CAP simplification – farmers have a big part to play

EU Commissioner Phil Hogan announced another wave of CAP simplification measures last week. What will the proposed changes actually mean for farmers in 2016?

The focus in recent weeks has been on farmers who have not been paid their 2015 basic payment. Preliminary checks will have the biggest impact in reducing payment delays.

It would allow farmers to make corrections to their applications for up to 35 days after the final date for submission without penalty.

The Department is likely to commit to the preliminary checks. Farmers actually have the biggest part to play to make it a success. To really make an impact in 2016, a number of areas should be implemented.

First come - first served

Let’s say the online application opened on 15 February. Farmer John submitted his application online that day. Farmer Jack, however, waited until the last day, 16 May, to submit his paper application. Should they expect the same service?

With entitlements now established, farmers who submit online applications early should get priority in both preliminary checks and clearance for payment. That way, there is a big incentive to submit applications early and online.

Move to 100% online applications by 2017

A move to 100% online will have the biggest impact in reducing penalties and speeding up payments.

Dual claims or over claims, the two biggest issues, could become a thing of the past, as with everyone online an issue would automatically trigger a flag in the preliminary checks.

Farmers notified could make the changes. Since it was introduced in 2007, online applications have grown dramatically, to nearly 70% in 2015 (see graphic).

The older generation and tillage farmers were the slowest to move online. Tillage farmers were pushed into it by online greening requirements last year.

Better communication

The biggest frustration for farmers is not knowing how the processing of their application is progressing, especially when their payment is delayed.

The Department should be more proactive on the online system. This could involve a simple guide as to what stage your application is at. It would start with the application being lodged and allow farmers to follow it through the process, ideally with a green light on those ready for payment when they are finished being processed.

Yellow card

Attempts to bring in a yellow-card system under the Charter of Farmers Rights were abandoned last year, when it was discovered that it would leave farmers found with minor breaches worse off.

To me, a yellow-card means that a farmer gets a warning that what they are doing is not right. There is no further action, but if they are found in breach again they would then be penalised.

Commissioner Hogan’s proposal appears to give a reduced penalty for the first offence, in addition to being red flagged for further inspection the following year. More tweaking is needed on this one.

Simplifying the penalty bands

This proposal does away with the currently penalty bands for over declaration and replaces them with a simple penalty of 1.5 times the value of the over-claim. What still stands is there will be no penalty if the over claim is less than 3% or 2ha. This is a big step forward. In the example given by the Commission, the small farmer has 10ha but declared 11ha.

The payment would be reduced to the actual 10ha, to which the farmer is entitled, and he is penalised twice the difference. Therefore, as it is a 10% over-declaration, ie 2ha, the farmer would be paid for only 8ha of the holding.