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Farmers urged to respond to Commission greening consultation

The European Commission is seeking views on the first year of the new CAP greening rules with a view to making changes to the policy for the 2017 greening year.
Farmers would like to see a number of changes to the CAP greening rules
Farmers would like to see a number of changes to the CAP greening rules

Farmers are being urged to inform the European Commission directly about their experiences with greening during the first year of the new Common Agricultural Policy (CAP).


The Commission launched a 12-week public consultation on CAP greening just before Christmas as part of Agriculture Commissioner Phil Hogan’s drive to simplify the CAP.


The consultation, which closes on March 8, seeks views on experiences of greening over the first 12 months it has been in place as part of the Basic Payment Scheme (BPS).


More details about the online consultation, including how to take part, can be viewed here.


Of particular interest are views related to:


  • The implementation of greening,
  • The impact greening on ensuring a level playing between farmers in different EU countries
  • The impact of the policy on production potential.
  • Possible ways to simplify the greening framework and reduce the administrative burden associated to it.
  • The effects of greening on farms.


Mr Hogan will present a package of changes to the greening rules before the summer of 2016, enabling any changes agreed to come into place in the 2017 claim year.

Burdensome regulation

Gail Soutar, the NFU’s chief economics and international affairs welcomed the consultation.


She said a major priority for the NFU was to have future rules that are much simpler and more market orientated for farmers and hoped the review would be a step towards this.


“Overly burdensome regulation and specifically CAP reform is consistently cited by our members as having the biggest negative impact on business confidence,” she said.


“The new rules were introduced with very little time for farmers to prepare and in many cases guidance was changing throughout the application window.


“The full impact of that is only now being felt as farmers face late payments and in some cases reductions in the value of their payments due to errors and mistakes being identified. “


The NFU has previously identified a number of CAP simplification measures it wants to see adopted, including for greening and will push for their inclusion in the Commission’s package of technical amendments.


The NFU will respond on behalf of members to the consultation but is also encouraging members to send their responses to the European Commission directly.


CAP greening accounts for approximately 30 per cent of a farmer’s BPS payment and covers crop diversification, ecological focus areas and maintenance of permanent grassland.

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 The NFU’s priorities for greening reform  

 The NFU’s priorities for greening reform  


Crop diversification

The NFU said this measure, requiring most arable farms to grow three crops, goes against all of the NFU core policy principles of simplicity, market orientation, and increased efficiency.


It is seeking an alternative greening option for farmers who have difficulty with the measure, for example the flexibility to undertake enhanced ecological focus areas.

Crop Diversification – evidence

Late sown crops such as maize, early harvested crops such as lettuce or crops with very short growing period such as vining peas might not be in the ground in May or June when crop diversification inspections take place.


The NFU wants inspectors to be allowed to accept all other forms of proof that demonstrate compliance, for example crop records, ground preparation or tagged photography

Tolerance with respect unintentional 'greening error

Given the exceptional circumstances farmers faced in this the first year of implementing greening, the NFU is calling for a ‘light touch approach be taken to enforcement in the early years’.


Specifically it wants ‘tolerances’ (or margins of error) to be introduced with respect to areas and proportions declared under greening to minimise the impact of payment withdrawals.


EFA Hedges and qualifying features

The criteria associated with defining which areas on farm are eligible for EFA is incredibly complex, according to the NFU, for example including unnecessary restrictions around non-eligible uses adjacent to the features.


It is calling for these criteria should be streamlined and therefore simplified.

Catch crops – seed mixture

The NFU wants the requirement for catch crops counting as EFA contain a mixture of seed to be removed.


The rule adds ‘unnecessary complexity’ and without it, it would be possible to control the catch crop requirement with remote sensing and therefore reduce the number of on the spot checks.


It also wants the requirement for catch crops to include a cereal crop to be removed as it increases the risk of disease spreading in the soil and subsequent crops.


The requirement forbidding the grazing of catch crops should also be removed, the NFU said.

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