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Oh dear. A couple of important errors/confusions in this piece by @ShankerASingham, and a generally unreal analysis.
First, he isn’t really right in saying that current CAP payments are based on size of landholdings. 
EAGF payments - most of the budget - are based on amount of land in good agricultural and environmental condition. But this isn’t the same as “landholding”: land not used for agricultural purposes doesn’t qualify.
Importantly though, and contrary to what you’d guess from the second sentence there, it does mean that you have to be a farmer to get EAGF payments. And in fact both RSPB and the National Trust get EAGF money precisely because they own and run farms - they *are exactly* farmers.
(PS I think Singham means the National Trust, not English Heritage. See eg bbc.co.uk/news/uk-politi…).
He also ignores an important but much smaller element in CAP funding - rural development grants. These are not linked to farming.
And since they are granted for a wide range of purposes including environmental ones, it’s unsurprising that the National Trust and RSPB get substantial sums under that programme.
I’m therefore not entirely certain what this para is calling for: direct payments are already “focused on actual farmers” (and are conditional on keeping land in good environmental and agricultural condition).
In fact, the usual criticism of CAP payments is that they are *too* focused on farming and don’t adequately reward landholders for using land in environmentally friendly ways that are not farming.
As for his recommendation on abandoning rules on GMOs, what I think this fails to grapple with is that opposition to GMOs is not something foisted on us by the EU. On the contrary, there is huge and passionate U.K. domestic opposition to these technologies.
Realism about trade policy starts with realism about what your own domestic politics are able to live with.
And speaking of political realism, looking at the start of the article, it’s true that EU farmers exporting to the U.K. will face tariff problems on no deal.
But the point is true in spades in reverse: our own farmers and fisherman would face high tariffs on not just one of their export markets but on the EU27 as a whole.
So, all in all, this is not an impressive piece of analysis.
See also, for a corrective to Singham’s “EU27 agriculture must be panicking so they’ll put pressure on the EU27 to cave in” view: buzzfeed.com/alexspence/foo…
