory 5% degressivity plus additional reduction of 25% when a business’s Basic Payments are greater than €300,000;
c) Apply the mandatory 5% degressivity plus a cap on Basic Payments so that maximum amount allowed to a business would be €500,000;
d) Apply the mandatory 5% degressivity plus additional reduction of 25% when a business’ Basic Payments are greater than €300,000 plus a total cap on Basic Payments of €500,000;
e) Should apply other types of optional degressivity in addition to the mandatory 5% degressive reduction of Basic Payments to a business which is greater than €150,000;
f) No view.

18. The Scottish Government proposes to use the windfall provision in cases where the termination or ending of a lease leads to a windfall gain for the farmer concerned. Do you agree?

Please select one item
a) Yes;
b) No;
c) No view.

19. The Scottish Government thinks that Scotland should take full advantage of a siphon on sales of entitlements without land. Do you agree?

Please select one item
a) Yes;
b) No;
c) No view.

2) Environmental measures – Greening, Equivalence and GAEC

20. The Scottish Government thinks that the Greening payment should be regionalised and paid on an area basis. Do you agree?

Please select one item
a) Agree the Greening payment should be regionalised, with each region having its own Greening payment rate;
b) Disagree because should pay Greening payment as a flat area rate across Scotland;
c) Disagree because should use the derogation that allows Greening payments to take account of Basic Payment value;
d) No view.

21. Do you think the Scottish Government should use the option to designate further environmentally sensitive permanent grassland areas outwith Natura sites?

Please select one item
a) Yes;
b) No, because other regulations already protect these areas;
c) No, because proposals are too restrictive;
d) No, because it creates additional complexity;
e) No, for another reason;
f) No view.

22. Do you think that the Scottish Government should continue to monitor the area of permanent grass at national level?

Please select one item
a) Yes;
b) No – would prefer area of permanent grassland to be monitored at holding level;
c) No view.

23. Which of the following areas do you think we should consider as being part of EFA in Scotland (bearing in mind the measurement and verification issues for landscape features):

(Required)
Yes No No view
Yes No No view
Yes No No view
Yes No No view
Yes No No view
Yes No No view
Yes No No view
Yes No No view
Yes No No view
Yes No No view

24. Do you think we should consider the option to implement the EFA requirement at regional level?

Please select one item
a) Yes;
b) No, because of risk of penalty due to behaviour of others;
c) No, because too complex and difficult for Scottish Government to verify/inspect;
d) No, because it is unlikely that sufficient farmers will wish to collaborate in this way;
e) No, for other reason;
f) No view.

25. Do you think we should consider the option to allow groups of farmers to implement the EFA requirement collectively?

Please select one item
a) Yes;
b) No, because of risk of penalty due to behaviour of others;
c) No, because too complex and difficult for Scottish Government to verify/inspect;
d) No, because it is unlikely that sufficient farmers will wish to collaborate in this way because it would be too onerous or too complex for farmers to organise;
e) No, for other reason;
f) No view.

26. We would like your views on whether optional weighting and conversion factors should be used when calculating the area of EFA on holdings?

Please select one item
a) No, because this would weaken the benefit delivered by the EFA requirement;
b) No, because this would increase complexity for farmers and Scottish Government;
c) No, for other reason;
d) Yes, because the required EFA area should be less than 5% of arable land;
e) Yes, because it is important to recognise the variable level of environmental benefit delivered by different types of EFA;
f) Yes, for other reason;
g) No view.

27. Should we consider using the equivalence option in Scotland and if so how?

Please select one item
a) Farmers should be required to meet only basic Greening requirements;
b) Equivalent practices should be optional for farmers;
c) Farmers should be required to deliver their Greening obligations through equivalent practices;
d) Farmers should be required to deliver their Greening obligations through an equivalent certification scheme which could include a combination of standard Greening requirements and equivalent practices;
e) No view.

28. If adopted, should an equivalent certification scheme include:

Please select one item
a) Through the standard Greening crop diversification requirement;
b) As the standard crop diversification requirement but delivered through an equivalent certification scheme;
c) Through one or more of the equivalent practices listed above, allowing farmers to choose which to implement on their holding if more than one is offered;
d) No view.

29. If we had an equivalent crop diversification requirement should it include:

Yes No No view
Yes No No view
Yes No No view
Yes No No view
Yes No No view
Yes No No view

30. As far as the Greening permanent grassland requirement is concerned how do you think it should be implemented in Scotland?

