Greening and Double Funding April 14, 2014 12:00 am It seems possible that features entered into a Stewardship agreement may also be able to count towards greening after all. This is a significant change from what was thought likely, but is the probable approach that DEFRA will adopt. To recap, EU rules do not allow ‘double funding’ – getting paid twice for the same action. This means that a feature that has been entered into an agri-environment agreement (ELS, HLS etc.) to get a management payment should not also be used as Ecological Focus Area (EFA) to help trigger a greening payment under the BPS. How existing Environmental Stewardship (ES) agreements would interact with the greening rules had therefore been a big unknown. It should be highlighted that it is not yet confirmed, but DEFRA looks likely to deal with the issue of double funding via a reduction in agri-environment payments. Therefore, features used in ES schemes will be eligible for the purpose of EFA; this previously looked unlikely. There are approximately twenty Stewardship options which clash with EFA options, including hedgerows, ditches and buffer strips. Agreements with these options will see reduced payments. Importantly, however there are some key exceptions: ELS agreements starting before 1st January 2012 will not be affected all HLS agreement holders, including the underpinning ELS, will not be affected. Bizarrely therefore, double funding will be allowed for a large number of ES agreement holders – i.e. it will be possible for them to use hedges, margins etc. to count both towards ELS /HLS and EFA. In fact, a majority of ES agreement holders could be in this category, as most ELS agreements were signed before 1st January 2012. This seems in direct contravention of the double funding principle, but apparently there are some legislative quirks that mean that this is possible. All those with an ES agreement starting after 1st January 2012 will see a reduction in payments. Payments will be reduced even if there is enough other EFA area to meet the greening requirements. A variable percentage deduction will be applied to individual options, depending on the overlap of between the greening and ES management prescriptions. An example may help illustrate the process (note that the percentage reduction used is only for illustration). A farm has 5,000m of hedgerow under EB1 (management on both sides). This is worth 1,100 points under ELS (22pts per 100m) or £1,100. If Natural England / DEFRA decide EB1 will be subject to a 40% reduction the farm will lose £440 from their annual ELS payment. Affected ES agreement holders have three options when faced with payment reductions. They can; incur the penalty, add additional ES options to ‘top-up’ points to get back to 30 per Ha, withdraw from the ES agreement. We will await confirmation from NE / DEFRA, but if this method is adopted the problem of double funding becomes far less complicated for most.