The Scottish government’s final CAP submission plans to the EU have come under fire for a lack of detail on ecological focus areas (EFAs) and changes to cross-compliance rules.
The criticisms were made by NFU Scotland, which said that the lack of information on outstanding questions meant growers would be second-guessing the rules when it came to crop planning. And the union added that could lead to greater cross-compliance risks.
Last week, the Scottish government confirmed that standard greening requirements around crop diversification would apply for 2015, because time had run out for a tailored package for Scotland, although the intention remains to introduce specific measures for 2016.
The union said the latest announcement failed to answer outstanding questions on EFAs.
NFUS president Nigel Miller said: “Scotland’s growers need to make decisions now and it is here that much more detail is sought. It is essential that it will be in the guidance which the Scottish government is intending to send to producers shortly,” he said.
“The fact that nitrogen-fixing crops have come through as an option may be an important EFA solution on many farms and the promised buffer strips and field margins open up some significant flexibility to draw in hedges and ditches and other landscape features under those prescriptions.
Mr Miller added: “These two boundary features carry a weighting of 1.5, which emphasises their value – not just as a biodiversity reservoir but underlines the vital role they play in connecting habitats across farmland.”
He compared the options offered in Scotland with those available in England and said it was “unfortunate” that the use of conversion factors, which have been put forward by Europe to ease the implementation and audit of EFA features such as buffer strips and field margins, have not been adopted in Scotland.
“Defra will use these when working with growers south of the border and Scottish growers would have benefited from that approach,” he said. “That will put extra compliance pressure on Scottish producers and may mean more Scottish productive land is ruled out of production to meet EFA requirements.”
Mr Miller said that other critical details around greening requirements were yet to emerge.
“Any additional environmental management requirements to be attached by Scottish government to the growing of nitrogen-fixing crops as part of EFA requirements must be made available as quickly as possible if this is to be a viable option for growers,” he said. “We note that Defra is not imposing any management restrictions on growers who choose to use this option south of the border.”