Please select one item
a) Through the standard Greening Permanent grassland measure;
b) As the standard Greening Permanent Grassland requirement but delivered through an equivalent certification scheme;
c) Through one or more of the equivalent practices set out by Europe (listed above), with farmers able to choose the most appropriate practice on their holding;
d) No view.

31. If we had an equivalent permanent grassland requirement in a certification scheme, which equivalent practice/s do you think should be included on meadows and pastures?

Yes No No view
Yes No No view
Yes No No view
Yes No No view
Yes No No view
Yes No No view
Yes No No view
Yes No No view
Yes No No view

32. If we had an equivalent permanent grassland requirement in a certification scheme, which equivalent practice/s you think should be included on extensive grazing systems?

Yes No No view
Yes No No view
Yes No No view
Yes No No view
Yes No No view

33. As far as the EFA requirement is concerned how do you think it should be implemented in Scotland?

Please select one item
a) Through the standard Greening EFA requirement;
b) As the standard EFA requirement but delivered through an equivalent certification scheme;
c) An equivalent requirement which ensures that at least 5% of arable land is devoted to one or more of the equivalent EFA types set by Europe (listed below);
d) No view.

34. If we had an equivalent EFA requirement which areas do you think should be able to count towards this requirement?

Yes No No view
Yes No No view
Yes No No view
Yes No No view
Yes No No view
Yes No No view
Yes No No view
Yes No No view
Yes No No view
Yes No No view

35. The Scottish Government thinks that GAEC 1 – the requirement to establish buffer strips along water courses – should include a ban on cultivation within 2m of surface water or wetland? Which of the following options do you prefer? Tick one.

Please select one item
a) A ban on cultivation and fertiliser and pesticide use within 2m of a water courses;
b) A ban on cultivation only within 2m of a water course;
c) No ban on cultivation within 2m of a water course;
d) None of the above;
e) No view.

36. The Scottish Government does not intend to introduce new requirements into GAECs 2, 3, 4 and 5. Do you agree?

Please select one item
a) Yes;
b) No;
c) No view.

37. The Scottish Government does not intend to introduce new requirements other than the compulsory ban on the burning arable stubble as set out by Europe. Do you agree?

Please select one item
a) Yes;
b) No;
c) No view.

38. In relation to hedges, which of the following options for GAEC 7 “Retention of landscape features” do you prefer? Tick one;

Please select one item
a) A ban on cultivation and fertiliser and pesticide use within 2m of a hedge;
b) A ban on cultivation only within 2m of a hedge;
c) No ban on cultivation adjacent to a hedge;
d) None of the above;
e) No view.

39. In relation to dry stone walls, which of the following options for GAEC 7 do you prefer? Tick one

Please select one item
a) A ban on cultivation and fertiliser and pesticide use within 2m of a dry stone wall;
b) A ban on cultivation only within 2m of a dry stone wall;
c) No ban on cultivation adjacent to a dry stone wall;
d) None of the above;
e) No view.

40. The Scottish Government does not intend to use the option to allow GAEC 7 to require farmers to tackle the spread of invasive species (click all that are relevant).

Yes No No view
Yes No No view
Yes No No view
Yes No No view
Yes No No view
Yes No No view
Yes No No view

41. Comment box for comments on Greening Measures, Equivalence and GEAC (500 words maximum)

There should be support through Pillar 2 for controlling invasive species as listed in Q40 as stand alone items, rather than simply imposition of penalties for not doing so. Grants should be available for these control measures alone rather than only as part of a wider agri-environment scheme. The cost (both financial and in terms of manpower, time, resources etc) involved in tackling these species can be enormous but will only increase if not tackled asap in many areas. Consideration should be given to including bracken as another plant species for which stand-alone area-based grants could be available through Pillar 2 for control.

3) Other Direct Payments

42. What level of VCS do you think should go to a future beef scheme?

Please select one item
a) 0%;
b) 2%
c) 4%
d) 6%
e) 8%
f) No view

43. The Scottish Government thinks that future VCS should be allocated to give 3 x the rate for the first 10 calves, 2 x the rate for calves 11-50 and 1 x rate for more than 50 calves. Do you agree?

Please select one item
a) Yes;
b) No should increase the front loading so that small producers (1-10 calves) benefit more;
c) No should decrease the front loading so that medium sized herds benefit more;
d) No view

44. Should any future coupled support scheme for beef allow payments on beef calves from dairy cows i.e. 50+% beef genetics?

