Supplementary Memorandum
submitted by English Nature (H31)
The Committee has posed the following questions:
Commenting on the Commission's proposed shift
in payment of HLCAs from a headage to an area basis, you note
that the change should "take pressure off farmers to maximise
stocking in the uplands". But as you acknowledge the real
incentive for overstocking comes from the sheepmeat regime rather
than hill livestock compensatory allowances.
— Do you agree that there may be little
immediate environmental gain from changing the payment of HLCAs
from a headage to an area basis?
— In your opinion, how stringent should
conditions on LFA farmers be in order to comply with draft Article
14(2), "on the need to safeguard the environment and preserve
the countryside"? How should this "good farming practice"
clause be monitored?
English Nature's advice on these points is as
follows:
POINT 1: HILL
LIVESTOCK COMPENSATORY
ALLOWANCES—THEIR
ROLE IN
STIMULATING OVERSTOCKING
IN THE
UPLANDS
The system of livestock headage subsidy payments
has provided an incentive for farmers to stock beyond the environmentally
sustainable carrying capacity of some hill areas and to neglect
beneficial practices. Whilst only a small element of total livestock
subsidy going into the uplands, HLCAs have maintained farmers
and sheep numbers in the more marginal areas and, in a time of
low upland farm incomes, can have a particularly significant role.
English Nature believes that the impact of a more environmentally
sustainable LFA policy will be reduced significantly unless there
is a corresponding reform of the EU sheepmeat regime, otherwise
the system which encourages intensification and environmental
damage will remain in place.
POINT 2: ENVIRONMENTAL
GAINS FROM
CHANGING TO
AREA PAYMENTS
English Nature does not agree that there may
be little immediate environmental gain from changing HLCA payments
from a headage to an area basis. The removal of an incentive to
maintain environmentally unsustainable grazing levels and the
introduction of environmental conditions should lead quickly to
the reduction of excessive overgrowing and therefore to the cessation
of continuing damage to many upland semi-natural habitats. Stopping
deterioration of habitats is a significant biodiversity gain in
the short term. Habitat restoration thereafter will require some
ongoing agri-environmental scheme support. This would be a longer
term gain with a variety of timescales depending on the habitat
and the degree of damage caused by overstocking and the speed
with which remedial action is put in place.
POINT 3: ENVIRONMENTAL
CONDITIONS
English Nature believes that there is a need
to attach environmental conditions directly to subsidy payments
to farmers. English Nature, on behalf of all the UK Countryside
Agencies, is currently managing a project examining possible options
for the reform of LFA policy. An important aspect of this research
is the level at which environmental conditions should operate.
The findings of this research will be disseminated to UK Ministry
of Agriculture and European Commission officials at a seminar
in January and will inform the Agencies' continuing work on the
Rural Development Regulation.
The level and type of environmental conditions
currently under consideration by the Agencies include:
— adherence to all legislation to prevent
environmental damage;
— following Codes of Good Agricultural
Practice and the proposed new Wildlife Code;
— retention of existing semi-natural habitats
and features;
— creation of buffer zones adjoining all
semi-natural habitats and watercourses;
— setting parameters for appropriate livestock
grazing levels;
— adopting an approach similar to those
conditions attached to ESA tier 1 payments across the whole LFA;
and
— production of an agreed environmental
audit and management plan.
It is important that conditions attached to
LFA payments:
— deliver genuine and sustainable environmental
gains;
— are compatible with the Rural Development
Regulation;
— can be politically justified in the longer
term;
— are transparent, realistic, achievable
within a given timeframe and enforceable; and
— are measurable and easily monitored.
POINT 4: MONITORING
OF "GOOD
FARMING PRACTICE"
To be able to determine compliance and to identify
changes in environmental quality some level of monitoring will
be required. English Nature would advocate that a monitoring/compliance
programme can be established that could assess environmental features
quickly and simply without being an administrative or a financial
burden. Information should be collected both on a presence/absence
basis and on a "condition assessment" using certain
indicators. We do not see the need to undertake this monitoring
across the whole LFA but on an acceptable sample basis. An initial
environmental audit would provide the baseline.
13 November 1998
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