Memorandum submitted by English Nature
1. Organic farming has an important contribution
to make to maintaining a healthy environment and supporting the
recovery of biodiversity. Organic farming illustrates a significant
trend in farming which has implications beyond the small current
area under registered organic production. Increasingly there is
a divergence between farming types in Britain. Large-scale food
markets demand large quantities of uniform, low cost products
as raw materials for the food industry. Conversely, there is rapid
and growing element amongst consumers who have expectations that
their food is produced to high ethical standards, exemplified
by concerns for animal welfare, social justice and the environment.
Both the practices of organic farming and the certification of
its products provide a guarantee to consumers that these ethical
issues have been taken into account in farming. Other farming
practices also need to be adapted to reduce their adverse impact
on the environment and to support the delivery of environmental
goods. Agri-environment and rural development initiatives have
an important role to play here. Wider adoption of the environmental
considerations which are now the hall-mark of the organic farming
system would be helpful here. This is necessary to help reverse
the serious decline of wildlife on farmland.
2. On land where organic farming is practised
English Nature believes that the evidence is strong that it has
significant positive benefits for wildlife on both the non-cropped
and, importantly, the cropped areas of the farm. These benefits
can be summarised as:
2.1 Greater diversity of wildlife (more wildlife
2.2 Higher abundance of wildlife (more individual
animals and plants).
2.3 Improved survival of species which have
become rare or are rapidly declining on conventional farmland.
3. The existing organic standards provide
the most stringent production system protocol for any sector of
the farming industry and provide a real opportunity for helping
to reverse some of the catastrophic declines in farmland biodiversity
which have been seen in the UK in recent decades.
4. Although existing organic practices and
standards are good, there is still room for improvement. English
Nature is actively working with the Soil Association to improve
further those parts of their standards which impact on farmland
biodiversity. Furthermore we would like to see these higher conservation
standards apply to all UK organic farmers and to products imported
5. The eventual size of the impact which
organic farming has on UK wildlife will depend not only on how
good the system is for wildlife and how well farmers implement
it but also on how much of the UK's farmland it comes to occupy.
Farmers face many challenges in converting to organic farming
and, to date, many do not have the confidence in the future to
make a commitment to organic production. English Nature would
like to see the Government do these things:
5.1 continue to implement the Rural Development
Regulation effectively with the increased budget recently announced;
5.2 expand the budget further for all agri-environment
measures (including organic conversion);
5.3 adopt a strategic and proactive approach
to supporting the expansion of the organic farming sector until
the supply of produce is brought into line with consumer demand.
1.1 English Nature is the statutory body
responsible for advising both central and local Government on
nature conservation and for promoting the wildlife and natural
features of England. In fulfilling its duties, English Nature:
advises Ministers on the development
and implementation of policies for nature conservation;
advises Ministers on other policies
affecting nature conservation;
identifies, notifies and safeguards
Sites of Special Scientific Interest (SSSIs);
establishes, maintains and manages
National Nature Reserves (NNRs);
provides guidance and advice on the
principles and practice of nature conservation to a wide constituency;
commissions and supports research
and other projects relevant to nature conservation.
1.2 Through the Joint Nature Conservation
Committee, English Nature works with sister organisations in Scotland,
Wales and Northern Ireland to advise Government on UK and international
nature conservation issues.
2. SCOPE OF
2.1 English Nature is not qualified to comment
on some of the issues raised in the press notice which launched
this enquiry. Additionally there is one area, the biodiversity
benefits of organic farming, which is not mentioned in the press
notice and where we would like to draw the committee's attention
to what English Nature believes is important new evidence. We
will comment on:
(1) The biodiversity benefits of organic
(2) The role of farm assurances schemes;
(3) The role of organic certification organisations
and the setting of organic standards.
3. THE BIODIVERSITY
3.1 English Nature has been concerned for
many years at the damage done by intensive farming, not just to
the special wildlife sites which it is our particular role to
protect, but also to the wildlife which until recently was an
integral part of the fabric of the whole countryside.
3.2 Published and peer-reviewed, ecological
research has identified some of the more damaging practices of
conventional agriculture which have been responsible for many
of the species declines recorded in the wider farmed environment
in the last half of the twentieth century.
3.3 There are good grounds for expecting
that organic farming, as it is routinely practiced in the UK lowlands,
will help to reverse or at least mitigate many of these practices
and produce an environment which is more attractive to our native
wildlife. These theoretical grounds are detailed at annex 1.
3.4 English Nature recently reviewed the
available published evidence, all of which relates to the lowlands,
which has sought to test this hypothesis and this review is attached
at annex 2.
3.5 In summary the review concluded that
in making a change in land management as fundamental as moving
from conventional to organic farming there are bound to be wildlife
species which benefit and others which will lose out. There are
some clear conclusions which can be drawn from the studies reviewed.
