APPENDIX 25
Supplementary memorandum submitted by
the Environment Agency (A35(a))
1. BACKGROUND
There is an increasing acceptance that agriculture
needs to have greater regard for the environment. It is important
that the protection of natural resources (water, land and air)
is recognised and addressed within any overall strategy.
Agriculture has significant environmental impacts
on soil, water and air. Protection of natural resources is fundamental
to both sustainable development for the UK and sustainable agriculture.
Failure to protect these key resources is clearly unsustainable.
Available evidence suggests that the cost of current agricultural
practices to natural resources could be in the range of £1.3
billion annually.[25]
These costs are conservative due to the exclusion of the cost
of loss of amenity and recreation, habitat and biodiversity value
and some health impacts.
If best available techniques were implemented
to address the environmental problems, reductions in these costs
of around £0.3 billion in the short term, increasing to £0.5
billion in the longer term are achievable.
More environmental legislation from Europe is
already in the pipeline and the costs of implementing and complying
with this will be substantial. To prepare for and meet these requirements
urgent action needs to be taken to raise the environmental performance
of all farms.
2. GOOD AGRICULTURAL
PRACTICE AND
PUBLIC GOODS
Good Farming Practice (GFP) should be the standard
all farmers are expected to meet as part of their normal business
practice. If all farms were to adopt GFP most environmental impacts
would be manageable. However, even though many farmers and land
managers support measures to protect the environment, in practice,
standards generally fall well below this level for the following
reasons:
— lack of awareness and acceptance
of the environmental impacts by those within the industry, leading
to lax environmental management;
— difficulties in measuring performance
because a number of different definitions of GFP currently exist;
— technology and knowledge transfer
from the Government to the farming industry has been patchy.
The DEFRA Codes of Good Agricultural Practice
do not provide a clear definition of GFP (and were not designed
to do so). Additionally the Codes are not particularly well known
or adopted. Practices in the industry need to change quickly if
European obligations are to be met.
In priority locations, measures more stringent
than GFP need to be adopted, to achieve the environmental outcomes
necessary to meet site specific European obligations such as the
Habitats Directive. Farmers going beyond GFP should be seen to
be delivering public goods above and beyond their social responsibilities.
In theory, greater public goods may be delivered on any farm.
In practice, because money is limited, Government investment on
farms should occur where the net benefits are highest.
3. WHAT IS
NEEDED?
Whilst action on farms is needed urgently, in
the short-term this action could be driven most effectively by
non-regulatory, knowledge transfer and grant-supported approaches.
The Agency believes that the way forward is to:
(a) Define clearly what is meant by GFP,
determining what are basic responsibilities and what public goods
society should pay for
(b) Provide mechanisms limited to an initial
time period to enable farmers to raise performance to meet GFP
standards, and where necessary, European obligations
(c) Provide mechanisms to take action against
poor performers
(d) Pay farmers to deliver genuine public
goods.
Our suggested strategy consists of two phases
separated by a review point.
— Phase I—A transitional,
non-regulatory phase in which all farmers are proactively helped
to bring their farms up to GFP, whilst farms in priority areas
are taken beyond GFP to protect specific catchments or habitats.
The infrastructure, training and advice needed to achieve this
should be grant-supported. There may also be a need for support
for capital investments. The Agency's proposed Environmental Management
System for Farms could provide the basis for this phase.
— Review point—Depending
upon the progress made towards performance targets in Phase I,
decisions can be made as to whether and what hard regulatory action
is required to guarantee the required performance levels in Phase
II.
— Phase II—Hard regulatory
approaches should be adopted as necessary to tackle under-performing
farms. No further grant-aid should be provided to bring farms
up to the basic level of GFP. Some continuing support will still
be needed for those farms delivering public goods.
This approach is illustrated by the diagram
in Annex 1.
4. AN ENVIRONMENTAL
MANAGEMENT SYSTEM
FOR FARMS
(EMSF)
The Agency's proposed Environmental Management
System for farms (EMSF) is key to this approach. It will enable
farmers to:
— Undertake a site-specific audit and
environmental impact assessment of the farm
— Use the audit as the basis for developing
and implementing environmental management into business planning
— Demonstrate that GFP is understood
and is being met
— Identify delivery of public goods
For Government and the regulator this means
both better environmental performance and cost-effective, better
regulation, allowing effort to be concentrated on poor performers.
28 February 2002
25 Agriculture and Natural Resource Problems: Benefits,
Costsand Potential Solutions-Environment Agency draft report. Back
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