Mr Capoulas Santos, by taking on board proposals from Alyn, has provided welcome relief to Scottish hill farmers by definitely including heather in eligible land for grazing through the deletion of the word "herbaceous"; he has also streamlined the definition of "active farmer" by removing the controversial and bureaucratic "income test", and retaining the ability of authorities to set minimum activity requirements.
"After months of abstract discussions, it's great that we finally have concrete proposals to get our teeth into. My congratulations go to Luis for recognising some of the major problems in the Commission's proposals which would cause significant difficulties for Scottish farmers. In particular, given similar proposals in European Council working documents, I think we can safely say that our upland livestock farmers have nothing to fear about being excluded from direct payment due to the definition of pasture. This is a textbook example of the legislative process and due scrutiny and discussion working as they should do.
"Similarly, I think that the reforms to the "Active farmer" clause will help exclude the worst abusers of the system (although nothing has been done yet about the free market in entitlements) through a "negative list". I believe also that the proposal to continue to allow the old criteria for LFA to be used until a new Commission proposal in 2015 will give us the time we need to ensure that the new system is fit for purpose. Coupled support will continue, which is critical particularly for our beef producers.
"There's clearly still a lot of work to be done. A number of Scottish interests have not been recognised yet, such as the need for a system of entry into entitlements that gives new entrants equality of access from day one; the need for more flexibility in greening options; the need for proper Scottish control of important aspects of the scheme, such as how much voluntary modulation is needed; and the need to extend the "young farmers scheme" to all new entrants. But we'll be working on that, and submitting amendments to those ends.
"Our amendment deadline in the Agriculture Committee is 9 July, and I urge all Scottish farming and rural organisations interested in participating in the process to get their ideas to me as soon as possible."
According to these reports, Scottish authorities will be able to fund the National Reserve for entitlements to new entrants every year through a top slice of direct payments. Greening will also be simplified for smaller farms through the requirement only to plant 2 crops for diversification if the farm is below 20 hectares, and the exclusion from ecological focus areas (EFA) for the same farms. Farms with agri-environmental schemes or certified environmental schemes will be considered as automatically eligible for the green payment.
On the other hand, the rapporteur did not opt for a "menu approach" for greening, which would have allowed Scotland some flexibility in choosing the right measures to achieve ecological and environmental transformation of our farming in the most efficient and sustainable way. Furthermore, his extension of the "flexibility mechanism" (the ability of Member States to transfer money from Pillar 1 to Pillar 2) to 20% of the national envelope threatens to de-fund direct payments to Scottish farmers, at a time when the UK Government are clear that they see no future for Pillar 1 and want to shift maximum money to Pillar 2. Finally, Capoulas Santos has done nothing to help new entrants without entitlements to gain access to the new system on a level playing field from day one.