CAP reform and single payment scheme

    CAP Reform and Single Payment Scheme

    An update.

    SPS Application
    Single Payment Scheme applications should have arrived for submission by 15th May.  It is possible that this is the last year in England when paper copies will be accepted and for ease of submission and speed of payment it is suggested that the on-line system is used, resorting to the paper submission if problems are encountered.  For the vast majority of applicants fewer than six numbers will need changing so should not be too arduous.  Do note that recent transfers of land and entitlements may not show on the paper or electronic versions.

    Entitlement activation will automatically be rotated so will not be lost through inactivation (where there is adequate land to allow this).

    Transfer of Land
    Where land has been transferred RLE1s should be completed and not simply amendments made on the application.  In the past the RPA have changed their minds closer to the SPS application date but this is not the case now.  The RLE1 notification cannot be submitted electronically.

    Recorded delivery and drop-in centres
    At present recorded delivery is no guarantee of receipt by the RPA and the RPA will not necessarily accept delivery where submitted in this way.  This is a major problem for RLE1s involving transfer of entitlements and there is no alternative but to telephone the RPA to check that delivery has been made as intended. 

    In contrast to our last newsletter the RPA have changed their drop in centres again.  These are: Carlisle, Exeter, Newmarket, Northallerton and Worcester.  They will be open 25 March to 15 May 2013, from 8:30am to 5:00pm Monday to Friday.

    Additional points
    There are few major changes this year but the most significant is that there is no longer a presumption that land “available for agriculture” is eligible to activate the entitlements.  Thus unless grazed (for example) bracken and salt marshes cannot be used to activate entitlements.  This creates the situation where land may drop in and out of eligibility between years.  We have investigated this and been told by the RPA “Salt marsh which is being grazed or has a record of being grazed (i.e. it is not sufficient merely for the salt marsh to be capable of being grazed) is eligible and can be claimed using land use code PP1.”
    The RPA has specifically stated that they are going to penalise arrangements put inplace to create artificially conditions to activate subsidy (often called ‘naked acre’ deals). 

    Dual use, where the SPS claimant and Stewardship scheme claimant differ, are still permitted but it is important to put proper documentation in place.

    Do update the Soil Protection Review in light of the waterlogged conditions and take care with NVZ rules.  The number of failures has substantially increased, forcing the RPA to undertake more inspections.

    Finally do check whether land eligibility has changed. The RPA get tetchy where an inspection reveals, for example, a new building on eligible land.

    The Future
    If the EU negotiations proceed according to plan, the new EU budget arrangement will come into place in 2014.   This may mean a reduction in subsidy prior to the new CAP reform.

    CAP reform negotiations continue at their own pace.  The three parties, member state agricultural ministers, MEPs and Commission need to iron out their differences.  The next defining moment is June and while the implementation of the CAP reform has already been pushed back to 2015 from 2014, any more hiccoughs could delay it further to 2016.  While there are areas of agreement within the groupings and between the groupings the nature of the negotiation means that even apparently settled areas may be changed.


    Key contacts

    Andrew Wraith

    Andrew Wraith

    Food & Farming

    Savills Lincoln

    +44 (0) 1522 508 973

    +44 (0) 1522 508 973