Alyn Smith, the SNP MEP, is proposing an amendment which would devolve most decision making on the Common Agricultural Policy from the member state to the sub-national authority, depending on the constitutional structure of each state.
Such a move would allow the Scottish Government to set up its own National Reserve. Critically, it would receive its own national envelope and be able to decide how much to transfer from Pillar 1 to Pillar 11, thus protecting Scottish direct payments from the UK Government's intention to transfer 20% to Pillar 11.
Mr Smith has a comprehensive list of amendments. He is also seeking to change the definition of land eligible for support payments to allow for the incorporation of a maximum of 10% of non-eligible land such as scrub, trees and bracken.
In line with the views of Scottish farmers, Mr Smith believes that direct support should only be given to those actively engaged in agricultural production.
He also opposes trading in subsidy entitlements.
More controversially, he accepts the Commission's proposal for a cap on direct payments of €300,000 – but has submitted an amendment which would allow Scotland to choose whether to use the proceeds of capping, either for investment in rural development programmes, or in the National Reserve to provide new entitlements to farmers commencing their activity. Either way, the money will remain within Scottish farming.
The Commission has proposed a "double-gate" system of eligibility for entitlements in 2014, whereby farmers would have to demonstrate the activation of an entitlement in 2011 in order to be eligible. This does not suit the Scottish situation, where hundreds of new entrants who have not received entitlements, and would hence be at risk of exclusion in 2014. Mr Smith's amendment proposes that all farmers who can prove that they actively farmed in 2011 should be eligible.
To fund the National Reserve through only top-slicing direct payments in the first year of application, as the Commission proposes, risks providing inadequate funds for distributing entitlements to all applicants. While the Commission's proposals focus distribution of new entitlements to young farmers, Mr Smith believes that all new farmers commencing their activity are worthy of such support.
His proposals for the granting of new entitlements and the National Reserve should ensure that all Scottish farmers without entitlements should have a secure route to receiving them. In case there are a few exceptions, Mr Smith proposes a special clause for the National Reserve allowing Scotland to distribute entitlements to those farmers who actively produce.
The overall effect of decoupling support, particularly in Scottish farming's more remote regions, has been significant de-stocking. To counter the current crisis in the red-meat sector caused by the loss of "critical mass", Mr Smith proposes to increase the potential for coupled support to 15% of the national envelope, not 5% as proposed by the Commission. In addition, farmed venison should be eligible for support.
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