Environment, Food and Rural Affairs CommitteeWritten evidence submitted by National Farmers’ Union of England & Wales (NFU)

Executive Summary

The NFU remains disappointed with this round of CAP reform and the lack of strategic vision the policy will provide farmers in facing the significant global challenges and opportunities that lie ahead for the sector.

The NFU wholeheartedly supports the findings of the Efra select committee which in July 2012 concluded that “the competitiveness of UK farmers will be reduced if they are exposed to higher modulation rates than their European counterparts. We therefore recommend that Defra does not set modulation rates higher than other Member States that receive similar single farm payment rates.”

English farmers very much welcome reassurances from the Secretary of State that he does not intend to put them at a disadvantage by gold plating the greening rules. In our opinion, “no gold plating” fundamentally means that English farmers should not be put at a disadvantage to our competitors. English farmers should not face more costly or burdensome conditions to unlock the 30% greening aid than farmers in other parts of the UK or across the EU.

We believe that the combination of the new greening rules, cross compliance, pillar 2 measures and voluntary measures will together produce environmental benefits. The introduction of the new greening requirements as a condition of the pillar 1 payments significantly reduces the need to transfer money from pillar 1 to pillar 2 for further environmental works.

We want to see the new “greening” rules implemented simply, but fairly. Defra should work with the Commission to come up with alternative choices for farmers that not only reduce the commercial impact of the new three-crop rule but will also deliver greater environmental outcomes.

Defra should find a way to share the CAP budgetary pressures which lie ahead in a fair and proportionate manner across all farmers. Given the vulnerability and disproportionate reliance that upland farmers have on CAP support it is clear that significant quantities of future CAP resource will need to continue to be targeted to active farmers in the uplands.

Defra should provide stakeholders a holistic analysis across the suite of CAP measures, which considers the impact of the new greening rules, the impact of likely targeting of future agri-environment support and the degree of transfers from pillar 1 to pillar 2 on farm incomes across all farm types.

The NFU believes that the outcome of the EU Budget negotiations 2014–2020, most specifically the reduced UK pillar 2 envelope, means that there must be a radical rethink of Government policy, matching the ambition of the next rural development programme with the level of funds available.

All farmers want to avoid the problems of the previous CAP reform recurring and the stress and anxiety that was caused. Support and guidance to farmers will be required in all its forms and will be required from mid-2014 onwards to ensure that the industry is fully briefed ahead of the expected 2015 changeover of schemes. 

Introduction

1. The NFU represents 55,000 farm businesses in England and Wales. In addition we have 41,000 countryside members with an interest in farming and the countryside. The NFU welcomes the opportunity to submit written evidence to the Efra select committee’s inquiry. CAP is a policy which affects almost every farmer in the country. It is hugely important that Defra and RPA work hard to implement the reform effectively and unambiguously.

2. Over the course of successive CAP reforms the NFU has played a key role in supporting progressive reform of the policy. In May 2011, the NFU published a policy document for the future CAP which outlined our preferred strategy. As an organisation, we have consistently advocated policies that increase farming’s market orientation, increase farmers’ competitiveness in the global market, strengthen the position of farmers in the supply chain and remain as common and simple as possible.

3. The NFU believed from the outset that the European Commission’s proposals to reform the CAP post 2014 were a missed opportunity. Despite this, the NFU has worked and engaged tirelessly with all the European political institutions and farming organisations to ensure strong representation of our members and to take every opportunity to put the next CAP back on a path that delivers more closely on our ideals. The NFU remains disappointed with the lack of a strategic vision of the CAP which would place farmers in a more competitive position.

4. The future CAP framework has now been agreed at the European level, but within the framework there are many areas where Defra has policy choices. Government must work through these options and find a way to implement them as simply and fairly as possible. English farmers take their environmental obligations seriously, but must also be able to compete with their competitors on the EU common market. That’s why “fairness”, by which the NFU means the opportunity to compete on even terms with our competitors in other parts of the single market which constitutes 63.5%1 of the UK farm exports (by value), is at the heart of our policy on CAP.

5. The NFU fully endorses the Government’s own guiding principles2 issued by the Department for Business Innovation and Skills earlier this year on the implementation of European legislation. In particular, the guidance that officials should not go beyond the minimum requirements of the agreed EU regulations; they should seek alternatives to regulation, endeavour to ensure that UK businesses are not put at a competitive disadvantage compared with their European counterparts and ensure that there is future ministerial review.