Please select one item
a) Yes agree should focus coupled support on 50+% beef calves;
b) Yes but only if the 50+% calves make it to slaughter or some other criteria to ensure proper use;
c) No because it would dilute payments to “beef” calves when we need to strengthen them and economic output from dairy relatively high;
d) No because it would complicate the market and devalue the “Scotch beef” brand;
e) Other;
f) No view

45. Do you agree that we should not consider coupled support for lambs until there is a statutory database in place that identifies individual animals?

Please select one item
a) Yes;
b) No;
c) No view.

46. If a coupled support scheme for sheep was introduced what proportion of VCS funding should be used?

Please select one item
a) 2% VCS for all sheep and 6% VCS for beef;
b) 3% VCS for all sheep and 5% for beef;
c) 2% VCS for hill sheep and 6% VCS for beef;
d) 3% VCS for hill sheep and 5% for beef;
e) Use all 8% VCS for beef;
f) No view.

47. Should we explore with the other UK regions whether it could be possible to use more than 8% of the Scottish ceiling for voluntary coupled support?

Please select one item
a) Yes;
b) No;
c) No view.

48. Should Scotland use the Redistributive Payment option?

Please select one item
a) Yes;
b) No;
c) No view.

49. The Scottish Government proposes to pay Young Farmer top ups on the first 54 ha using Option (1) (top up payments calculated at 25% of average entitlement value). Do you agree?

Please select one item
a) Yes
b) No, should use Option 2 ;
c) No, should use Option 3 ;
d) No, should use Option 4;
e) No view.

50. Given that the majority of Scotland’s small farms are grassland and livestock based, the Scottish Government does not propose introducing a Small Farmers Scheme. Do you agree?

Please select one item
a) Yes;
b) No;
c) No view.

51. The Scottish Government does not propose to use the Pillar 1 ANC option and will continue to provide support for Less Favoured Areas under Pillar 2. Do you agree?

Please select one item
a) Yes;
b) No;
c) No view.

52. In Year 1, the Scottish Government proposes to use the National Reserve to help existing new entrants from Day 1. Do you agree?

Please select one item
a) Yes;
b) No;
c) No view.

53. The Scottish Government intends to ensure that future new entrants are able to access the National Reserve for entitlements and may use the option to perform further top slices to ensure there are adequate funds for this purpose. Do you agree?

Please select one item
a) Yes;
b) No;
c) No view.

4) Proposed final package

54. Please score the following aspects of the proposed package for Basic Payments (1= Strong agreement that feature should be in final package, 2 = Agreement, 3 = Weak agreement and 4 = Disagree that feature should be in final package).

a):
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b):
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d):
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f):
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g):
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h):
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i):
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55. Please score the following possible aspects of the future package (1= Strong agreement that feature should be in final package, 2 = Agreement, 3 = Weak agreement and 4= Disagree that feature should be in final package).

a)
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b)
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c)
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56. Final comment box for comments on proposed package as a whole (500 words maximum)

There are two fundamental issues which I believe must be addressed under the new system - (1) slipper farming and (2) a move as quickly as possible away from distorted historical subsidy payments. I strongly believe that the move to area based payments on 2 region basis should take place as early as possible (2015). There is no justification for continuing with a large (albeit decreasing) element of direct payments based on activity during the period 2000-2002. The system must now be changed and it seems that the current proposals are on the whole sensible and fairly well advanced and developed. Why should we not therefore move as quickly as possible towards an updated system based on what is happening on the ground now, rather than what was happening 13+ years ago? I speak as both a young farmer and also a land agent who has advised and worked for many farm and estate clients. From experience in both of these roles it is very clear to me that there is a huge level of inactivity on large parts of Scotland's farm land. This is being encouraged and sustained by the current historic subsidy system whilst a significant number of young, enthusiastic and capable people who would welcome the challenge of taking on additional land or starting up a business are unable to do so. The only way to ensure that Scotland's farming industry moves with the times and that there is dynamic activity in the sector (particularly opportunities for taking on land) is to move to an up to date direct payment system as quickly as possible and to ensure there is an effective "active farmer" test in place from the outset (and throughout any convergence period if there must be one). A combination of these two things will undoubtedly lead to many of the older generation who are currently being propped up by subs but not actively farming looking to either dispose of their land or make land available to lease. Surely this is one of Scot-Gov's desired outcomes and this is the only way in which to ensure that it happens.