IFA Makes Submission to Eu Agriculture Commissioner Phil Hogan on Cap Simplification

IFA President Eddie Downey said IFA has made a detailed Submission to EU Agriculture Commissioner Phil Hogan on simplification and a reduction in red tape for farmers under the new CAP reform.

Eddie Downey said the administrative burden on farmers, and associated bureaucracy and red tape under the direct payment system, is very complex and challenging for farmers. He said the stress and fear associated with farm inspections, particularly unannounced inspections, has a negative impact on farmer welfare and is unacceptable.

The IFA proposals call for real reform and simplification across the direct payments system, including the inspection and cross compliance regime. Eddie Downey said the Ciolos CAP reform, with the inclusion of greening, has added to the complexity for farmers. He said the entire inspection process needs to be simplified and streamlined in an efficient and more farmer-friendly manner. “Currently farm inspections are extremely complex and bureaucratic with a full inspection similar to a forensic examination involving hundreds of questions, many of which are incomprehensible.”

Eddie Downey said the IFA submission on simplification focuses on the following key principles:

  • The simplification initiative must make a real difference to, and improve the situation for, farmers, including a substantial reduction in red tape and bureaucracy;
  • Dignity and rights of farmers to be fully restored under the inspection and cross-compliance regime;
  • A reduction in the stress associated with inspections for farm families, with the objective of removing unannounced inspections;
  • Payments across all schemes must be delivered efficiently, within agreed timelines;
  • A fairer and proportionate penalty regime, involving greater tolerances, the removal of cumulative penalties, and a reduction in overall penalties on farmers must be implemented;
  • Greater use of cost effective technologies to improve efficiencies, with a reduction in the administrative burden for farmers and competent authorities, and a reduction in the level of on-farm checks;
  • A change in focus in the audit system away from investigation and enforcement through a penalty-driven regime is required, towards fostering compliance through continuous improvement at farm and Member State level.

On inspections, Eddie Downey said IFA is calling for the on-farm inspection rate across all schemes, including land eligibility, cross compliance, GAEC and all other schemes, to be limited to 1% and that duplication under the inspection regime must be fully removed. IFA is also calling for all no-notice inspections to be eliminated and a change so that 14 days’ advance notice will be provided for all on-farm checks

On tolerances and penalties, the IFA President said there is a need for greater tolerance thresholds to provide farmers with the opportunity to achieve compliance, and avoid financial penalties in cases of unintentional non-compliance. He said IFA wants the new ‘yellow-card’ system be introduced in Ireland, whereby farmers are given a fair opportunity to correct unintentional non-compliance.

In addition, Eddie Downey said there must be a fairer and more practical approach to penalties, to take account of normally occurring unintentional non-compliances at farm level. An increase in the categories of defined breaches is required, to explicitly include unintentional non-compliance. The current unfair penalty regime is totally disproportionate and must be reformed. It must be proportionate to take account of the non-compliance involved, the compliance history of the farmer, the size of the holding and the impact on the farmer. The application of cumulative penalties is very severe and unfair. On land eligibility, there must be a minimum area of tolerance for land eligibility under the LPIS (minimum of 0.5ha on all sizes of holdings). Eddie Downey said the change in the penalty regime to impose across-the-board deductions on all schemes, where an infringement has been found in one scheme only, is very severe and disproportionate.

The IFA President said the current EU audit system is too focused on in investigation and enforcement through a penalty-driven regime. This must be changed in favour of fostering compliance through continuous improvement at farm and Member State level. A single audit approach must be adopted. Once an audit is completed, there must be sign-off, with no retrospective penalty application.

Eddie Downey said the detailed rules around the application of greening are far too complex, totally unnecessary and not understood by the vast majority of farmers. IFA has made a detailed submission on simplification of Greening. He called for a simplified approach, which is easily understood and implementable, for the mapping, locating and calculation of the area of crops and (Ecological Focus Areas) EFAs. He said the remote sensing system should be sufficiently robust to accurately interpret the EFA area on farms. Farmers should not have to reinterpret this data. A robust system would eliminate the need for on-farm inspections. All greening checks should take place at time of IACS (land eligibility) check. There should be only one check for land eligibility, Basic Payment and Greening.

IFA has also made detailed proposals on simplification under the Common Organisation of the Market, the Rural Development side including issues such as Young Farmers and farm Safety. In addition, Eddie Downey said the publication of individual details on CAP payments is an unacceptable breach of confidentiality and will expose the farming community to unnecessary security issues and additional stress.

Read the full submission


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