Q.1 Views on whether the UK’s implementation of CAP might put English farmers at a competitive disadvantage to their regional and European counterparts:

6. Farmers want to get to a place where they can depend significantly less on direct support, but this requires two conditions to be met:

Functioning market and food supply chain.

Reform to be pursued equally across the EU and by major global players like the USA.

As long as British farmers continue to compete within the European single market, it is important that we remain part of a common policy framework for agriculture and that English farmers are treated fairly within that framework.

7. It is worth reiterating that the last set of reforms saw farmers in England experience more radical reform of the CAP than farmers in other parts of the UK and EU, and which saw English farmers face the largest deductions in direct payments of all EU farmers. This was due to:

full decoupling of direct support payments;

the move towards the area based payments system; and

Government’s use of national modulation.

8. Driven by our members’ concerns and the degree of implementation flexibility that was likely to be conferred on Defra, the NFU, along with TFA and CLA has formed the “Fair Deal for English farmers” coalition which brings together over 30 organisations representing the interests of farming and the rural economy in England. Specifically, the objective of the coalition has been to raise shared concerns on two central elements of the CAP reform which we believe threaten a fair outcome for English farmers, namely transfers from pillar 1 to pillar 2 and the potential for gold plating of the new environmental conditionality rules known as “greening.”

Transfers from Pillar 1 to Pillar 2

9. The recent EU budget negotiations already places English farm payments lower than the average payment of many of our main competitors (graph 1).

10. If Defra uses the powers to reduce the pillar 1 envelope by 15%, then the impact would be to move the average payment received by English farmers below all of their main competitors (see graph1).

Graph 1

11. However, the average payments in member states and regions mask the important fact that actual payments to farmers differ greatly across Europe. All our main competitors, with the exception of Germany, continue to make payments to farmers on the basis of the “historical payment model.” This means that more productive farmers are paid higher amounts by virtue of the level of activity they undertook back in 2000, 2001 and 2002. Whilst there will be limited attempts in other member states to move away from this model towards the “area based payment model”, the majority of member states have sought to minimise the number of winners and losers arising as a result of this shift in approaches. This means that farmers in other countries, with comparable levels of output will continue to receive much higher levels of support per hectare than English farmers, whose payments have been spread across land as opposed to targeted on past activity.

12. Proponents of transfers from pillar 1 to pillar 2 often downplay the extent of the current and future differences these transfers create. They are not trivial. Already a Dutch dairy farmer who continues to receive payments based on historical activity receives a payment per hectare in the order of €500/ha, a Danish dairy farmer €447/ha and even in Germany where the Government has implemented the area based approach, an arable farmer in an area such as Schleswig Holstein receives €359/ha. An English farmer currently receives €265/ha and will receive significantly less if Defra transfers up to 15% of the pillar 1 envelope to pillar 2 in the future.

13. English farmers are competing in a single market. In a year of exceptionally poor weather the single farm payment is an important element in the resilience of farming businesses. Other governments see the SFP as in part a mitigation of the more stringent environmental regulations which apply in Europe and the restrictions, ever more costly, in our use of plant protection products and other technology. Higher payment rates allow our competitors to invest in their farming operations and to enhance their competitiveness. Cutting English payments by more than our competitors will not leave us in a better position to compete. It will leave English farmers more vulnerable to the volatility we have seen in markets and weather in recent years and make businesses less resilient compared to European competitors. The impact of transferring money from pillar 1 to pillar 2 would be further exacerbated given that other member states have been granted powers to do the reverse and potentially increase the value of direct payments made to farmers.

14. Utilising data from Defra’s Farm Business Survey over the period 2005–2012 the NFU is able to show the impact on net farm incomes of South West livestock farms if voluntary modulation was increased by 6 percentage points from 9% to 15%. In low income years the effect of increased modulation has a disproportionately negative impact on the bottom line of farming businesses. The table shows that in the most recent year, based on Defra net farm income estimates, such a move would result in a decrease in farm income of 12%.

Table 1

		2005	2006	2007	2008	2009	2010	2011	2012 (f)
Lowland grazing livestock	Revised NFI	2,111	4,043	5,667	8,146	10,136	8,683	18,552	9,607
	% NFI change	-38.6%	-24.7%	-19.0%	-14.0%	-11.6%	-13.2%	-6.7%	-12.1%

Reduced Pillar 2 Budget

15. It is unrealistic to expect the CAP to be exempt from the austerity measures which have affected all public spending throughout Europe. The EU budget agreement earlier this year confirms that the UK is facing a significant budget reduction in its pillar 2 rural development allocation and will retain the unenviable position of having the lowest share of European rural development funds of all member states on a per hectare basis.

