Memorandum by the National Farmers' Union
of England and Wales (BIO 32)
The National Farmers Union (NFU) welcomes this
opportunity to submit written evidence during the Sub-committee's
inquiry on UK Biodiversity. The NFU represents some 60,000 farmers
and growers who collectively have a significant impact on biodiversity
through their land management of the countryside. Biodiversity
in the UK, in common with other parts of Europe, is adapted to
and dependent on farming practices that have been established
for many centuries. This close association between wildlife and
farming practices makes biodiversity conservation an important
challenge in Europe and particularly for the farming community.
We believe we are well placed to provide a practically based submission
to the Sub-committee.
In our evidence to the Sub-committee we have
commented on the UK Biodiversity Action Plan (UKBAP) process and
highlighted those actions we believe that farmers can take to
support the targets set in the plans. In forming our response
we are conscious of a number of key principles:
— Farmers and growers have a special
contribution and responsibility to protect and enhance biodiversity.
Farming actions have created the diverse landscapes in which wildlife
and habitats are found. Farmers are proud of their contribution
as stewards of the nation's biodiversity. However we feel this
role has been undervalued by society and governments for too long.
— The farming community cannot take
on the conservation of the nation's biodiversity alone, as is
implicit from UKBAP process: This task is shared by society as
a whole. We are concerned that the "biodiversity partnership"
is still too immature, consequently there remains a gap between
farmers ability to deliver biodiversity targets and the aspirations
of the UKBAP process. Particularly farmers have limited economic
incentives to promote biodiversity—friendly farming practices.
The current depression in farming makes this situation especially
acute.
— The drivers of agricultural policy
remain at odds with a fuller expression of biodiversity conservation.
In particular the continuing development of open world markets
as a consequence of GATT, WTO and in Europe, the single market
continues to bring intense cost pressure on UK farming businesses.
Our trading partners are highly sceptical of the European model
of agriculture in which wildlife, landscape and farming are co-dependent.
At the same time retailers report equivocal support amongst consumers
for biodiversity—friendly (as opposed to organic) produce.
In this context market and policy signals on biodiversity are
confused and contradictory.
The Sub-committee will be aware that the Government
recently held a Farming Summit at Downing Street. Primarily this
addressed solutions to the farming crisis, however it also provided
an opportunity to consider longer term remedies for farm businesses.
These remedies include a more prominent biodiversity role—a
role emphasised in our contribution to the summit "Farming
for Britain—Our Contract With Society" published at
the same time.
We will now turn to three areas we believe that
the sub-committee should consider during its inquiry.
1. UK BIODIVERSITY
ACTION PLAN
Since its launch, the NFU and individual farmers
have been active participants in the UKBAP process. We recognise
that the process will fail to meet its objectives if it does not
have the support of a wide ranging partnership across society
and especially those who manage the countryside. Hence we are
pleased to be represented on the UK Steering Group, country groups
and many regional and local initiatives.
However we are conscious that much of the effort
put into the UKBAP has been focused on plan preparation and monitoring
rather than action.
This emphasis continues at a local level with
the preparation of local biodiversity action plans. While recognising
the value of clear priority setting and partnership formation,
farmers are becoming increasingly frustrated with the lack of
obvious plan implementation. This is a particular issue locally
as action is most often achieved by targeting agri-environment
schemes (which is a regionally-driven process). The situation
is further compounded by confusion over the relative importance
and contribution of other local "plans", such as local
environment action plans (LEAPS), local agenda 21 plans (for sustainable
development) and local development plans. We believe that the
Government needs to move quickly to clarify how these processes
are intended to complement one another.
The national UKBAP process by contrast has considerably
greater clarity of role. The primary concern at this scale is
the number of plans and steering groups charged with its implementation.
Unfortunately it has been impossible to participate in all the
groups that have an agricultural dimension, as fully as we would
wish or feel necessary. To some extent, the situation has been
improved by the creation of "umbrella" habitat groups
and corresponding status on other groupings, however the steering
and monitoring of action plans from an agricultural perspective
remains unsatisfactory.
2. CONSERVATION
LEGISLATION
The UKBAP process has been particularly welcome
in that it has sought to attain biodiversity targets by a combination
of means including where necessary legislation. In this respect
it has provided a model for better regulation, an important goal
for the Government. We accept that legislation is needed to protect
wildlife where other means are impractical or inappropriate. In
this respect the current draft wildlife legislation contained
in the Countryside and Rights of Way Bill rightly seeks to achieve
a balance between the rights of the individual and society.
