Active Farming Requirement will change landscapes
CAP reform has introduced area based payments for which only active farmers who can demonstrate that they are actively farming will be eligible. The Scottish Government estimate that this will remove approximately 600 000 hectares of inactive land from the grant supported sector.
The requirement for active farming will also have an impact on the ground that remains within the CAP supported sector. This should be seen in combination with the current push for Land Reform and the Reform of Agricultural Holdings legislation which will alter the basis on which the tenanted sector operates.
An active farmer is one who has activated SFP in 2013 or can provide evidence of farming activity and who is not on the Negative List. The Negative list now includes sporting estates. There are 3 options which would allow a business on the Negative List to demonstrate that it is an active farmer.
1. The annual amount of direct payments is at least 5% of total receipts
2. Receipts from agricultural activities represent one third of total receipts
3. Prinicipal business is agriculture proved via foudning documents or affadavit from a legal adviser.
The likelihood is that a number of sporting estates would fail this test, and that others will pass it only to fall at the active farming / cross compliance hurdle. The good news for those that bought SFP entitlements or land with SFP entitlements is that there may well be a tax advantage at the point where they become worthless.
An active farmer must also either produce (rearing or growing) or maintain in order to demonstrate active farming. The new payment should "be allocated to the person enjoying the decision making power, benefits and financial risks in relation to the agricultural activity on the land for which such allocation is requested". This is likely to exclude those only renting out land, it is also likely to have an impact on some current contract farming arrangements.
In Scotland land which is described under the new CAP as being "naturally in a suitable state for grazing or cultivation" will tend to be rough grazing. It is likely to be in payment region 2 or 3. Under the so-called Scottish clause this land will now have to meet activity requirements. This is likely to mean either a minimum stocking density of 0.05 units /Ha for 183 days per year or the business could undertake an activity plan. Options include carrying livestock at a lower density in line with the capacity of the land or specificied souming, the carrying out of bracken control and membership of and compliance with a farm assurance scheme. There is a commitment accross the regulated sector to use these requirements to try and ensure that BPS payments reach those actually working the land.
In practice the loss and dispersal of hefted flocks under the previous CAP regime may well make it difficult to bring previously farmed region2 and 3 land back into production. Estates which have allowed their infrastructure to fall into disrepair may be facing a dilemma. The payments for Region 3 are likely to be minimal in comparison to previous entitlements and are designed to be topped up with LFASS and the Voluntary Coupled Support schemes for Sheep and Beef. In order to qualify for support it would not just be necesary to restock the ground. There will also be requirements for shepherds, dogs, handling facilities, record keepers, storage, fencing and a hundred other things. The hills themselves are often in a very different condition to that when they were last stocked. Bracken can be sprayed but dense scrub, gorse, bramble and the bogs created by unmaintained ditches can all present hazards to stock not previously present. Land that has not been grazed for long periods in unlikely to support the stocking density it previously carried.
Some businesses are going to discover that a few years of neglect have undone the work of generations in creating these essentially manmade landscapes. The cost of repairing the damage done will be high, in some cases it will be unfeasibly high. It remains to be seen how many hillsides will not be restocked.
Perhaps we should be grateful this shift in policy has come in time to save some of our most precious landscapes. Hopefully CAP reform will at least go some way toward placing the skills of active farmers at the heart of farm businesses. When the next round of food security and shortage scares arrives it may look like too little too late but it is a start.