16. Defra has not provided stakeholders with this analysis despite repeated requests and therefore we rely on our own analysis drawn on various well-documented data sources to assess the impact.

17. In the first year of the new rural development programme, the UK will see its share of the available European funds cut by 16% compared to the 2013 budget, rising to cuts of 27% in the final year. That’s 22% less over seven years compared to the 2013 budget over that same period. By 2020, UK farmers will see less money coming back to the UK than they contributed by way of the compulsory EU modulation transfers in 2013.

18. Defra’s initial response appeared not to be scaling back its policy ambition but to compensate for these losses by further cutting English farmers’ direct payments by up to 15% and transferring this money across to the pillar 2 budget. The effect of which would be to save Treasury money, but also greatly exaggerate the difference in payment levels between us and competitors.

19. The NFU believes that Defra Ministers should be re-prioritising rural development spending with the aim of running measures only where they make a real difference to the productivity and profitability of agriculture. This is not the time to maintain rural development spending by reducing farm resilience to market and weather shocks with a substantial transfer from pillar 1 to pillar 2. Costly and complex schemes to deliver money back to the very same people Defra have taken the money from in the first place appears a perverse outcome.

20. The NFU wholeheartedly supports the findings of the Efra select committee which in July 2012 concluded that “the competitiveness of UK farmers will be reduced if they are exposed to higher modulation rates than their European counterparts. We therefore recommend that Defra does not set modulation rates higher than other Member States that receive similar single farm payment rates.”

21. The NFU believes that the outcome of the EU Budget negotiations 2014–2020 means that there must be a radical rethink of Government policy, matching the ambition of the next rural development programme with the level of funds available.

Greening

22. The new CAP will include mandatory environmental conditions which farmers claiming direct support payments in the future will have to undertake (so called “greening” rules). The “Fair Deal” coalition partners’ second concern is the potential risk of Defra gold plating these new environmental rules.

23. English farmers very much welcome reassurances from the Secretary of State that he does not intend to put them at a disadvantage by gold plating the greening rules. The NFU is also pleased that Defra Ministers and officials have pledged to work with agriculture to implement the new rules in a way that works for farmers, the environment and taxpayers. They have adopted the principles of the Macdonald Task Force findings for co-design. In this spirit of co-operation the NFU is working closely with Defra officials to provide input on the design of the future rules to ensure no “gold plating”.

24. In our opinion, “no gold plating” fundamentally means that English farmers should not be put at a disadvantage to our competitors. English farmers should not face more costly or burdensome conditions to unlock the 30% greening aid than farmers in other parts of the UK or across the EU. This is irrespective of whether there is a choice in the regulation for Defra to undertake alternative options or flexibilities offered. If Defra were to go beyond the minimum requirements as a condition of unlocking the 30% greening, we believe that this would clearly be contrary to the Government’s principles for transposition of EU legislation.

25. “No gold plating” specifically means to us that:

Farmers should have choice including access to the 3 European measures, with all of the options and exemptions offered within the Council regulation.

Farmers with more than 75% grassland and small areas of arable (less than 30ha) should be exempted from the ecological focus area and crop diversification requirements.

Where the requirements can be fulfilled at the national level (for example relating to the permanent grassland measure), this approach should be taken to avoid unnecessary costs on individual businesses (and farm-scale verification by the RPA).

We expect the implementation rules associated with the ecological focus areas measure to respect the European Council declaration of the 8 February 2013: “The requirement to have an ecological focus area (EFA) on each agricultural holding will be implemented in ways that do not require the land in question to be taken out of production and that avoids unjustified losses in the income of farmers”.

26. Defra can decide what counts as “ecological focus areas” on arable farms. A number of member states argued to include features such as hedges, ditches and trees as well as areas of nitrogen fixing crops. We want to see the new rules implemented simply, but fairly. This means that English farmers must have access to the same types of ecological focus areas as farmers in other countries. For example, if a French farmer was able to count his peas or beans towards the 5% ecological focus area requirement, then so must English farmers.