However we have some doubts that the Bill achieves
this balance in all respects. For example, it notably fails to
place a duty on the conservation bodies to contribute to the goal
of sustainable development through their biodiversity actions:
a duty which already is the primary function of the Environment
Agency.
In a similar way we are concerned that the draft
legislation provides English Native and CCW with new powers with
little reference to a knowledgeable third party—for example
when serving management schemes on owners and occupiers of SSSI's.
Our greater unease is that the Minister has
still not made clear his intention to fully fund the costs of
securing positive SSSI management. The Sub-committee will be aware
that English Nature in oral evidence to the House of Lords last
year estimated that it required £20 million/year to meet
the immediate needs of SSSI management. In the absence of commitment
to meet this need, we are concerned that owners and occupiers
will find a stronger stick than a carrot.
The application of the EU's Habitats and Birds
Directives is also causing considerable concern to the farming
community. This has been primarily due to the requirement on the
"competent authorities" (such as the Environment Agency
and local planning authorities) to ensure that consents or permissions
they grant will not cause significant damage to the integrity
of any "Natura 2000 Site" (sites designated or awaiting
confirmation under these European directives) unless exceptional
reasons apply. Our concern is that the agencies are applying the
required test extremely cautiously and with little sense of proportion.
Hence for example even minor consents for renewal of abstraction
licences are required to undertake onerous and costly environmental
assessment out of proportion to the scale of the permission sought.
3. AGRICULTURAL
POLICY AND
PRACTICE
We have already commented that the EU's agricultural
policy has still some way to develop to fully integrate biodiversity
objectives. However the recent Agenda 2000 settlement which embodied
a further round of CAP reform has made considerable progress in
the right direction with the approval of the Rural Development
Regulation. This amongst other measures designed to improve the
economic, environmental and social capabilities of rural areas,
requires member states to run agri-environment schedules across
their entire territories. As a consequence there is to be a planned
expansion in funding for Countryside Stewardship, Environmentally
Sensitive Areas and (in Wales) Tir Gofal. Agri-environment schemes
will absorb 62 per cent of the total England budget and 40 per
cent of the Welsh RDR budget between 2000 and 2007. This will
undoubtedly be beneficial for wildlife and the UKBAP target species
and habitats.
Farmers have already shown that they are keen
to participate in environmental land management schemes. In England
by 1998 over 650,000 hectares were entered into voluntary agri-environment
measures. We expect that this growth will continue over the next
seven years of the Rural Development plan implementation period.
However biodiversity-friendly farming is not
dependent only on agri-environment schemes (which also seek to
achieve landscape, heritage and public access objectives too).
Many arable farmers are now also implementing integrated crop
management techniques, which seek to minimise the use of fertilisers,
pesticides and other artificial inputs while maintaining a similar
standard of output. Other farms are responding to market place
initiatives and converting to organic systems. Both organic and
integrated crop management systems can be beneficial to wildlife.
Similarly livestock farmers are also seeking
to improve their environmental performance most obviously by improving
effectiveness of their use of farmyard manures and by implementing
farm waste management plans.
In summary what we are finding is steady progress
to address biodiversity concerns across a range of farming activities—progress
may not be as rapid as some would wish, but farming practice is
changing for the better (see for example MAFF's publication "Towards
Sustainable Agriculture—a pilot set of indicators").
SUMMARY
We welcome the Sub-committee's inquiry on UK
Biodiversity which comes at an important time for both wildlife
and the farming community. It is now over five years since the
last Government committed itself to implementing the UK Biodiversity
Action Plan. However during this period agriculture has experienced
an unprecedented economic crisis which threatens farmers' ability
to deliver biodiversity-friendly land management that was previously
regarded as a normal part of farming practice. In addition the
recent reform of the Common Agricultural Policy and especially
the launch of the Rural Development Regulation provides the hope
of new opportunity for both farming the countryside and its wildlife
on a scale not previously envisaged.
Farmers accept, and are proud of their role
in protecting the nation's biodiversity heritage and have the
potential to do more. However barriers to biodiversity conservation
remain to be overcome not least the apparent reluctance of consumers
to express preference for biodiversity-friendly products in their
buying decisions.
June 2000
| 
