Letter to Commissioner Hogan - My Concerns and Reccomendations on Greening Reform

Today I wrote to Farming Commissioner Hogan on my concerns regarding current Greening Requirements faced by Scottish and British farmers and my thoughts on where there can be reform.


Dear Commissioner Hogan,

As you are aware, one of the most controversial aspects of the current CAP is the 'Greening' requirement faced by British farmers. In particular, the issues surrounding crop diversification and EFA qualifying features have provoked much concern in the agricultural sector.

British farmers, who primarily operate a 'crop-rotation' style of farming, believe that the crop diversification measures of the current CAP- designed initially to avoid monoculture  of crops,  goes against the aims of simplicity, market orientation and increased efficiency.  The NFUS has stated that the three crop rule, "forces Scottish farmers away from established markets, such as malting barley, and instead of being market-focused in the crops they grow, look to plant other crops simply to secure the greening element of the support available."

This view is backed by environmentalists who state that the new requirements, when compared to traditional rotational planting, will not add diversity to an already mixed landscape.  The preference of British farmers, as outlined by the NFU and NFU Scotland is for those farmers affected by crop diversification rules (such as barley farmers supplying the Scotch whisky industry) should have an alternative greening option in order not to lose out on important pillar 2 support.

On the criteria associated with defining which areas on farms are eligible for 'Ecological Focus Area' (EFA) status, the view of British farmers is that they are too complex. An example given by the NFU is as follows, "When an EFA eligible hedge runs around a field of nitrogen foxing crops, fallow or catch/cover crops the claimant is required to make a deduction. However, in practice these features are unlikely to physically overlap." The requirement to make a deduction in instances like this should be removed.

Progress in these areas would represent a step toward a more workable CAP.

Yours sincerely,

Ian Duncan