The most important of these conclusions are that, when comparing
the two farming systems, then on balance:
3.5.1 there are higher numbers and greater
densities of non crop species (wildlife) on organic farms;
3.5.2 there is a greater diversity of wildlife
on organic farms;
3.5.3 overwhelmingly, whether it is Birds
of Conservation Concern, rare arable weeds or non pest butterflies,
the wildlife species which have suffered the greatest declines
on farmland in the last 50 years do better under an organic farming
3.6 English Nature's Council examined the
evidence attached at annex 1 and 2 at a meeting on the 17 May
2000 and subsequently issued the position statement on Organic
Farming attached at annex 3 [not printed].
3.7 Ultimately it may not matter how good
a particular farming system is for wildlife if it only occupies
a small proportion of the landscape. For organic farming to make
a meaningful impact on the farmland biodiversity crisis it will
need to grow until it occupies a far more significant area. The
potential for this is there, in the rapid increase in consumer
demand, the extent to which imported produce could be substituted
by home grown and the impressive growth rates (albeit from a low
base) which organic farming has achieved in recent years.
3.8 In parallel, other farming systems need
to deliver equivalent biodiversity benefits. We need environmentally
sensitive farming across much more of the English landscape. English
Nature has an inclusive approach to the farming community and
gives advice on how to safeguard and enhance wildlife on all farms.
English Nature believes organic farming offers part of the solution
to enhancing biodiversity. We are keen to work with everyone in
the agriculture industry especially those who share our vision
of recreating many more biodiversity rich landscapes. All farming
systems will need to address the issues identified in our position
statement on environmentally sustainable agriculture and nature
conservation (Annex 4 [not printed]).
4. THE ROLE
4.1 English Nature participated in a DETR
sponsored evaluation of the environmental conditions of quality
assurance schemes for food production in 1999
which looked at conventional farm assurance schemes.
4.2 An examination of the way in which organic
farm assurance delivers results to both the environment and farmers
reveals a number of critical and interlinked factors, which will
need to be in place for any farm assurance scheme which aspires
to use the consumer market to support the delivery of wildlife
benefits. Organic farming has:
4.2.1 a defined and regulated set of standards;
4.2.2 a proven ability to deliver wildlife
4.2.3 a brand which consumers trust;
4.2.4 lower levels of per hectare productionwhich
are a feature of wildlife friendly farming;
4.3.5 premium prices which pass back down
the supply chain to the farmer. This compensates for the lower
level of production.
4.3 Continuing to secure these benefits
will require that any farming system maintains a high level of
integrity in order to secure public confidence. English Nature
is aware of anecdotal evidence that lack of specific biodiversity
training among some organic advisors and inspectors has compromised
the generally high quality of advice which is available to both
converting and practicing organic farmers. We would like to see
specific training put in place to rectify this deficiency.
4.4 To date, most farm assurance schemes
only benefit wildlife as an incidental consequence of following
good agricultural practice (as defined in the codes) in pursuit
of other objectives, especially food safety. It is essential that
more progress is made in pursuing practicable codes of conservation
management within the increasing range of farm assurance standards.
5. THE ROLE
5.1 All UK organic production has to confirm
with standards set by the UK Register of Organic Food Standards.
These reflect, and may further enhance, base line standards set
by the European Union.
5.2 Individual certification bodies may
decide to further enhance their standards. Historically the Soil
Association has led the way in this field and for many years has
included additional wildlife standards in its own regulations.
5.3 While acknowledging the important role
which organic farmers have taken in pioneering the development
of a wildlife friendly farming system English Nature feels that,
with a little extra effort, there is more which organic farming
could deliver for wildlife.
5.4 English Nature is concerned on three
5.5.1 The increasing number of new entrants
to organic farming who are opting to register with certification
organisations who adopt the lower (in terms of wildlife protection)
5.5.2 The potential for some future developments
in organic agronomy to erode some of the present intrinsic benefits
to wildlife of the organic farming system, eg stockless organic
5.5.3 the large proportion of UK organic
consumption which is produced overseas and which is rarely produced
under codes which follows explicit conservation management standards.
5.5 English Nature has been working closely
with the Soil Association since 1998 to try and improve the conservation
elements of the Soil Association standards. We welcome the way
in which the Soil Association has actively encouraged the involvement
of wildlife conservation organisations in this process.
5.6 In order to guard against the concerns
outlined in 5.5.1 and to further underpin consumer confidence
in organic farming as a wildlife friendly system of food production
English Nature would like to see the additional safeguards for
wildlife, adopted by or under discussion with the Soil Association,
incorporated into the UKROFS regulations so that they apply uniformly
to all UK organic production.
5.7 English Nature would also like to see
action taken at international (EU and globally through IFOAMthe
International Federation of Organic Agriculture Movements) to
ensure that enhanced and relevant biodiversity standards are applied
to all organic production.
13 June 2000
24 Bains, R N; Dee T M; Manley; W J. & Smith G
P. Quality Assurance Schemes For Food Production-An Evaluation
Of The Environmental Conditions. Department of the Environment
Transport and the Regions Report. April 2000. Back