Miljø- og Fødevareudvalget 2015-16
MOF Alm.del Bilag 337
Offentligt
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Simplification of the CAP
We fully support the initiative on simplification of the Common Agricultural Policy.
We all have a common interest in simplifying the legal framework to cut red tape
without losing focus on the overall political objectives.
It is of common interest to farmers, Member States and the Commission to have a
clear and simple legal framework.
Administration of EU subsidies costs considerably more compared to other national
subsidies. It is worth noting that the annual cost of the administrative burden in ag-
riculture in 2014, that is prior to the new reform, was around €5.3 billion as men-
tioned in the
State of play Briefing.
It is reasonable to speculate that the administra-
tive cost has only gone up following the new reform.
There is a need to have a close look on what can be done in the short term, medium
and long term on simplification. Please find below suggestions on simplification that
from a Danish situation would benefit the function of the CAP through some simplifi-
cation.
Abolish the requirement that EFA-catch crops must be established as
a mixture.
Farmers risk getting their green payment reduced, as there is a
large risk that one of the two crops may outperform the other. In addition, it
is difficult to control the requirement, which increases the risk for the farmer
(Delegated Act 639/2014, Art. 45(9)).
Only one control visit for basic payment, greening and cross compli-
ance.
For the 5 % of farmers chosen for on the spot checks, each greening
requirement must be controlled. As certain requirements may only be con-
trolled at a specific time of the year, it is in many cases impossible to carry
out only one control visit to a farmer. It should be possible to undertake just
one inspection, which would cover both the basic payment, greening and
cross compliance at the same time (Implementing Act 809/2014, Art. 31).
Greening reductions should be more proportional.
A farmer risks large
reductions of his green payment even with a minor non-compliance. The re-
ductions should be less severe. Today, the reduction is calculated as the ratio
of difference multiplied by 50 % of the total area of arable land determined.
Ministry of Food, Agriculture
and Fisheries of Denmark
Slotsholmsgade 12
DK-1216 København K
Tel +45 33 92 33 01
Fax +45 33 14 50 42
[email protected]
www.fvm.dk
 MOF, Alm.del - 2015-16 - Bilag 337: Udkast til brev fra udvalget til kommissær Phil Hogan vedr. forenkling af den fælles landbrugspolitik
Instead, the ratio of difference could be multiplied by for instance 25 % of
the total area of arable land determined. Also, the rule for increased reduc-
tion after non-compliance has been found for three years should be repealed
(Delegated Act 640/2014, Art. 25-28).
2 pct. benchmark for error rates should be increased to 5 pct. for Ru-
ral Development (EAFRD).
Rules for rural development measures are
complex and difficult to control. This especially applies for area-related
measures, where requirements are linked to agri-environmental nature of
the areas. Therefore, there is a higher risk that farmers do not comply with
these rules. The current threshold set by the European Court of Auditors
should be therefore increased to 5 pct. (Procedures used by the European
Court of Auditors and the Commission)
Member States should have the possibility to set a minimum size up
to 0,3 ha for EFA-areas.
It should be possible to set a minimum size per
type of EFA in a differentiated way and not only for areas eligible for basic
payments. It is difficult for farmers to manage EFA-areas as small as 0,01 ha
correctly. A minimum size would not have a negative effect on the fund or
the purpose of greening (OTSC guidelines DSCG/2014/32, section 2.2.3).
More flexibility than present to allow new rural development com-
mitments to replace old commitments even if the new commitments
in some aspects are less strict.
This would be much simpler for a farmer
as he could choose to have only one type of commitment and requirement
throughout his holding (Delegated Act 807/2014, Art. 14).
Revoking Cross Compliance from Pillar II
Cross compliance penalties are applied to beneficiaries under Rural Develop-
ment, alike beneficiaries under Direct Payment. It does not seem justified to
include Rural Development beneficiaries under Cross Compliance rules, as
support provided under RDP may only cover additional costs or income fore-
gone that go beyond minimum standards
and
Cross Compliance (Basic Act
1306/2013, Art. 92).
It should be possible to make the direct payments to farmers that
are not selected for control.
Control of EFA, especially catch crops makes
it difficult to finish all controls as soon as previously, meaning the payments
would have to be delayed to all farmers using catch crops as an EFA element
(Basic Act 1306/2013, Art. 75(2)).
Carry over unused funds from financial discipline to next year’s crisis
reserve.
Simplify the rules in order to carry over unused appropriations in
year n to financial year n+1 and earmarked to the crisis reserve. This would
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 MOF, Alm.del - 2015-16 - Bilag 337: Udkast til brev fra udvalget til kommissær Phil Hogan vedr. forenkling af den fælles landbrugspolitik
make it possible to have a lower adjustment rate for the farmers in year n+1
(Basic Act 1306/2013, Art. 26).
Harmonize the rules on controls and sanctions.
It is very difficult for a
farmer to understand the different rules concerning control and sanctions
under the integrated administrative and control system (IACS), cross compli-
ance and greening respectively. In the future the rules on control and sanc-
tions should be amalgamated into one set of rules which would make it much
easier for the farmer to understand.
We would also like to highlight the need to discuss long-term simplification ideas
with a focus on both error rate and risks to the funds. Proportionality should be en-
sured between control and administration on the one hand and on the other hand
the actual risk for EU budget. At the moment, the correlation between the cost of
control and administration for Member States and the actual risk to the EU funds
seem out of proportions.
Member States have a national envelope setting the ceiling for the payments in a
Member State, the actual risk to the EU budget is very limited. It should be possible
for Member States to have more flexibility to reduce the cost of control without put-
ting the effectiveness of the policy and sound financial management at risk. If for
instance, in cases where the administrative checks prove effective then it should be
able to reduce the on-the-spot-checks.
Also, error rates should reflect the actual impact on expenditures. We have to en-
sure a transparent and trustworthy method for calculating the error rate. Today we
have several layers of audit and revision in place. From my point of view the role of
the certifying bodies should be strengthened and harmonized. Thus we would be in
favor of introducing a common EU certifying body in order to improve the quality of
the work.
Yours sincerely,
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