A DOG’S breakfast, bonkers and greenwash – just some of the uncomplimentary phrases used to describe the European Commission’s proposals to reform the Common Agricultural Policy (CAP).

The proposals have certainly attracted strong views since they were officially unveiled in October, generating a wave of objections from member states, MEPs and organisations including the RSPB and the National Farmers’ Union (NFU).

Reasons for the objections vary but the objectors all agree on one thing – the proposals must change substantially before they are imposed on Europe’s farmers in 2014.

The NFU has always said that the CAP should be about production and helping farmers to become more competitive and market orientated and these proposals do not achieve any of those objectives.

The complexity of the proposals is another real concern. The Commission has made ‘simplicity’ a priority in terms of understanding and implementation, but they are certainly anything but simple. And the Rural Payments Agency, which administer the scheme and pays the claims, agrees.

We are particularly concerned about the potential impact on farmers in the East of England, traditionally Britain’s breadbasket and one of the most productive agricultural regions in the country.

One of the main concerns centres on the proposals to ‘green’ the whole CAP. Farmers currently deliver huge amounts of environmental and wildlife benefits under Environmental Stewardship Schemes, which are part of Rural Development pillar two of the CAP. These schemes are voluntary and farmers are paid based on what they are able to achieve and deliver.

This is where we think greening should be focused. Instead the Commission wants to see a greening of pillar one, which relates to the direct payments that farmers receive, based on the land they farm. It would effectively be a new set of compulsory rules that farmers would have to abide by if they wished to claim the payments.

Under the greening proposals, farmers would have to grow at least three different crops on their farm. This idea was developed to address concerns over mono-cropping in the Paris Basin and parts of Eastern Europe.

Although there might be some farms in Suffolk and Essex that grow single crops in any one year, our farming systems are diverse enough to deliver a patchwork of different crops across the region as a whole. This proposal will cause major problems for some, particularly smaller farmers who are farming in conjunction with others.

Another part of the greening measures require farmers to have 7% of their arable area allocated to an ‘ecological focus area’. This is likely to consist of areas such as hedges, buffer strips and ponds, although the Commission has not yet defined the exact criteria.

England is exceptional within Europe in having developed the voluntary Environmental Stewardship Scheme. Seven out of 10 farmers have joined this scheme and there are currently large areas on farm dedicated to delivering environmental benefit.

At the moment it does not look like we can include all of this land in the proposed 7% EFA. Consequently some farmers are holding off renewal of their voluntary agreements as they cannot afford to dedicate further land over and above this 7% to environmental activities. After all, we must not forget the need for food production as a priority in all of this.

Farmers are told that they have to compete in the market place, but they will be competing with one hand tied behind their backs as long as they are expected to meet standards of care for the environment that simply do not apply to their competitors elsewhere in the world.

We need to ensure a policy framework that helps us meet the challenges of producing more while impacting less so that we can deliver what our consumers want and need.