For the purposes of the NRDP programming exercise, Romania actually chose to define “subsistence” farms as smaller than 2 ESU. Holdings in this category are estimated to cover 45% of UAA and to account for 91% (3.8 million) of the total number of farms. Most of these units lack legal personality (although there are some exceptions) and the vast majority lie in the farm size range of less than 5 ha farm with an average size of 1.63 ha.

The current level of SAPS payment (EU funds topped up with the Complementary National Direct Payments) in Romania is currently only 85 EUR/ha so clearly a significant proportion of these holdings (i.e. those less than approximately 3 ha) would be affected by the 250 EUR lower limit.

Although to be more precise – it would be those holdings from 1-3 ha that would be affected since farmers with less than 1 ha do not meet the basic pre-requisite for being listed in the National Farm Register and do not qualify for SAPS. These smallholdings are estimated to represent 45% (1.9 million) of all farm holdings.

But of course the disadvantage suffered by small-scale subsistence farmers in Romania is not just restricted to the lack of access to SAPS since the combination of a small land holding and low economic size (especially with the threshold lifted to 2 ESU) also delivers a double whammy whereby subsistence farmers with:

1. An economic size of less than 2 ESU are excluded from Axis 1 measures:

* setting up of young farmers
* modernization of agricultural holdings (unless applying for support as an association of small-holders)
* supporting semi-subsistence agricultural holdings
* farm advisory and extension services

2. Less than 1 hectare are excluded from Axis 2 measures:

* Less Favoured Areas (mountain and non-mountain)
* agri-environment payments

On the other hand, there is a clear tendency within the Romanian NRDP to encourage subsistence farmers to diversify into activities such as crafts, tourism and food processing. Those that are willing to register as micro-enterprises are eligible for two measures under Axis 3:

* support for the creation and development of micro-enterprises
* encouragement of tourism activities

However, the majority will find the conditions – including the establishment and registration of a micro-enterprise, finding security for co-finance etc. – an insurmountable obstacle, at least without a huge amount of support and encouragement. And diversification is a very long way from being any kind of solution…………………….

I’m not sure I agree with you about farmers and cross-susbidy from non-farm work. If a farmer is only farming part-time then he or she cannot expect to earn a full-time salary, right? So part-time farming may go hand-in-hand with part-time something else, whether that’s an on-farm diversification like agri-tourism or an off-farm job in a nearby town or village.

Thanks for drawing my attention to the EFNCP-WWF report. It’s emphasis on HNV farming is welcome. Clearly a designation of nature value needs to play a much bigger role in the allocation of CAP support, and it follows from this that measures need to be tailored to be appropriate to the circumstances of the farmers and land managers who are active in HNV areas, and in many cases this will be subsistence farmers for whom the CAP is currently, at best, an irrelevance.

I am surprised however, that the EFNCP response to the Commission’s LFA consultation was against Option 4, which would have introduced HNV as a core concept in support for farming in marginal lands.

“We do not support an approach which involves attempting to map and delineate HNV farmland areas, either as a suitable tool for targeting support at HNV farmland, or as a substitute for LFA boundaries. The HNV farming concept is not best applied through delineation of areas, but rather through farm-level criteria.”