The DAERA consultation on whether Basic Payment Scheme (BPS) entitlements should be frozen at 2019 levels or continue towards a flat-rate payment (around €330/ha) by 2021, is now closed to responses.

Of note is the Ulster Farmers’ Union (UFU) position, with the organisation refusing to submit a formal response while the Department has no legal authority to change entitlement values in 2020.

That goes back to the fact that the last CAP reform period applied to the five years from 2015 to 2019.

In effect therefore, under current EU law the euro value of entitlements in 2019 is seen as the “final unit value”.

After Brexit if NI wants to change the value of these entitlements in 2020 (or later years) it will require a new domestic law under the direction of a minister.

“Now is not the appropriate time for this consultation or to submit a formal response. DAERA must revisit this issue when it is legally able to take a decision on entitlement value. To do otherwise would be irresponsible,” said UFU president Ivor Ferguson.

Given that entitlement values in 2019 have already moved five steps of seven to a flat-rate payment, the issue is not as controversial as it once was, although still potentially divisive for organisations like the UFU, as it creates winners and losers.

DAERA analysis shows that the main winners from flattening out payments in 2020 and 2021 would be sheep farmers in severely disadvantaged areas (SDA), who would see an 11% increase in payments. SDA mixed cattle and sheep farms would also gain (+5%).

The losers are cattle and sheep farms in the disadvantaged area (DA) and lowland.

ANC

Recognising that members in the SDA will financially lose out while the entitlements are frozen in 2019, Ferguson has called on DAERA to re-instate the Area of Natural Constraint (ANC) scheme, which was worth £20m to the SDA in the 2016 scheme year.

The decision to stop ANC payments in NI was partly justified on the back of the re-distribution of money from lowland and DA, to SDA land, which is happening as part of the move to flat-rate direct payments.

Each year approximately £2.8m is going into SDA. By 2019 this is an extra £14m into the SDA when compared with 2015.

If entitlements continued to a flat-rate by 2021, it would be an additional £19.6m to the SDA.

NIAPA

It is understood that the NI Agricultural Producers’ Association (NIAPA) has taken a similar approach to the UFU, and has not put in a formal response on flattening of payments, but instead called for a re-instatement of the ANC scheme.

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