27. For Defra to make full potential of these greening requirements, then Ministers must also lobby for and make available additional EFA options with appropriate coefficients reflecting their environmental value to those already listed in Annex VIb to the agreed Council text. For example options could include pollen-rich margins and water protection buffers within priority catchments. Industry-led initiatives like the Campaign for the Farmed Environment could promote targeted uptake of these options. Well-judged coefficients would reduce land take while also increasing environmental benefit provided by EFA options. The Secretary of State is on record as saying he wants to introduce measures which benefit pollinators. In our view, this is the way to achieve that ambition.

28. Set against EFA-based greening we see no merit in the Commission’s crop diversification requirement. It will cause significant business disruption for some specialist growers and mixed farms. It also creates administrative burdens for farm business and RPA alike. Defra should work with the Commission to come up with alternative choices for farmers that not only reduce the commercial impact of the new three-crop rule but will also deliver greater environmental outcomes. One option may be to substitute the crop diversification requirement with an additional EFA commitment. We recognise it will be a challenge to persuade the Commission to introduce this possibility, and are ready to lobby jointly with Defra on this point.

Q.2 What steps the Government might take in implementing CAP to help tenant farmers and farmers in upland areas, and to take account of issues pertaining to common land?

Tenant farmers

29. The original CAP reform proposals raised concerns that agents of landowners could seek to maximise the in-hand land holdings of their clients. The rules on who can be allocated payment entitlements have now moved on and Defra has the option to minimise potential speculation in land holding by rolling on the existing payment entitlements. We fully support the rolling on of existing entitlements.

30. Many tenant farmers and their landowners operate “dual use” whereby the two different parties claim distinct elements of CAP support on the same parcel of land. The rules have permitted this to occur in the past and we would wish to see this approach remain permissible. Whilst the introduction of the new greening rules and the demise of the broad and shallow “ELS” may mean that these types of agreements become more difficult to operate in the future, but we believe that the flexibility should remain.

Upland farmers

31. The NFU Hill and Farming Group outlined farmers’ commitment to the hills and uplands earlier this year.3 This commitment sets out our members’ concerns and aspirations for CAP reform. Upland farmers share a long-term vision held by all farmers, to reduce their dependency on direct support payments and secure more of their income from the market. This can only be achieved through a long-term strategy that rewards farmers properly for the public benefits they deliver and through fair market returns for their agricultural products. Until these conditions can be met, substantial CAP support cannot be removed without serious damage to hill farming.

32. In 201011 over half of LFA grazing livestock farmers depended on the single farm payment to remain profitable, and while this reduced to 32% in 2011/12, the vital role of this basic payment is clear. Analysis of upland incomes 201112 by cost centre identifies that farmers in the uplands derive almost 95% of their total income from CAP payments (graph 2).

Graph 2

33. We understand that it is Defra Ministers’ ambition to “move more CAP money up the hill4.” NFU Council has discussed this ambition on a number of occasions and has agreed that Defra should find a way to share the budgetary pressures in a fair and proportionate manner across all farmers. Given the vulnerability and disproportionate reliance that upland farmers have on CAP support it is clear that significant quantities of future CAP resource will need to continue to be targeted to active farmers in the uplands. We call on Defra to provide a holistic analysis across the suite of CAP measures, which considers the impact of the new greening rules, the impact of likely targeting of future agri-environment support and the degree of transfers from pillar 1 to pillar 2 on farm incomes across all farm types.

Common land

34. The implementation of the current SPS in relation to common land has caused significant problems for some farmers in the hills and uplands. Some were not allocated the correct amount of entitlements for the common, others were told they could not claim at all and, on some commons, areas have gone “unclaimed” because rights recorded on the common land register do not sit with active graziers. All of this means that farmers actively involved in the management and grazing of upland commons may not currently receive their fair share of the SPS. We believe that Defra should consider ways in which the future national reserve can be used to allocate additional payment entitlements to farmers affected by these problems, thereby avoiding the legacy of past discrepancies prevailing in the future CAP.

Q.3 What steps does the Government need to take to ensure the reformed CAP will be less bureaucratic than its predecessor and what might prevent this ambition from being achieved?

35. It is in everyone’s interest to keep the new CAP rules as simple as possible, both for farmers but also for the RPA to reduce the risk of disallowance. As reported to us, Defra Ministers are being urged to remove all risk of disallowance from their implementation plans. While this is a laudable aim, we are concerned that strictly interpreted this may result in direct read across of Council or implementing regulations without intelligent application to the detriment of farm businesses, or indeed the environment. Defra must explore implementation choices with the NFU and other stakeholders.

