Scotland’s livestock farmers are being urged to assess what changes they need to make to comply with the new criteria coming into force next year and avoid losing part of their payment.
Last week saw the Scottish government publish new guidance, but many livestock, dairy and mixed farmers may have assumed that greening was predominantly an issue for the arable sector, and you could hardly blame them.
After all, the country has around 2.8m hectares of rough grazing, 1.4m hectares of grass and another 0.6m hectares that is used for common grazing of animals.
However, it’s now clear that the detailed conditions attached to the greening element of the new CAP will require many livestock and mixed enterprises to make significant adjustments to their businesses to meet the rules.
Some businesses – particularly organic farms – already comply with greening requirements as part of their normal agricultural practices, in which case they won’t have to take any action in order to receive their greening payment.
On a national level, the regulations insist that from 2015 onwards the ratio of permanent grassland compared to the total agricultural area declared cannot decrease by more than 5%.
This ratio will be monitored at a national level and the Scottish government will only take action to increase the area of permanent grassland if there is a reduction, but given that Scotland’s 2.8m hectares of rough grazing area counts as permanent grassland, there is little concern on this point.
For individuals, they will need to consider the greening requirements. Greening activities include one or more of the following:
- Protect permanent grassland designated as environmentally sensitive grassland (ESG)
- Grow a minimum number of crops
- Farm 5% of the arable area in a manner that promotes biodiversity – known as an ecological focus area (EFA)
The detail of the rules is complex, but the key message from government and NFUS is to waste no time in working out if the new conditions are relevant to individual businesses and, if they are, to put a plan in action without delay.
Permanent grassland is land used to grow grasses or other herbaceous forage, such as clover, either naturally or through cultivation, which has not been included in the crop rotation for five years or longer.
In Scotland, ESGs have been defined as Natura-designated sites. Land managers will already be bound by the existing specific management agreements in place, to ensure they are sympathetically managed and protected.
It is worth remembering that if permanent grassland is ploughed or improved and sown to a one-off crop such as spring barley, kale or turnips, the land will convert to arable, and future grass will be temporary for at least five years.
Crop diversification requirements
The basic rule is that if you have more than 30ha of arable crops you must have at least three crops, with the main crop not occupying more than 75% and no two crops occupying more than 95% of the arable land area. Any additional crops must, therefore, occupy at least 5% of the arable area.
Arable land includes any temporary grassland that is included in a crop rotation.
Winter and spring crops are considered to be separate crops – for example, spring barley and winter barley count as two crops. However, oilseed rape and swedes, which are members of the brassica napus species, will count as one crop. Similarly kale, cabbage, broccoli and brussel sprouts would all be counted as a single crop type.
Fallow, temporary grass and other herbaceous forage, such as pure stands of clover, will also count as different crops.
If nitrogen-fixing crops are grown as part of the crop diversification requirement, they can also count towards the EFA requirement. These include alfalfa, beans, birdsfoot trefoil, chickpea, clover, faba bean, lentil, lupin, pea and vetch.
Ecological focus areas (EFAs)
Farmers with more than 15ha of arable land will need to ensure that 5% of the arable area is managed as one or more of the following:
- Field margins and buffer strips along water courses (applying a 1.5 weighting factor)
- Catch crops/green cover (0.3 weighting)
- Nitrogen-fixing crops (0.7 weighting)
- Land lying fallow (1.0 weighting)
As a simplification measure, the EU rules allow the use of conversion factors for landscape features such as buffer strips and field margins. These apply a standard figure for every linear metre of the feature to convert to area, which avoids the need for farmers to accurately measure the width of the feature along its full length and for government officials to have to check the measurement.
However, while this option can be used in England for buffer strips and for hedges, it is not being applied in Scotland, at least for 2015. The break-even, therefore, is a width of 6m; the English implementation being better for narrower strips, the Scottish for strips wider than 6m.
This means that in Scotland, farmers and government will have to measure width accurately, hence why those features are expected to be less attractive than they might otherwise have been.
According to the NFUS, many farmers are opting for the fallow option as it is the least complex and offers fewest intricacies, although it does require the biggest commitment of land.
Buffer strips and field margins have a higher weighting so the impact is on a smaller area, but in terms of practicalities and measurements, they make demanding alternatives. The NFUS warns specifically of the restrictions on grazing, which make these measures impractical for many livestock farmers.
Another point to note is that if temporary grass is put in fallow, the land retains its arable status for the period it is claimed as EFA fallow, even if the grass becomes more than five years old during that period.
EFA fallow, catch crop/green clover groups and nitrogen-fixing crops must be located on arable land. And while field margins and buffers can be on or adjacent to arable land, it must touch the arable land.
Scenario planning and solutions
A 120ha mixed upland farm of which 85ha is arable land (including 40ha of temporary grass) and 35ha of permanent grassland, including two designated sites of environmentally sensitive grassland (ESG).
This farmer needs to consider each of the three greening elements.
Permanent grassland: The areas designated as ESGs must not be ploughed, cultivated or improved.
Crop diversification: At least three crops must be grown. This farmer has chosen to meet the requirement with the following crops:
- 15ha spring barley, undersown with grass – 17.6%
- 20ha winter barley – 23%
- 40ha of temporary grass – 47.1%
- 10ha of turnips – 17.8%
- Total = 100%
Two main crops total: (23% + 47.1%) = 70%
For the purposes of crop diversification, there are four crops. The main crop is not more than 75% of the arable area and the two main crops together are not more than 95% of the arable land.
Ecological focus areas: To meet the EFA requirement at least 4.25ha (85ha of arable land x 5% – 4.25ha) must be managed as EFA.
This farm could meet its EFA requirement by having at least
- 4.25ha of fallow land (4.25ha x 1 = 5ha EFA) or
- 2.84ha of field margin or buffer strip along water courses (2.84ha x 1.5 = 4.26ha EFA) or
- 7.2ha of nitrogen-fixing crops (7.2ha x 0.7 = 5ha EFA) or
- 14.17ha of catch crops, of which spring barley undersown in grass could be 10ha (14.17ha x 0.3 = 4.25ha EFA) or
- a combination of these to meet the required EFA commitment.
A 200ha hill farm with 5ha of forage rape, 25ha temporary grass and 170ha permanent pasture
This farm is already “green” as far as permanent grassland requirements are concerned. As 75% of the holding is temporary or permanent grassland, there is no requirement to grow multiple crops.
The 170ha are not designated as ESG.
A 100ha dairy farm of which 20ha is in arable crop and 80ha is temporary grass
This farmer needs to consider each of the three greening elements.
Permanent grassland: There is no permanent grassland on this unit so it is exempt from the permanent grassland requirement.
Crop diversification: As 75% of the holding is temporary or permanent grassland, there is no requirement to grow multiple crops.
Ecological focus areas: As 75% of the holding is temporary grass and he has less than 30ha of arable crop, this farm is exempt from any EFA requirements.