Memorandum submitted by
the Tenant Farmers Association (H3)
INTRODUCTION
The Tenant Farmers Association welcomes the
opportunity to provide written evidence to the House of Commons
Agriculture Committee on the European Commission proposals for
rural development within the package of measures for CAP reform.
The TFA is the only organisation representing the sole interests
of tenant farmers in Great Britain. We hold that agriculture remains
the backbone of rural communities in Great Britain and in the
rest of Europe. Unlike other industries that can survive in a
free market environment, we believe that the characteristics of
agricultural production are such that it deserves continued support
within the CAP and that this will help to ensure the economic
survival of many rural areas.
CONCERNS OF
TENANT FARMERS
The Committee will know that some policy changes
can have differential impacts from the perspective of owner occupiers,
tenant farmers and landlords. This is particularly so in the area
of rural development policy.
As an example, whilst it might be desirable
to encourage farm families to diversify their sources of income
beyond agriculture there could be problems for children of tenant
farmers working off the farm if they are hoping to succeed to
the farm tenancy under the statutory provisions contained in the
1986 Agricultural Holdings Act. This is because for at least five
years out of the last seven years before the succession the potential
successor must have worked predominantly on the holding in question
and gained the majority of his or her income from that work rather
than from outside sources. A high proportion of off-farm income
could invalidate the succession.
The thrust of the UK's position in relation
to CAP reform is to allow a steady transition from the current
market-based support systems through decoupled payments into direct
support for environmental and rural development projects whilst
allowing agriculture to be largely self-sufficient in a freer
market. However tenant farmers are, in the main, restricted by
their tenancy agreements in relation to the activities they can
carry out on their holdings. They are mostly required to be farmers
and even the new farm business tenancy agreements place similar
restrictions on producers to those of the 1986 Agricultural Holdings
Act. If tenants engage in non-agricultural activities either under
a rural development scheme or an environmental scheme (without
landlords' permission which is not always forthcoming) they may
find, as a worst case scenario, that they are served with a Notice
to Remedy following by a Notice to Quit. Alternatively, they might
fall into the provisions of the 1954 Landlord & Tenant legislation
which is less beneficial to tenants than the 1986 or 1995 Acts.
Therefore, in developing rural development and
environmental schemes it is important to provide sufficient scope
for tenant farmers to take advantage of those schemes without
breaching their tenancy agreements. If agricultural support payments
are to be transferred into environmental and rural development
budgets at some future date, we must ensure that these are non-discriminatory
between owner-occupiers and tenant farmers.
LONG TERM
VISION
The TFA welcomes the simplification of the rural
development legislation into one regulation. This will help greatly
in allowing individuals to access components of the package. Part
of the problem of EU rural development policy is that there are
few who really understand all of its aspects. The simplification
being carried out to the legislation must be continued through
to the implementation stage. The procedures for accessing funding
must be simplified as should the associated scheme rules.
However, the TFA is disappointed that the European
Commission has not been more visionary in its thinking about the
future of agriculture and the rural areas of Europe. What is needed
is for Governments both at home and abroad to set a future goal
where agriculture can be freer from regulation and less dependent
on subsidy. We must move towards that goal with purpose but gradually
to allow costs and production systems to adjust to the freer and
less costly production environment. This will not only provide
benefits for agriculture but also the rural environment and rural
society.
Complete liberalisation is not possible or desirable.
Low level regulation will still be needed to cover health and
safety issues, food hygiene and environmental concerns. These
will however build in costs to the industry. Food will continue
to be a "strategic commodity" whose supply will need
to be broadly guaranteed. There will also be the desire to see
increased environmental quality through manipulation of agricultural
practice. Again this will not come cheaply let alone freely. UK
and European agriculture will continue to be subject to competition
from abroad where production practices may not mirror those at
home leading to unfair competition. A level of protection from
the market will therefore remain essential.
It is disappointing then that the current CAP
proposals in the round continue to be driven by medium term and
financial concerns rather than putting agriculture and Europe's
rural areas on a firm long term footing.
ENVIRONMENTAL "CROSS
COMPLIANCE"
A great concern to the TFA is the proposal to
allow member states to make the granting of support payments conditional
on environmental criteria. This idea of so called "cross
compliance" was considered at length by the UK Government
in recent times. It was decided that such a policy should not
be promoted and the TFA continues to hold that view. It is important
when establishing a support mechanism that it is not used to meet
mutually exclusive targets. Whilst a payment might be granted
to supplement farm income based on stocking rates an environmental
condition might be aimed at reducing the impacts of over stocking
which will tend to work against the primary aim of the payment.
Individual targets must be met with individual mechanisms and
there should be positive payments for positive environmental actions.
Another problem is finding a set of conditions
which are not only desirable but practicable and policeable. In
the consultation process carried out by the previous Government
into cross compliance measures it was concluded that it would
be difficult to find measures which met all three criteria. For
example, whilst it may be desirable to have bare strips, grass
strips or conservation headlands around arable fields it would
not be desirable to have them around all arable fields. Cross
compliance is therefore a blunt instrument which cannot take into
account the individual needs of local areas. A more target based
approach of positive incentives should be pursued instead.
The TFA believes that cross compliance is a
distraction from the long term goal of achieving a sustainable
agricultural policy environment.
CONCLUSION
Rural areas must be given the opportunity to
develop and prosper. The TFA believes that this can best be achieved
by ensuring a long term, profitable agriculture which remains
the backbone of rural society. Schemes and projects developed
to complement this approach should ensure that they are broadly
accessible regardless of how land is occupied. With this in mind
we need a long term vision which allows agriculture and the wider
rural areas to have confidence in the future.
9 June 1998
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