Memorandum submitted by the Royal Society
for the Protection of Birds (X2)
1. SUMMARY
1.1 The RSPB welcomes the Agriculture Minister's
statement on the Rural Development Regulation (RDR) and believes
that the announcement really does represent the start of a "new
direction for agriculture".
1.2 We have recently submitted a number
of proposals to MAFF on how the new money can be used to ensure
that all farmers have some access to measures contained in the
RDR (box at 3.5), comprising measures for agri-environment schemes
which could be undertaken now or at least given consideration
prior to MAFF's planned full-scale review in 2001.
1.3 From an environmental perspective, there
are a number of unanswered questions about the way in which the
package will be implemented including:
— Whether the agri-environment funds
raised through the RDR and modulation will be used specifically
to combat the ongoing environmental problems in arable areas;
— How MAFF will ensure that farmers
are made aware of the various new measures available to them under
the RDR to ensure a good uptake;
— Whether some of the agri-environment
funds raised through the RDR and modulation will be made available
to fund pilot or experimental projects to help find new farming
methods which benefit wildlife;
— Following MAFF's consultation on
a new Hill and Livestock Compensatory Allowance Scheme, whether
measures will be brought forward that protect the environment
as well as supporting hill farmers.
2. INTRODUCTION
2.1 The Agriculture Minister's announcement
last month outlining proposals for modulation of production subsidies
and increases in funding for the RDR was extremely welcome news.
The RSPB has called for such a shift in farm subsidies for many
years and believes that this announcement really does represent
the start of a "new direction for agriculture".
2.2 The £1.6 billion for the RDR has
the potential to deliver significant benefits in rural areas.
We especially welcome the allocation of almost two-thirds of this
money to agri-environment measures, which we consider begins to
reflect the scale of the environmental problems in the countryside.
The Government's recently revised Quality of Life indicators—which
showed continuing declines in farmland birds—emphasise the
need for real solutions to such problems.
2.3 The RSPB supports MAFF's intention to
undertake a full review of agri-environment schemes, beginning
in 2001. However, we also have a number of proposals for agri-environment
measures which could be undertaken now or at least given consideration
prior to a full-scale review. It would be possible to phase in
these measures in a targeted way as funding becomes available
and to contain the overall expenditure, as necessary.
3. TARGETING
RURAL DEVELOPMENT
REGULATION FUNDING
3.1 The RSPB has always argued that agri-environment
funding should be targeted according to conservation priorities.
We continue to endorse this principle and therefore welcome the
priorities set out in the Government's Rural Development Plan
for England submitted to the European Commission in December 1999.
3.2 The recent decision on modulation, providing
additional funding for agri-environment schemes, will ensure that
significant progress can be made towards meeting these environmental
priorities. However, many farmers are concerned about the potential
loss of farm income as a result of modulation and critical of
the Government's decision.
3.3 MAFF's own analysis of the impacts of
modulation[1]
shows there will be "winners and losers" as a result
of modulation and the combined effects of the RDR. In aggregate,
there will be revenue gains for cattle and sheep farms and smaller
gains for dairy and arable farms. Small farms will also do relatively
well compared to large farms. From an environmental perspective,
this shift in funding is welcome but the RSPB recognises that,
for some farmers, it is unpalatable. The combined effect of Agenda
2000 commodity reforms and modulation will have particular impact
on the incomes of large cereal farmers—a sector of the farming
community with political weight which is likely to make its criticisms
widely known.
3.4 One of the best ways to deflect criticism
of modulation across the farming sectors, but particularly in
those sectors most affected, is to ensure that all farmers have
some access to measures contained within the RDR. With this in
mind, the RSPB has already proposed to the Government a number
of measures for agri-environment schemes generally and the arable
sector specifically (see 3.5). The latter is not just a device
to appease arable farmers but reflects the fact that some of the
most acute losses of biodiversity are occuring on arable farms.
3.5 RSPB proposals for the agri-environment
programme:
Countryside Stewardship
— Continuation of the Arable Stewardship
pilot for a further five years with additional monitoring and
evaluation work, plus the inclusion of a number of the pilot arable
prescriptions within the full Countryside Stewardship menue to
make them available to arable farmers throughout England (these
measures could be applied in a targeted way to limit the overall
funding requirements);
— Expansion of the Special Projects
option within CS target species such as tree sparrow, corn bunting
and black grouse in key geographical areas to prevent localised
extinctions of these species;
— Ring-fencing of funding for the upland
options within CS to increase uptake by hill farmers and tackle
problems such as overgrazing and the restoration of upland habitats;
— Ring-fencing of funding for the new
saltmarsh options in CS (following the review of the Habitat Scheme
and merging into CS) to ensure adequate restoration of this habitat.
Environmentally Sensitive Areas
— Improving the performance of ESAs
by increasing uptake of the conservation tiers and placing greater
emphasis on restoration and re-creation of habitats.
Organic Farming Scheme
— Building on the existing OFS by developing
an Organic Stewardship option within Countryside Stewardship,
which would give farmers support during the initial conversion
period to organic farming methods and on an on-going basis for
additional environmental work undertaken (eg hedgerow management
or habitat restoration).
New Pilot Projects
— Development of a new pilot scheme
targeted at intensive grassland systems (eg dairy farms) to test
prescriptions that could be included at a later date in the full
CS menu.
1 MAFF (1999) Appendix 1 The Economic Impact of Rural
Development Expenditure and Recycling in Agenda 2000 CAP reform:
A new direction for agriculture. MAFF, London. Back
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