The proposals for the next Multiannual Financial Framework and the Common Agricultural Policy ... 83 support must be established on the basis of the farmers' income from agricultural activity over a representative reference period. Without prejudice to the possibility, and indeed the necessity, of differentiated policies for specific groups of farmers, our Confederation considers that this should not be done in the case of aid decoupled from production whose purpose is to ensure a minimum level of income – which is why the degressivity and the capping proposed for this support should be reviewed. The absurdity and bureaucracy associated with this proposal are not compatible with the simplification slogan. 3. Our Confederation's position The Confederation of Portuguese Farmers categorically rejects the proposals presented by the European Commission on 16 July for the next MFF 2028-2034. In fact, with a completely remodelled structure, the proposal for the new MFF, by integrating the CAP into the 'Fund', ignores this policy as a pillar of food security and removes its relevance, identity, autonomy and common nature. Furthermore, this new model lacks realism, given the complexity of the legislation and the requirement that the planning and implementation of the 'Fund' be dependent on the submission of a single plan (NRPP) by each Member State (MS). This requirement, stipulated by the 'Fund', requires prior agreement at national and regional level for the implementation not only of the CAP and Fisheries Policy, but also of other interventions traditionally supported by the Structural and Cohesion Funds, thus involving multiple entities with very different interests and demanding a level of coordination and agility that does not exist in the Portuguese administration. The simplification announced by the Commission is not compatible with the proposals presented. Specifically in relation to the CAP, the main reasons for disagreement are as follows: — Despite the widely publicised financial ambition associated with the new MFF, Portugal is heavily penalised by the budget allocated to it from the ‘Fund’, with the CAP losing around 20.4 % of its financial allocation at current prices4 compared to the allocation for the 2021-2027 programming period; — The abolition of the two pillars of the CAP and their replacement by an integrated financial allocation in the ‘Fund’ which, although it does not cover all CAP interventions, leads to ‘competition’ between CAP measures traditionally distributed across the two pillars; — The loss of identity, autonomy and financial predictability of the CAP, as the agricultural sector is forced to compete with other sectors in order to secure funding that was previously guaranteed for interventions traditionally included in the CAP, such as LEADER and knowledge-related interventions. Increased concern regarding POSEI, public irrigation and investment in the bioeconomy (agribusiness), for which funding is not clearly mentioned; — The stability and predictability of farmers' incomes are not safeguarded; — The imposition of a minimum co-financing rate of 30%, roughly double the current rate, and with no capping for interventions traditionally supported by the EAFRD and included in the specific financial allocation for the CAP, which represents an enormous strain on the Portuguese budget and creates major distortions between Member States, due to their different economic capacities, accentuating the trend towards the renationalisation of the CAP; 4 This loss is not offset by the removal of some of the interventions traditionally covered by the CAP, which now have to be financed outside its ringfencing
RkJQdWJsaXNoZXIy MTgxOTE4Nw==