Your view on whether entitlement values should be frozen at 2019 rates, or should continue to a flat rate payment by 2021, probably depends on where your entitlement value currently sits against the NI average of €333/ha. Back in 2013 DAERA initially proposed a 10-year transition. It was a position generally supported by the DUP. Others, including Sinn Fein wanted a much faster move to the NI average. In the end, seven years was a compromise between the two largest political parties.

But policy makers knew that the decision taken to go for a seven-year transition took us beyond the current CAP reform period that ends in 2019. It was always possible that entitlement values in 2019 got locked in for future years.

If that happens, it is generally farmers in the severely disadvantaged area (SDA) who lose out. Over the period since 2015 approximately €4m in payments have flowed annually from lowland and disadvantaged area farms to the SDA.

But SDA farmers can point to the loss of areas of natural constraint (ANC) payments, which were worth £20m per year in 2016 and 2017. By the time direct payments were fully flat rate in 2021, DAERA analysis showed that farms in the region would have effectively made up for the lost ANC money – it was one of the justifications used for ending the ANC scheme in NI.

On the other hand, there are those who will point to the very substantial direct payments already going to some farmers in the SDA. The top 17 NI claimants are all operating in the SDA.

But many of these cases are already at the NI average, having successfully claimed to the regional reserve as a young farmer or new entrant. They also might have been able to split the business in 2015 and stacked existing entitlements onto a relatively small area. Interestingly, in these cases, they would benefit from a freezing of entitlements in 2019.

Either way, it is not an easy decision, and one DAERA officials will happily leave to a Minister.

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