Oh no, I hear you sigh, not another opinion piece about CAP reform.

Countless commentators have penned their views on previous amendments to European agricultural policy and this recent reform is no different.

While I can’t recall their every word, I can be sure that none concluded with “Bravo to Brussels and all involved with this round of CAP reform – they should be applauded for their innovative and inspirational vision”. Ditto, I doubt any ended with “British farmers won’t know what to do with their time now that so much bureaucracy has been removed by this reform of farm support”.

There also appears to be a lot of jargon – greening equivalency, flexibility, agri-environment climate schemes, oh and a return to MAFF (multi-annual financial frameworks, if you must).

Aside from the disagreement between the NFU and DEFRA secretary Owen Paterson over the proposed national modulation rate, I am concerned by the emphasis on penalties, especially those associated with “greening”. Not a gentle tap on the wrist, but punitive electronic ankle tag equivalents.

I would describe myself in commissioner Ciolos’ words as ecologically focused. ELS, HLS, LEAF – you name it I have an acronym for it. So why, 18 months before any of these reforms are implemented, do I have visions of a dog’s dinner of a compromise where those already committed to environmental schemes may be expected to do more – not to satisfy the needs of the environment, but to placate the bureaucrats in Brussels. I pity those at Natural England who will no doubt bear the sharp tongue of many a farmer as they try to roll out these amendments.

I understand the reform of the CAP isn’t simple, but there is too much emphasis on policing the conformists than addressing simple measures to police and penalise offenders who blatantly flout the law to the detriment of the environment. An RPA inspection may spend weeks trying to find a missing skylark plot, but when was the last time you heard of a fly-tipper being brought to account?

Perhaps some simple spot fines would heighten the public’s value of the countryside; they could also raise the profile and understanding of current environmental stewardship. Why doesn’t (and this suggestion is partly tongue-in-cheek) fly-tipping in the countryside carry double the fine that it does in the towns? Quite simply it has a greater impact on the environment.

Walking dogs on ELS margins should be an offence, and where there are signs inviting dog owners not to, they should pay a spot fine. Anyone who then proclaims that they are allowed to wander all over agri-environment land because of their “right to roam” should pay triple for being an ill-informed idiot.

There should be a tolerance (which for purpose of simplicity let’s call the “common sense tolerance”) for farmers who have narrowly missed EFA targets. Any RPA official who sends out a letter warning a farmer that they may be liable to a fine for claiming 0.01ha too much should be subject to a counter fine of half a day’s wages for overzealous interpretation of the rules and not recognising the cost of imposing administration.

If Ciolos and Paterson want effective ecological intensification, they should buy a Eurorail ticket and spend three weeks travelling around Europe to see which member states are over-delivering and which are under-delivering. Perhaps then they would realise where they should focus their policing methods.

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