Common Agricultural Policy (CAP) Health Check 2008
RICS Wales comments on the draft legislative package are as follows:-
1. Further decoupling of Agricultural support
The decision in Wales has already been made in 2005 to decouple all agricultural support and we see no reason to change the present position.
2. Historic basis for Single Payment
The proposals allow the authority to review the basis on which a Single Payment was originally made and it may be that some amendment is appropriate in the future. However, we support the proposal to look at the options in due course and have a further consultation on the matter in 2009.
3. Reducing the types of SPS Entitlements
This is agreed and the removal of National Reserve Entitlements would be a benefit.
4. Time Allowed to Claim against Entitlements
The reduction from 3 to 2 years is agreed.
5. Minimum Payments or Minimum Area
The proposal for 250 Euros or 1 hectare is agreed.
6. Increased Flexibility in the Rules of National Envelopes
This may be worth further consideration and we understand that the amount of money involved can be taken from the total volume of payment not on a sector basis. At the moment it is difficult to see specific advantages of creating National Envelopes.
7. Abolition of compulsory set aside and set aside Entitlements
This is agreed that we would encourage the Assembly not to introduce major environmental regulations bearing in mind that most of Wales is pasture, as there are already regulations over hedge rows and hedge banks and further restrictions and regulations would not be welcome.
8. The Premium for Energy Crops
We have little experience of this and cannot comment thereon.
9. Simplification of Cross Compliance
We agree the proposals set out in the Consultation. If the rules on identification registration of cattle are removed from the Cross Compliance system although they are covered by a separate requirement, does that mean that breach of those rules will not result in a penalty and loss of Single Farm Payment in some form, we presume that a breach of the cattle identification and registration regulations will still render the applicant liable for a deduction on Single Farm Payment.
10. Improving Market Orientation
Of the details set out in that paragraph we consider only the Milk Quotas to be of immediate effect in Wales. Currently, with UK production heading for one billion litres under UK Quota, Milk Quotas do not feature on dairy farmer’s consideration list these days.
The economic conditions of the last 6/8 years have resulted in a huge fall in milk producing numbers in England and Wales and that fall cannot be made up by expansion plans in the remaining milk production holdings. It is likely therefore, that for the foreseeable future, UK milk production will remain under the current UK National Quota.
The other items under that paragraph are not of major significance to Wales and no comment is put forward.
