Defra secretary Michael Gove has set out plans to cut direct payments by £150m from 2020, according to a public consultation launched by his department on Tuesday.

Health and Harmony: the future for food, farming and the environment in a Green Brexit seeks opinions on other public goods that could be supported, such as investment in technology and skills, public access to farmland and the countryside, enhanced animal welfare and rural development measures.

While Defra said that direct payments would remain unchanged in 2019, Gove is considering options for the following year, including a £100,000 cap on payments, or a progressive reduction of all direct payments with deeper cuts for larger farms.

The department is also inviting contributions on “measures to move away from heavy-handed enforcement, which penalises farmers for minor errors, including a more efficient inspection regime to uphold important environmental and animal welfare standards”.

The consultation paper applies to England only and states that “devolution provides each administration with the powers to decide its own priorities”.

However, common frameworks agreed by the Joint Ministerial Committee – the consultative body comprising UK and devolved administrations – will be in place to enable a “well-functioning internal market across the United Kingdom”.

Ewing disputes UK Government

The main issue that the Scottish Government has identified is that the EU Withdrawal Bill does not state that consent must be obtained from devolved nations prior to implementation of any common frameworks.

A source close to Fergus Ewing told Farmers Journal Scotland that “it is essential that the powers currently devolved to Scotland in agriculture stay devolved should we leave the EU. This paper sets out how vital it is for the EU Withdrawal Bill to be changed in order for Scotland to have the power to shape its own policy, which is in the best interests of Scottish farming”.

The level of influence this consultation will have over Scottish policy will depend on that and the outcome of the Continuity Bill, introduced to Holyrood this week as an alternative to the EU Withdrawal Bill.

NFU Scotland said it agrees with the Defra consultation’s principles of a UK-wide regulatory framework, but called for all elements of agricultural policy to remain within the hands of the devolved administrations.

“The proposals to cap and eventually phase out direct payments in England runs counter to the real needs of significant sectors of the Scottish agricultural industry,” said NFUS president Andrew McCornick. “Of real interest are the suggestions as to how recycled funding might be spent to deliver environmental benefits and drive productivity gains, while enhancing animal and plant health, and building resilience in the face of increased volatility.”

The consultation is open until 8 May 2018.