LFA support must go to supporting sustainable land management
The Less Favoured Area (LFA) scheme is a longstanding measure of the Common Agricultural Policy. In place since 1975, it provides a broad-scale mechanism for maintaining the countryside in marginal areas.
The current Rural Development Policy (RDP) includes a significant evolution of the LFA support scheme. Previously the scheme had been a subject of concern for the European Court of Auditors. Within the new strategic approach and taking into account the Court of Auditors' concerns, the aid to farmers in areas with handicaps became part of Axis 2 of the RDP, which aims at improving the environment and the countryside by supporting sustainable land management.
However in 2005 the Council could not find an agreement on a possible Community wide system for LFA classification more in line with the new policy objectives. It was decided that the Commission would undertake a review of the LFA measures implementation and present in 2008 a report and proposals concerning the future payment system and designation of LFAs for a Council decision.
Key points from the EFNCP response:
- LFA is central to the achievement of the EAFRD Axis 2 objectives, so the LFA reform must result in a robust and easily defensible set of rules which can play a strengthened role in the CAP over future programming periods.
- LFA payments should aim to support farming that is a) handicapped by natural conditions and b) operates within these physical handicaps in such a way that ecological values are conserved (“sustainable land management”).
- Criteria for setting the boundary of the LFA should be transparent and rigorously enforced, but should not be tightly drawn. Effective targeting of LFA payments is best achieved through farm–level eligibility criteria.
- Criteria for farm eligibility and for setting payment levels should be drawn tightly. They should be set at Member State level but conform to a set of common EU guidelines, and be clearly related to Axis 2 objectives. Criteria which are unrelated to Axis 2 objectives, such as a requirement to be a full-time farmer or being below the age of retirement, should be disallowed.
- Farms which are not disadvantaged, or have been able from market returns or CAP support to overcome the natural disadvantage of an area through intensification, should not receive payments, whether or not they fall within the LFA boundary. In many cases, the intensified farms within LFAs have been heavily subsidised by the EU taxpayer to be better able to respond to the market, and in doing so to move away from providing public goods in the strict sense1. Examples are farmers using irrigation (other than certain very localised traditional systems, particularly flooded meadows), polytunnels or whose farms are dominated by agriculturally improved grassland.
- Eligibility rules and the requirements which applicants must fulfil should be clearly separated in the logic of schemes. For example, an eligibility rule might be that a certain percentage of a livestock farm’s forage area should be under semi-natural vegetation. To ensure sustainable land management, a maximum stocking density limit might be applied as a requirement.
- Sustainable land management should not be interpreted merely as compliance with GAEC and SMR. The LFA have particular fragile environments and the conservation of these environments depends on the continuation not of farming in general, but of specific types of farming, generally characterised by a low intensity of input use and land exploitation. The LFA cover vast areas and funds are limited, so eligibility criteria and payment scales should aim to target most support on the types of farming that are best placed to deliver the environmental priorities defined for a given LFA.
- Payment levels must be closely aligned to the requirements and to the cost of meeting these requirements in the specific natural conditions in which the farm operates. For example, an LFA scheme requiring farmers to maintain a minimum grazing density of 0.15 LU/ha should have payments calculated only on the basis of the direct costs of maintaining that required density of livestock, whatever the actual stocking density on the claimant farms. Schemes which in the past have not followed this rule have ended up paying significantly higher payments to less disadvantaged than to more disadvantaged farms.
- All payments within a particular scheme should aim as far as reasonably possible to compensate additional costs and income foregone to the same extent and in the same proportion in all areas; Member States should be required to demonstrate this in RDPs.
- A high proportion of semi-natural vegetation2 in the total forage area of a farm (including all seasonal, short-term and common grazing land) is an indicator that a farm is disadvantaged and also that the farming is highly relevant for environmental goals. For livestock farms, the proportion of semi-natural forage should be a criterion for both eligibility and the setting of payment levels. This is the best way to link the LFA measure to the delivery of the HNV farmland objectives of Axis 2.
- Many Member States have a semi-natural grassland inventory, which some have incorporated into their LPIS/IACS systems. Others have cadaster-based systems which can be adapted to give information which better identifies semi-natural vegetation. As part of their preparation for the new LFA measure (and to facilitate their monitoring of the HNV indicators in their RDPs), all Member States should ensure that their LPIS/IACS system is able to identify all semi-natural farmed vegetation used by farmers (including grazing land off the UAA).
- As for all CAP support, the basic requirements of the LFA scheme should be the minimum specified in GAEC. Some aspects of GAEC are not adapted sufficiently to the realities of farming, particularly in the LFA, and do not ensure sustainable land management in their current form. For example, farmers should be required to demonstrate that their use of land and water complies with legal requirements. Currently, farmers using land and water illegally are able to receive CAP payments. This is a significant concern in some LFAs in Southern Europe.
- In order to address the GAEC issues concerning “Minimum level of maintenance: Ensure a minimum level of maintenance and avoid the deterioration of habitats” (Annex IV of Regulation 1782/2003), Member States should not limit their standards to “preventing the encroachment of unwanted vegetation”. It is important to include standards that define “Minimum livestock stocking rates or/and appropriate regimes” (as stated in 1782/2003), in terms of the active management (grazing and/or mowing in the case of semi-natural vegetation) that is required to avoid deterioration of the habitat in question. A requirement merely to “prevent unwanted vegetation” is not sufficient to ensure the continuation of the range of environmental values associated with an active farming system. However, the necessary tightening in cross-compliance criteria must be matched by improved targeting and more tailored payment calculations in LFA schemes and better use of Pillar 1 support.
- The interaction of the LFA measure with agri-environment measures and also with SFP and Article 69 measures should be made explicit in the RDPs, with a clear justification of the costs and benefits being paid for through each measure.
- Remoteness from markets and key services should be included in the set of natural factors recognised as leading to disadvantage. Remoteness is clearly a natural and physical factor beyond the control of the farmer and is as important in defining marginality as the other factors proposed by JRC.
- We do not support an approach which involves attempting to map and delineate HNV farmland areas, either as a suitable tool for targeting support at HNV farmland, or as a substitute for LFA boundaries. The HNV farming concept is not best applied through delineation of areas, but rather through farm-level criteria. Furthermore, the concept tends to be interpreted purely in relation to biodiversity values, whereas sustainable land management in the LFA is concerned with a wider range of environmental issues (e.g. soil conservation, fire prevention). Therefore we do not support Option 4 of the consultation document.
- With the caveats referred to above and explained in more detail below, EFNCP supports Option 3 as the most likely to deliver the aims of the LFA reform, by ensuring the application of robust eligibility criteria focused on sustainable land management, within a common EU framework.
1) Public goods are services which people cannot be prevented from using (non-excludable) and/or ones whose use by one person does not diminish the value of the resource for another (non-competitive). Thus, though public goods may in theory be valued by society, and though they certainly represent a service for society, the market mechanism cannot provide an incentive for their provision. Thus goods and services desired by the public include both Public Goods and private goods. A beautiful landscape is a public good; a fine artisan cheese is not, but the maintenance of the cheese-making tradition in the absence of a market might be.
2) Specifically semi-natural vegetation (including grazed scrub or woodland), as distinct from permanent pasture or grassland in general.
The entire response on the Forum can be downloaded:
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