NFU president Ben Gill has contacted agriculture minister Nick Brown to stress his concerns over further amendments to the Hill Farm Allowance scheme.
The revised scheme was submitted to the European Commission on August 2 and since then further negotiations have resulted between the commission and MAFF.
A further revised proposal has already been submitted with the following revisions:
l Lowering of the minimum stocking density from 0.2 lu/ha to 0.15 lu/ha - clarification is still being sought over which animals will be used for calculation purposes.
l No maximum stocking density applied for the new HFA scheme - the old HLCA scheme operated a maximum stocking density of 1.4 lu/ha.
l Penalties will be applied for higher stocking rates - disincentives to higher stocking rates: at or above 1.6 lu/ha payments will be reduced by 25pc; above 1.8 lu/ha payments will be reduced by 50pc.
l Confirmation is required on animals used for the calculation before the impact of this amendment can be assessed and the effect, if any, on the environmental enhancement payments.
l Clarification of the "safety net mechanism" - this will affect the likely support levels of those who are facing a loss under this new support mechanism.
It appears that the safety net will provide lower support levels for the next three years than previously understood.
The revisions, aside from the lowering of the minimum stocking rate, cause the NFU great concern.
Meetings with MAFF officials have already been held and the severity of the difference in the calculation of the safety net has been strongly emphasised to the agriculture minister.
In addition to the most recent revisions, there are still outstanding issues requiring clarification from the first submission of the HFA scheme to the EU Commission:
l The ability for farmers to identify the proportion of moorland on individual holdings.
l Eligible livestock for the purpose of calculating stocking densities; transfer of land in relation to the safety net provision; dairy land apportionment.
The NFU is constantly pressing for the clarification of all the questions arising from the details of the HFA scheme.
The HFA proposal is likely to be approved by the EU's Star committee in September. Following this, in late September, the NFU plans to hold roadshows to explain the new scheme.
Laurie Norris- NFU policy adviser
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