36. With this in mind the NFU’s view on specific implementation choices for pillar 1 is:

Entitlements — Defra should “roll on” the existing payment entitlements. This will reduce the upheaval of having existing entitlements expire and the RPA having to reallocate new payment entitlements on the basis of land declared in 2015.

Minimum claim size — The minimum claim size should be set at 5ha. Defra analysis estimates that 16,000 direct payment claimants could be removed from the regime, reducing administrative costs and transactions for the RPA. Defra indicates that 60% of those excluded would not be commercial farms.

Active farmer — A list of entities that the EU deems not to be active farmers has been agreed. This is known as the “negative list.” The list comprises operators of certain legal entities. We are concerned that genuinely active farmers who have diversified business interests will be caught by this negative list, for example we must guard against the “operators of real estate” being interpreted to include things like farmers letting out farm buildings or cottages. We believe that the EU’s negative list should be implemented in England in a pragmatic way which causes the least disruption to genuinely active farmers.

Optional aid schemes — Defra should not make use of any of the optional aid schemes available to it. Our preference is to keep the pillar 1 direct payments regime as simple and streamlined as possible.

Young farmers’ aid — Defra should not add additional requirements to the eligibility criteria for the young farmers aid scheme.

Agri-environment Schemes

37. Agri-environment schemes form a major part of Pillar 2 activity. Currently, 83% of Pillar 2 budget is spent on agri-environment. There are real challenges in designing a new scheme that builds on current successful agri-environmental schemes with a reduced budget. The new scheme design must be clear and simple at the point of delivery. This will allow the farmer, as the potential agreement holder, to understand what is required of the scheme, know if they are eligible and be able to enter without requiring specialist support. There is a danger that scheme complexity will lead to “bid writers” to develop a successful application, without delivering additional environmental gains.

Q.4 How might the Government define the minimum activity required for qualification as an “active farmer”?

38. It is difficult to say precisely how this new rule should be implemented until we see more details in the implementing acts. In England, we believe that this rule should only apply in heather moorland areas, and even then it is questionable whether that land is naturally kept, or whether it is land that is kept in a condition by virtue of there being an agricultural activity on that land.

39. Our preference is that if it is necessary to implement this rule in England, then the requirements are kept as simple as possible. We think that this may be achieved for example by setting a minimum stocking density, but this would have to be consistent with any agri-environment obligations attached to that land.

Q.5 How should the Government ensure that CAP delivers the best environmental benefits while supporting food production?

40. The combination of the new greening rules, cross compliance, pillar 2 measures and voluntary measures will together produce environmental benefits. We estimate that the current transfer rate of around 9% would buy the equivalent of half of the expenditure under the current Entry Level Scheme and Organic Level Scheme and would retain the same level of resources for the other agri-environment schemes and elements of the rural development programme in England.

41.  In accordance with the Government’s own guiding principles5 on transposing EU legislation which encourages implementers to seek alternatives to regulation, we believe that harnessing industry led action, for example in the Campaign for the Farmed Environment (CFE) and Voluntary Initiative, will maximise the environmental value of the greening efforts by promoting informed location and management of these features and signposting to more targeted pillar 2 agri-environment commitments, especially if Defra successfully introduces farmer choice for higher value greening options alongside the basic requirements defined in the Council Regulation.

Q.6 What are the principal lessons the Government should learn from the implementation of the previous CAP?

42. All farmers want to avoid the problems of the previous CAP reform recurring and the stress and anxiety that was caused. The reality is that CAP receipts are an integral revenue stream for many farming businesses, with cash flow implications resulting from any inaccurate or delayed payments. Accurate communication and certainty of payment is most sought after by farmers.

43. The impact of change, for example the introduction of greening and the move to “digital by default” should not be underestimated. The Government should seek efficiency savings in delivery of the future CAP, but changes should not risk the validation and delivery of payments going forward and not undo the progress that has been made in recent years to rectify the problems of SPS implementation.

44. The concerns with the implementation of the previous CAP reform have been captured in the various reports published since 2006 by National Audit Office, Committee of Public Accounts, and Parliamentary and Health Service Ombudsman. Some lessons learnt are outlined in more detail in an enclosed appendix. In summary, the following issues are critical:

Develop a new IT system and processes only when the specification of the new schemes are finalised.

Understand how farmers will react to the introduction of new policies.

Be aware of how reduced resources offered by other departments shape CAP implementation and support.

Ensure the drive to digital by default does not make scheme application inaccessible.

Develop effective claim validation mechanisms that minimises duplication.

