The document puts sustainable intensification at its heart.

"The opportunity offered by the upcoming reform of the CAP must be used to refocus on reinforcing the economic role of farmers, making European agriculture a dynamic, innovative and more profitable sector," it says.

Unfortunately, as Copa points out, the view among European farmers is that the Commission "has failed to grasp this opportunity."

Copa-Cogeca highlights mandatory greening and added bureaucracy as elements of the proposals likely to undermine the ability of EU farmers to be competitive, efficient and achieve sustainable growth.

The NFU has been actively involved in the drafting of Copa position. President Peter Kendall and Director of Policy, Martin Haworth, attended the recent meeting of the 56 farm union Presidents that make up the Copa "presidium", and our Brussels staff have maintained close contact since then.

Copa-Cogeca wants to see a "re-appraisal" of elements of the plans, including:

• The active farmer test scrapped and greater flexibility should be given to the member states to choose the most appropriate way of targeting payments to active farmers.
• Capping payments should be rejected.
• Member states (and regions) applying historic payments should have more time to move across to the flat rate approach.
• More work needs to be done to streamline and simplify cross-compliance.
• It should be mandatory for all member states to assist young farmers, either through an annual top-up to direct payments or through specific support in pillar two.
• The small farmers’ scheme should be optional for member states to apply.
• The Commission must ensure that coupled support should have minimal distortive effects on competition.
• Sugar quotas should be maintained until 2020.

Instead of ‘mandatory greening’, Copa calls for an alternative aimed at encouraging green growth.

It suggests the construction of an EU list of measures from which a farmer can choose the most appropriate action based on his own farm situation. If a farmer is already carrying out items on this list, Copa believes that this should be recognised.

The 30 per cent earmarked for greening should be substantially reduced and penalties for those who do not undertake the green growth must be limited.