The Federation responds to CAP consultation

The Federation has responded to the Defra consultation on the future CAP. Below are some of the main points we made.

  1. Basic payment must go to active famers:

Underpinning our response to the consultation is the aim of the Federation of Cumbria Commoners  to support the active, responsible management of common land by active commoners. We understand that  basic payments are to help active farmers better respond to market demand, to support their income and to maintain land in GAEC. We are particularly critical of basic payments paid to those who do not contribute to increasing agricultural productivity alongside maintaining the environmental value of land. The passive holding of land (which includes common land)  is not sufficient to justify payment of tax payers money.

  1. Rules for claiming basic payment on common land:

The consultation document states that the rules for claiming direct payments on common land are not agreed. We want to see rules for claiming direct payments on common land that do not allow 'naked hectares' by ensuring basic payment is paid on the whole common. Also an ability to change the distribution on a year by year basis as commoners circumstances change to avoid the basic payment  being seen as a pension top-up.

  1. Moving the money uphill:

Equalisation of base payments and an uplift in moorland payments is critical to the continued viability of upland and common farming - it is after all only seeking to ensure a status quo as UELS (previously HFA and HLCA) money disappears. However, Option 2 does not compensate for the loss of UELS on commons above the moorland line. The proposed cash increase of €25 is less than current UELS payments of £23/ha on moorland parcels of 15ha or more. We request that the increase in upland direct payments equates as a minimum current direct payments + UELS payment.

  1. NELMS and landscape approach:

We have extensive experience of multipartite agreements on commons. They are hard, expensive and time consuming to negotiate and difficult to deliver and this is between farmers who already undertake a level of collaborative working such as gathering sheep off the common.  We find it  disappointing that the designers of the new scheme architecture do not seem to have taken on board (or perhaps not even sought out) the experience and the lessons learnt from delivering AE schemes on commons. In our view this approach is fraught with difficulties and risks and is very unlikely to work. Please re-think it.

You can download our full submission