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In response to the CAP reforms, Phil Stocker, Head of Agriculture at the Soil Association said: “Organic farming delivers many of the environmental and social benefits that the changes intend to stimulate, yet under the current CAP framework organic farmers are disadvantaged, with some receiving a third less in subsidies than other farmers”.

“We urge Defra to take up the 100% decoupling option whilst ensuring that this does not lead to unfair competition from countries that do not introduce single payments.The option to retain certain premium payments will not benefit organic farmers and may encourage some parts of the farming industry to continue to overstock.“

The Soil Association made the following comments about specific proposals:

• The single payment may disadvantage existing organic farmers, as it is based on the amount of subsidies historically received. We have asked Defra to give organic farmers the option to claim for the period 1997-1999 when many were still farming conventionally and as a result received higher levels of subsidies. Farmers who were fully organic before 1997 should be paid 45% above the historic level. Using this system would ensure better equity between existing organic farmers and those who choose to convert after CAP reform with relatively high single farm payments
  
  
• Growers producing fruit, vegetables and potatoes again miss out. The reform process could have provided an opportunity to provide support payments in terms of single farm payments to these sectors, and a re allocation of funds to encompass this sector would have had little impact on the arable and livestock sectors.
  
  
• Continued modulation – which allows a percentage of farm subsidies to be paid back into an EU-wide fund for rural development – is welcomed. The UK currently pays a higher rate of modulation than most other EU countries (3.5%), 80% of which can now be used on domestic schemes. We agree that farmers receiving less than 5,000 Euros should be exempt from modulation.
  
  
• The requirement to keep land under 'good agricultural conditions' has been changed to keeping land under 'good agricultural and environmental conditions'. Though this would appear to be an improvement, the benefit of this term will only be seen when a full definition is given. Whilst the concept of decoupling support from production is right, support payments should not be completely divorced from the production of food. The definition could be expanded to require a level of quality agricultural output that delivers environmental, animal welfare and social benefits.
  
  
• The option for member states to divert up to 10% of direct aids into a national envelope is welcome, as is the national reserve to deal with special cases, such as new entrants to farming.
  
  
• We welcomed the proposed 10-year non-rotational set aside option for non-organic land, which would allow biodiversity to develop on unfarmed land. However, this proposal appears to have been dropped, and rotational set aside is unlikely to provide equivalent environmental benefits. For the last two seasons, farmers whose whole holdings are organic have been allowed to graze livestock and produce crops on set a side land whilst still receiving set aside payments. It is important that this concession is expanded to holdings with organic and non-organic units.
  
  
• The requirement for permanent pasture to remain as permanent pasture has been relaxed. We will continue to lobby for an environmental assessment to be made before land that has been under grass for 12 years or more is ploughed up.