Environment, Food and Rural Affairs CommitteeWritten evidence submitted by J M Greensit
1. Fairness
(a) The British Government have always ensured that English farmers are placed at a competitive disadvantage to the European counterparts. The option to transfer up to 15% of the money allocated to UK farmers from Pillar 1 to Pillar 2 will immediately put English farmers at a disadvantage as European Governments will opt to avoid any transfer from Pillar 1 to Pillar 2 or transfer funds from Pillar 2 to Pillar 1 no matter what the final deal is. The British Government has always had to cross the “T” and dot the “i” where as European Governments have always read the rules but instead of abiding by them they have always gone their own way. There should be no “cap” on the amount of money paid to large farmers unless the other European Governments treat their large farmers in the same way. Unlikely, as European Governments always look after their farming community and would not put any of their farming community as a disadvantage.
(b) If the Government put too many restrictions on who can claim payment under the new CAP, landowners will take back in hand land and farm this themselves or contract farm the land thus reducing the area of land available to let to new entrants. Does the Government want tenant farming to continue and for land to be available to new entrants? If so, care should be taken when deciding whether to “cap” payments to large farmers.
(c) If the British Government change the regional boundaries from the present ones, Non-SDA, SDA and SDA Moorland, then upland farmers will have an advantage over the lowland farmers. At present upland farmers are well paid through Higher Level Stewardships—some getting £100,000 per year for 10 years without changing their farming practice. Other upland farmers receiving Higher Level Stewardship monies only have to reduce slightly the number of livestock on the moor in winter. Lowland farmers are at a disadvantage as fewer farmers are eligible for the Higher Level Stewardship Agreements. Another reason care should be taken when deciding who should be classed as an active farmer is that upland farmers removing livestock in winter from the moors need lowland grazing for the livestock or they have to build housing for the livestock, not something the National Parks readily agree to.
(d) The principal problem with Common Land grazing rights is that the Common Land Registers are not up to date. A major factor under the present system is that many farmers with “rights” on the Commons are unable to provide proof of ownership as ownership may have changed a number of times—some rights registered by tenants and others by owners. What we do not want is the European Commission bringing Acts to deal with something they do not understand. If the Common Land Registers were brought up to date then many Common Land problems would be resolved. Once again farmers may not receive a high level of payment under the present system but Commons have been put into Higher Level Stewardships and graziers do receive a considerable amount in payment under these Stewardship Agreements.
2. Bureaucracy
(a) The Government needs to ensure that any new CAP system is easy to work, easy for farmers to understand, less interference from Civil Servants, and more knowledgeable staff dealing with the annual claim forms. A computer system should be in place that works correctly from the start of the new CAP system and not one that needs to be continually corrected as with the present Single Payment Scheme system. If this does not happen then farmers will again be disadvantaged as payments will again not be paid on time. All inspectors employed by DEFRA/RPA should understand farming and use common sense with regard to minor infringements and not at every opportunity try to knock farmers by penalising them just to show that they, the inspectors, have “power” to make farmers do as the inspectors say. This does happen at present and does not make for good relations between farmers are DEFRA/RPA. Inspectors should give farmers at least 24 hours notice of an inspection whether it is an RPA inspection or an Environmental Scheme inspection.
(b) The present definition of an Active Farmer should be that they are predominantly involved in agriculture. I agree that airports, waterworks etc should not be classed as Active Farmers and that the minimum area to claim should be increased slightly. The definition of Active Farmer needs to be very carefully considered in relation to shooting estates who also farm some land but with the majority of the Estate’s land being let either long term under the old AHA act or short term under an FBT. The latter enabling a shooting estate to bring it to an end at the end of the term and take the land back in hand to farm in the Estate’s own right thus reducing the amount of land available to be let to tenant farmers. It should also be borne in mind that upland farmers removing livestock off the moors in winter need grazing not just on large areas of grass but on small areas of grass as well. If the small man is not classed as an Active Farmer then large areas of grazing land will be lost to the farming community.
3. Greening
(a) It should not be compulsory for farmers to have to grow three crops. It is easy for “desk top farmers” to bring in rules but practical farmers know best what their land will grow.
Some farmers only grow one crop because the produce from that crop is fed to their livestock (poultry farmers). They will now have to grow three crops, two will have to be sold and taken off farm by lorry and feed bought to replace the loss of produce, this will have to be brought onto the farm by lorry—more CO2 emissions. No benefit there to the environment.
Some farmers grow two crops because that is what their land is suited to and fits in with their farming system.
Others farmers, usually large farmers, will have no difficulty in growing three or more crops. It may be that more than one crop is fed to their livestock (dairy farmers) with the other crops sold off farm.
What will be classed as a crop:
will only arable crops be eligible as part of a three crop rotation; and
will grassland used for hay and silage but not grazed be eligible for part of a three crop rotation.
(b) Under the present system we had Set-Aside which was supposed to produce environmental benefits but was disbanded when food prices increased. This will happen again as Governments cannot be seen to increasing the cost of food to the general public.
(c) Under the present system we have 2m margins again to help the environment but in many cases there is less wildlife, as the margins provide little or no cover for wildlife and allow predator’s easy access to catch wildlife.
(d) Is it more important to protect the environment than produce food for the general well being of the public? The population of this country is increasing all the time, more people finding it hard to afford food and more food banks setting up, but the British Government does not appear to be more concerned with food production. The British Government would rather keep the environmentalists happy.
4. Lessons Learnt
(a) The present Single Payment Scheme shows just what a complicated system “desk top” civil servants trying to farm can make. Payments are still not all paid on time. The Government has been fined for not making the payments on time. The fines should not have been paid—Europe may have objected but could not do very much—the French Government refused to pay the fine for refusing to allow British beef into France. European Governments should remember that the British Taxpayer pays more into Europe that we get back.
(b) The old IACS system was simple and easy for everyone to understand. The system worked and payments were made on time. Farmers and the DEFRA/RPA staff understood how it worked.
(c) The present Single Payment Scheme continues to have Rural Land Register mapping problems and farmers have difficulty in understanding why. The Rural Payments Agency mapping section are continually changing boundaries (many by a very small area), areas of land parcels and the areas that can be activated for payment, usually after the Single Payment Scheme claims have been submitted. It is no wonder claimants are continually having problems with over-claiming. This problem must be addressed as soon as possible or is it a way of either keeping staff employed or making sure that farmers continue to have problems with over-claiming.
(d) The main lesson to be learnt is that whatever new CAP system is introduced it must be simple and not have a complicated computer system to run it.
(e) Any money paid for Rural Development must be to some aspect of farming and not to something that does not have any bearing on agriculture.
The British Government always bends over backwards to keep the European Commission happy even though the British Government, with taxpayers money, pays into the European Union more than the Government gets back. Is it not time for the British Government to say that any changes to the CAP will in no way disadvantage British farmers even if the European Commission are not happy with that.
With the population of his country increasing rapidly it should be more important to ensure food production for the majority of the people in this country, even to the extent of being self sufficient in some foods, rather than environmental benefits which benefit to the few.
British farmers are well aware that this Government would like to do away with subsidies but would the general public be happy having to pay more for food. The farmer may get a subsidy but in fact so do the general public as the subsidy keeps down the cost of food. The Government should ask itself: do you want cheap food to help keep the cost of living down and so keep the general public happy or food production with no subsidy that forces food prices and the cost of living up.
8 October 2013