Thank you for the opportunity to respond to the Scottish Government’s proposal to transfer funds from pillar 1 to pillar 2. The SCF does not agree with the amount suggested in principle, though our reservations regarding pillar 2 will be obvious. We strongly disagree with the suggestion that LFASS will be used in the same way as it is currently and that CCAGS will be opened to non-crofters.
An overall objective of the CAP reform, we were told by the European Commission, is to move money away from direct payments and into rural development, where it can be targeted to achieve specific outcomes. With Scotland receiving the lowest rural development payments in Europe, it does seem anomalous that the full 15% transfer of funds from agricultural direct payments (pillar 1) to rural development (pillar 2) is being questioned and Scottish Government is minded to only transfer 9.5%.