Ensure farmers have adequate support and guidance from an early stage.

Develop scheme rules appropriate to the lifespan of agreements rather than frequent reviews.

APPENDIX TO THE WRITTEN EVIDENCE SUBMITTED BY NATIONAL FARMERS’ UNION OF ENGLAND & WALES (NFU)

Implementation of the reformed Common Agricultural Policy in England 2014–2020.

Lessons Learnt from implementation of the previous CAP.

As stated in the full EFRA submission, the NFU believes that all farmers want to avoid the problems of the previous CAP reform recurring. The reality is that CAP receipts are an integral revenue stream for many farming businesses, with cash flow implications resulting from any inaccurate or delayed payments. The challenges faced by the industry back in 2005 are still recalled by many, with accurate communication and certainty of payment particularly sought after by farmers.

Progress has been made in recent years to rectify the problems of SPS implementation. However, as new policy measures are introduced alongside shifts in delivery (eg digital by default), it is essential that changes do not undermine the validation and delivery of payments going forward. The below text elaborates on the issues flagged in the EFRA submission.

1. Develop a new IT system and processes only when the specification of the new schemes are finalised

Currently there are no EU Commission implementing rules communicated to member states, yet we are aware DEFRA is now in the process of building their IT solution. Ideally, a new system would not be constructed until its requirements are fully known. In practice, the timeframe for implementation and delivery of CAP is tight. It is therefore important that the system is flexible enough to adapt to last-minute changes.

2. Understand how farmers will react to the introduction of new policies and processes

An increasing number of SPS applications have been undertaken online in the current programme period (currently approximately 55,000). This means that a relevant risk of the new IT system is how farmers and agents will adapt to any changes to the online application process alongside the new policy measures. A farmer friendly application process is integral to the success of implementing the new CAP.

3. Be aware of how reduced resources offered by other departments shapes CAP implementation and support

Clearly the next CAP must be delivered by a government department and its agencies that are required to contribute to efficiency savings. As a result, reductions in resource levels may coincide with a change in CAP policy that actually triggers increased demand for support. Online resources offer channels for more effective support, and it is critical that the operational knowledge gained through the current CAP is not lost as any resource efficiencies are implemented. Help with the completion of claims in the first year is likely to be vital for those seeking assistance. Delivery bodies need to offer multiple ways of engaging with farmers, road show events, etc;, stakeholders have a key role in facilitating this farmer engagement.

4. Ensure the drive to digital by default does not make scheme application inaccessible

The online approach to applications has many benefits (reduced costs of administration, reduced errors, enhanced checking). However, some rural areas still find it difficult to apply online with the current rural broadband provision. It remains unlikely that the rural broadband situation will be resolved in the next 18 months. We must ensure that connectivity restrictions do not make CAP schemes inaccessible.

5. Develop effective claim validation mechanisms that minimises duplication

In conjunction with the IT systems, it is essential that validation processes are tested thoroughly prior to implementation. In addition, based on previous experience, in-house expertise is preferable to a reliance on external developers to support IT and checking systems once they are operating. Whole claim validation carried out by as few staff as possible would be the preference. Task based working created many challenges in the run up to 2005 payments being made. There remains scope to further integrate Pillar 1 and 2 validation. Mapping issues have been well documented in the current programme, so factoring in appropriate resource to deal with the recording of greening is vital.

6. Ensure farmers have adequate support and guidance from an early stage

This will be required in all its forms and will be required from mid-2014 onwards to ensure that the industry is fully briefed ahead of the expected 2015 changeover of schemes, particularly in relation to greening. All potential claimants will need a core base level of clear and user friendly information in 2015 and such information would ideally be provided in paper form in the run up to the first year of the new scheme. There is a need to invest in the transition to the new schemes, which can be a platform to build on over time, in terms of value for money delivery—if farmers understand the new schemes from the outset then there are likely to be fewer compliance issues, which helps minimise costs of validation, inspections, etc.

7. Develop scheme rules appropriate to the lifespan of agreements rather than frequent reviews

Agri-environment schemes have been well received by famers, as demonstrated by the uptake. Yet as the scheme has developed, the detail has been refined either to clarify rules or ratchet up scheme requirements. For example, since 2007 there have been three scheme handbooks issued capturing these changes. This has led to different rules applying depending on which date the agreement started. Going forward there should be a clear ambition to get the scheme rules right from the outset and reduce the number of changes made through the lifespan of the agreements.

October 2013