Select Committee on Agriculture Appendices to the Minutes of Evidence


Memorandum submitted by the Council for the Protection of Rural England (H 3)

  1.  CPRE is a national charity which helps people to protect their local countryside where there is threat, to enhance it where there is opportunity and to keep it beautiful, productive and enjoyable for everyone. Our interests in IACS derives from the significant impact that its implementation in relation to CAP schemes can have on the environment.

  2.  CPRE welcomes the opportunity to submit our views and comments to the Committee's inquiry into the implementation of IACS. Our submission is restricted to comments regarding the need to ensure that environmental objectives are fully integrated within CAP schemes relating to IACS. This is essential if the environment is to be put at the heart of agricultural policy, in keeping with the European Union and the UK Government's stated commitments.

The need to integrate environmental objectives within IACS

  3.  The European Union is required, through the Maastricht Treaty, to ensure the integration of environmental and agricultural policy. Article 130r(2) states that "environmental protection requirements must be integrated into the definition and implementation of other Community policies". Indeed, the Cardiff European Summit in June 1998 reinforced this by concluding that "integration of environmental considerations into other policies is no longer an option but an obligation".

  4.  The need for environmental responsibility within agriculture policy has also been publicly recognised by the Agriculture Commissioner Franz Fischler. In November 1999 he stated that "nobody can seriously question that farmers and agriculture have many and diverse roles to play, all of which we take account of in our agriculture and rural development policy. As well as being a producer of a rich variety of high quality and safe foods, it also has the key and growing role in protecting the rural environment, preserving rural landscapes . . . These are services for the public good, services the public expect and indeed demand". The UK Government has reiterated the importance of this in its New Direction for Agriculture, stating that"the aim for agriculture—as for every other industry—is that it should not harm, and indeed should enhance, the environment".

  5.  These policy statements and obligations are, however, not always borne through in practice. One notable example is the conflict that has arisen over the past 12 months in the UK concerning the restriction of the width of field margins eligible for payments under the Arable Area Payments Scheme (AAPS) to two metres. The negative implications that this could have on the landscape, the environment and the drive for more sustainable farming practices has starkly illustrated the need for environmental requirements to be integrated into CAP schemes relating to IACS.

  6.  The conflict arose when the European Commission decided to strictly enforce European guidance (pertaining to Article 6 of EC Regulation 3887/92 on rules for applying the integrated administration and control system for certain Community aid schemes) restricting the width of field boundaries to a maximum of two metres for farmers claiming Arable Area payments on the whole field area. This decision removed the flexibility in calculating arable areas that had previously been acceptable in order to ensure the continued traditional management of the network of hedgerows, banks, ditches, walls and other field margins, central the fabric of the UK countryside. This flexibility had also encouraged farmers to adopt uncropped field margins and sympathetic management of hedges and ditches in accordance with sustainable crop management principles to help control weeds and pests without using agro-chemicals.

  7.  Solutions to this problem are still under consideration by the European Commission. The implications, however, of the initial decision for both farmers and the environment were extremely alarming. Not only would it have reversed progress in persuading farmers to adopt more sustainable management practices, it would have actively penalised those adopting field margins in the future, resulting in a reduction in hedgerow width, the loss of field margins and the intensification of field-edge management. This loss of habitat and the further fragmentation of the landscape would have had a severe impact on the promotion of sustainable farming practices as well as on the landscape and biodiversity. The decision would also have hindered progress in fulfilling European Union commitments regarding linear features under the Habitats Directive and would have run counter to the European Commission's strategy on Biodiversity.

  8.  A report published by Wildlife and Countryside Link, Field Margins and the Common Agricultural Policy: the need to integrate environmental objectives into the Arable Area Payments Scheme (copy enclosed [not printed]), and supported by 17 environmental and farming organisations looks at the issue in more detail and suggests a number of solutions. The European Commission is currently looking at finding a workable solution to the problem and we hope this will remove the inconsistencies between environmental and agricultural objectives that exist within the AAPS and IACS currently.

  9.  This particular conflict experienced in the UK exposes a much greater inconsistency in European agricultural policies regarding the positive promotion of sustainable farming practices within agricultural policies. All of Europe's farmers should be encouraged to follow environmentally sustainable farming practices through CAP policies, subsidies and schemes and the way IACS is interpreted and implemented should enable this to happen. European policies for the environment and IACS should work together rather than against each other, recognising the importance of the environment for the future of farming throughout Europe. This will be essential if the European Commission wants to make progress on achieving the Union's overarching policy objective for greater integration of the environment into agriculture.

31 October 2000

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