The merry band of subsidy disclosers at farmsubsidy.org (known on stage as Jack Thurston and The Transparencies) have been embarrassing the EU subsidy lobby since launch a few years back. And now the disclosure of who gets what in the Common Agriculture Policy has plopped the payment limit issue squarely on the table.

Here, courtesy of the indefatigable Keith Good's FarmPolicy feed this morning (do subscribe via this email farmpolicy-on@list.farmpolicy.com), is a Q & A that accompanied EU Agriculture Commissioner Mariann Fischer Boel's press conference yesterday, in which she enumerated some of the policy ideas likely to be debated in Europe during the "Health Check" of the Common Agriculture Policy now formally underway.

Big European farms should begin thinking about making it on their own. From the Commission's document:

Why are we proposing upper limits for payments?

Calls for transparency on recipients of CAP payments are linked to the apparent imbalance which still exists in the distribution of direct support per beneficiary. The shift towards decoupled support makes this distribution more evident and puts pressure on the justification of payments – are they destined to the appropriate recipients? In this context the capping of payments, an old idea which was dropped in the past, has resurfaced.

In the EU-27, about 20% of beneficiaries receive around 80% of direct payments. This distribution is linked to farm size distribution in each Member State, farming intensity and which farming sectors formerly received production linked direct payments. Exactly for these reasons, only at low thresholds would capping change the distribution of payments per beneficiary. At such a low level, however, the measure also has a significant income impact on many beneficiaries.

As is the case here, the limits proposed will hit only the very largest subsidy recipients. Mr. Thurston observes:

Analysis of the Commission's proposals for limiting the subsidies paid to Europe's very largest farms shows that 23,500 farms would be affected, though most of them only at the 10 per cent reduction rate.

The payment limitations proposal published today would involve three bands:

1. Payments between €100,000 and €200,000 would be subject to a 10 per cent reduction. This would affect 17,460 farms.

2. Payments between €200,000 and €300,000 would be subject to a 25 per cent reduction. This would affect 3,070 farms

3. Payments above €300,000 would be subject to a 45 per cent reduction. This would affect 2,790 farms.

Taken together, these payment limitations would affect 23,500 recipients of farm payments (around 0.3 per cent all farms). The amount of subsidy cut would be €554 million (around 1.7 per cent of the budget for direct payments).

By contrast, the failed Franz Fischler proposal of a hard ceiling of €300,000 would have affected 2,795 recipients and would have cut payments by €750 million (2.3 per cent of the total amount spent on direct payments to farmers).

This development only strengthens the hand of reformers over here who are pursuing Dorgan-Grassley's payment limit and sensible subsidy cut-off's for the wealthy (the adjusted gross income approach). We can point to the lively debate now officially engaged in Europe as evidence that the subsidy lobbies in both countries have perpetuated inequities that the public, once aware, will no longer tolerate.

Transparency in subsidy payments has helped make a transatlantic case for sensible limits on who should receive them.

If you want to stay tuned to the CAP review with guidance from reform-minded NGO experts, academics and others, here's the spot.