CAP Reform – What We Don’t Know

“There are known knowns; there are things we know that we know. There are known unknowns; that is to say, there are things that we now know we don’t know. But there are also unknown unknowns – there are things we do not know we don’t know.” – US Secretary of State, Donald Rumsfeld, February 2002. 

In terms of implementing CAP reform, we can now provide a fairly comprehensive list of the ‘known unknowns’ – the areas where we are clear that more information is needed.  Most of these are now decisions for National Governments.  (Note that this analysis applies to England, and is also largely relevant to Wales.  Scotland is far behind in making its decision so there are far more unknowns  – and probably some unknown unknowns too . . .). 

The areas we have identified are;

• Level of uplift in payments in the ‘Moorland’ region in England.  Whether the Lowland and SDA regions will be merged or just equalised in payment terms.
• Detailed eligibility rules for the National Reserve (and also timings for application).
• Detailed eligibility rules for the Young Farmers Scheme.
• Precise definition of ‘Permanent Crops’ (within the Greening land-type calculation).
• Will Greening simply be a ‘snapshot’ as at the 15^th May each year?
• List of crops for ‘Crop Diversification’ – including how winter and spring cropping will be differentiated and the treatment of outdoor pigs.
• Whether DEFRA (WG/SG) will take up all the EFA options possible.
• The definition of the landscape features (e.g. when does a line of bushes become a ‘hedge’?).
• The definition of the other EFA areas including the important rules on what is a catch-crop and which crops will be counted under the ‘nitrogen fixing’ category.  Plus management rules (e.g. when can fallow be cut/sprayed/cultivated etc.).
• The interaction of EFA with areas already under an agri-environment scheme (any derogation to allow double funding for a limited period?, cut in ES payment rates?, possible differentiation between existence and management of features).
• The definitions for those on the ‘negative list’ for the Active Farmer test.  What is the timescale of determining whether a claimant is ‘active’ or not (i.e. will this done before the 15^th May 2015)?
• What land is to be classified as ‘naturally kept in a state suitable for grazing or cultivation’. 
• The minimum activity levels on such land.
• The future of ‘dual use’ in England.
• All issues around cross-border holdings.

There are probably others, but these are the main areas we have identified.  Hopefully DEFRA and the other administrations will be able to start issuing guidance on some of these matters soon, so the industry can start planning.