Common postiton of Czech NGO to CAP legislative proposals
Actual Common Draft Position of the Czech NGOś, concerning future CAP Reform, Proposals
Actual version dated 28th November, 2011.
I. Direct Payments
1. Capping:There are no arguments in favour of recent proposals concerning possible capping in the future. We cannot accept argument saying, that without capping, the CAP budget would be decreased. As we do assume that there are no guarantees for the future to come which can eliminate possible changes in the EU-CAP budget with consequent negative impact on the Czech enterprises.
We have to remind negative statement of the German Prime Minister Mrs. Merkel, who represents the biggest country contributions into EU budget. Most probably Germany can be in favour of budget decrease, but from her point of view the capping can be understood as the act of hostility. There are following arguments, which support our refusing of future capping:
Direct payments for large enterprise are legitimate. These subjects are active in agriculture production, meets GAEC and cross-compliance rules as well as others farms, so they are entitled for direct payments, too.
Size of agricultural enterprises in individual MS is subject to their historic development and is not influenced of their own will. Therefore any capping means further penalization and discrimination of large size enterprises and of some MS and unequal EU market access.
Implementation of capping would lead to further administration burdens and to increased bureaucracy within the CAP; such approach would undermine competitive position of European agriculture.
Planned capping would create further discrimination of large size enterprises, would cause loss of productivity, job creation in rural areas and would make further innovation process impossible.
It is necessary to add, that NMS accession process was influenced by Berlin Declaration-1999, thus prevent them from full direct payments to be received. These countries were given on political and on working level as well promises, that discrimination in upcoming CAP period is to be eliminated and no other form of such discrimination would be taken into consideration while discussing future CAP reforms. Actual proposals of EC do not guarantee previously given promises.
We also have to say, that plans for future capping are not welcomed unanimously on all EU levels, however EC has been trying to push through this proposal recently.
If it will be inevitable to accept EC proposal for capping, it is of the most importance the future definition of capping should contain following parameters:
- To increase upper ceiling per one agricultural holding for 100.000 EUR in comparison with actual proposal, which is oscillating from 150-300.000 EUR, it means amount between 250-400.000 EUR,
- To allow to ascribe to the ceiling all personal costs of all agricultural holding employees in the previous year,
- Not to use in capping definition cohesion and interconnection of individual enterprises, which is predicted in small and medium size farms proposed directives. Such a step would negatively influence Czech agriculture. Capping should be targeted on individual independent holding only.
2. Greening:
- We cannot accept proposal for mandatory 7% of UAA of individual holding to be dedicated for ecological set-aside. This requirement goes directly against actual situation in EU, where the quantity and high-quality production of food and food safety for the future to come is a must. Simultaneously, if we want to meet criteria connected with EU target of 20% market share of renewable energy sources, the agriculture and farmland areas play important role. If we are going to meet these targets the “green” NGO requirement concerning stop of construction of new conventional and atomic power plants cannot be met.
- We require voluntary approach to greening. Under voluntary scheme we have to understand the possible penalization of farmer who has voluntary decided not to meet greening requirements, but up to certain part of total payments entitlements. Basic direct payments scheme has to be paid him in full.
- We require all unused direct payments funds for greening to be transferred on EU MS national level into funds for rural development as proposed in capping.
- To define precisely, what does it stand for word “crop” in term “crop rotation”?
- After respective analyses to implement under category fallow land areas, which are not managed under LPIS and no subsidies under SAPS scheme are granted now a days on these areas. In Czech Republic there are some 4,2 mill. of farmland of which about 3,5 mill. hectares are managed under LPIS rules and SAPS schemes.
- We strongly oppose additional payments deducted for further greening from national financial budgets out of CAP. Such an approach would create further un-equality and differences on EU Common Market.
3. Coupled payments for sensitive commodities connected with production:
We welcome coupled payments for sensitive commodities, which help to keep stability on market with agricultural products and employment in rural areas. Sensitive plant and livestock commodities are those production of which requires higher human and labour potential.
- We require add on list of sensitive commodities also pigs and poultry. These commodities are sensitive ones in majority of EU MS and have great impact on employment and on social stability in rural areas. For example, in Czech Republic before accession, were some 300.000 sows, today we count less than 100.000 animals.
- We do not agree with proposed level of coupled payments in EU MS (from 5 up to 15%). We require unified level of support at minimum level of 12%, ideal should be 15% of support level.
- We also require elaboration of unified-harmonized level of possible supports of sensitive commodities from regional, national or other sources out of CAP financial funds. Such a step influences agricultural enterpreneuring in large scale now.
- These coupled payments cannot be ring fenced with increase of agricultural production in comparison with the year 2013; this act would be extremely disadvantageous for the Czech Republic. Another possibility is to eliminate such a option, or to compare it with our agricultural outputs at the moment of Czech Republic accession to EU.
- It is inevitable to solve problems of another commodity as sugar beet-this commodity cannot form part of proposed coupled payments with production due to fact that this commodity would exploit major part of available financial funds.
4. Payment entitlements for direct payment scheme:
- We rather prefer not to introduce new model, but to continue in already tested SAPY scheme.
- There is no need to block financial sources creating 3% financial reserve; this situation can be solved with help of transfer from seller through reserve to buyer in the same volume as there are no changes in area (hectares) of farmland thus 3% blocking is not inevitable.
(What is the role of the reference year 2011 and how to solve change of eligible area in period 2014-2020?).
5. Others-within 1st pillar:
- We express our disapproval with definition of “active farmer” as subject with 5%of subsidies arising from non-agricultural activities. This can be problem in some farms getting low amount of direct payments-pigs breeding, for example. Therefore we require define active farmer as subject with ratio of incomes arising from agricultural primary production to total amount of incomes for farm-holding, which is entitled for 10% of subsidy.
- We ask to keep voluntary principle of 5% direct payments to be transferred in favour of LFA in given MS, but we do not recommend to apply this principle in Czech Republic.(?)
- We agree with increased level of support for young farmers, but we cannot accept proposed percentage from total amount of payment entitlements. Such an approach can cause (in some member states-MS) not sufficient use of financial funds due to limited number of young farmers- in Czech Republic, too. Therefore we require to set-up support of young farmers after submitting of respective applications.
II. Second Pillar- Rural Development
1. Financial envelope for member states:
In comparison with the CAP 1st pillar, no EC proposals have been published so far. Because of the long transitional period for equal and fair redistribution of direct payments among all the EU member states in 1st pillar, we ask for adequate (financial) compensation in form of increased amount of financial funds in rural areas development envelope, because of the fact, that low level of assets per one hectare, or high outsource financial capital should be balanced.
2. Large size holdings limitation:
- We strongly oppose with limitation of large size enterprises (holdings) in RD programmes. That it is not acceptable from point of view of proposed capping to continue in further restrictions of large size enterprises in RD and across the whole food-chain.
- We strongly oppose LFA delimitation and cutting of direct payments; such a measure is not advantageous for the Czech Republic.
3. Common Strategic Framework:
- Within the frame of this new mechanism it is necessary to define role of administrative bodies- ministries of agriculture to avoid separation of RD programmes from agriculture itself.
- Clearly set up which part of future investments in rural areas should be covered with help of RD financial funds and which part is to be financed by others operational programmes in order to avoid duplicity in financing.
4. Others-RD measures:
- We do not agree with proposed “performance reserve”.
- We ask for advance payments for investment in RD programmes.
