APPENDIX 35
Memorandum submitted by English Nature
(A46)
INTRODUCTION
1. English Nature is the statutory body,
which champions the conservation and enhancement of the wildlife
and natural features of England. We work for wildlife in partnership
with others by:
— advising—government,
other agencies, local authorities, interest groups, business communities,
individuals on nature conservation in England;
— regulating—activities
affecting protected species and the special nature conservation
sites in England;
— enabling—helping others
to manage land for nature conservation, through grants, projects
and information;
— enthusing—and advocating
nature conservation for all and biodiversity as a key test of
sustainable development.
2. We have statutory duties for nationally
and internationally important nature conservation sites including
Sites of Special Scientific Interest (SSSIs), the most important
of which are managed as National Nature Reserves (NNRs); Special
Areas of Conservation (SACs); and Special Protection Areas (SPAs).
3. 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.
ENGLISH NATURE'S
VISION FOR
FARMING
4. There has been a sea change in how society,
consumers and taxpayers regard agriculture stimulated by a growing
concern and awareness that farming is far more than just producing
food. BSE and FMD have raised huge issues about food safety and
the way in which farming is practised. Citizens increasingly realise
that farming is important for providing and sustaining attractive
landscapes, wildlife, access and of the links between farming
and many aspects of the economy of rural areas.
5. Decisions on the future for agriculture
and the food chain need to be set in the wider context of the
Government's commitments to sustainable development. Agriculture
and the food chain need to play their part in attaining the social,
economic and environmental elements of sustainable development.
A healthy environment is a key feature in achieving quality of
life for those who live and work in rural areas and for visitors
(DETR, A Better Quality of Life, 1999). Over 90 per cent
of people think we have a moral duty to protect the countryside
(Countryside Commission 1996). A healthy environment helps to
achieve social inclusion both for rural and urban communities.
6. English Nature wants to promote sustainable
rural development. Farming occurs over 75 per cent of the area
of England and as the most important manager of undeveloped land
it has a vital and diverse role to play. As a major cultural and
natural heritage asset for the nation, the countryside must be
safeguarded and enhanced. Our vision for farming that can help
achieve sustainable rural development is for it to:
— protect and improve the quality of
soil, air and water—providing long term sustainability and
providing for the range of uses of these resources;
— protect and enhance biodiversity
and integrate this into farm management decision making;
— protect and enhance the character
and diversity of landscapes;
— support viable rural communities
and the economies of rural areas;
— provide access to and encourage public
enjoyment of the countryside—providing the basis for wider
rural businesses based on visitors who enjoy and appreciate "rural
amenity" including biodiversity;
— protect and enhance the historic
environment; and
— provide high quality affordable food,
fibre and other products produced to defined environmental and
animal welfare standards.
7. To achieve this vision the subsidies,
quotas and other production related support mechanisms of the
CAP, which encourage unsustainable farming and environmental damage
should be stopped. Standards of agricultural practice should be
defined and enforced through a combination of regulation, advice
and codes of practice with transitional support available to help
farmers invest in the infrastructure that will raise farming's
overall environmental performance. Farmers should be encouraged
to provide public goods and services, such as a high quality and
diverse environment, through incentive schemes that are available
to all land managers.
THE EVOLUTION
OF THE
CAP AND THE
MARGINALISATION OF
ENVIRONMENTAL CONCERNS
8. The CAP has long been criticised for
its many negative environmental impacts. In highlighting the problems
of the current system, English Nature's role is to focus on the
wildlife and natural features of England, highlight the impacts
of farming on the environment, to offer suggestions on how these
negative impacts can be reduced and how the positive outcomes
can be encouraged.
9. The policies UK and European policies
to "modernise" agriculture after the Second World War
aimed to increase and intensify production and make farming more
efficient at producing bulk agricultural commodities for a largely
state controlled food chain. It was not appreciated at the time
that the "intensification" of agriculture (key elements
of which are greater mechanisation, labour shedding, greater use
of agro-chemicals, winter cropping, enterprise specialisation
and increases in farm and field size) would, in addition to increasing
productivity, have such a major and damaging impact on the countryside
and the wildlife that lived there.
10. The policies used to achieve or encourage
this process of agricultural intensification were a system of
price support for most of the main agricultural commodities and
the provision of advice and dissemination of research findings,
which was also focused on increasing production of crops and livestock
products. As production increased beyond that required by the
internal European market a system of quotas and export subsidies
were added to the CAP in order to limit production or dispose
of surpluses on external markets. The various commodity regimes
of the CAP have been under a process of almost continuous ad hoc
reform in order to try and control production and/or manage or
create demand for surplus products. The first attempt to strategically
reform the CAP was the 1992 MacSharry reforms. This package of
measures aimed to decouple some subsidies from production and
to introduce compensatory area payments or enhanced livestock
payments. The main driver of the 1992 reforms was not environmental
concerns; it was the need to control spiralling budget costs and
to make the CAP more compatible with moves to bring agriculture
into world trade negotiations. The impact of agriculture on the
environment was a marginal issue for CAP reform in 1992 and not
surprisingly the reforms failed to deliver any significant environmental
improvements. The environment had become a more important factor
in the latest Agenda 2000 CAP reform package, although the final
agreement reached in the Berlin Heads of Government Summit in
1999 again diminished the Commission's proposals to "green"
the CAP. Looking forward to the mid-term review of the Agenda
2000 agreement, starting in 2002, the impact of the CAP on the
environment is again struggling to be included as part of the
review. The focus of political attention is the expansion of the
European Union and compatibility of the CAP with a new round of
world trade negotiations.
THE ENVIRONMENTAL
COSTS OF
PRODUCTION SUBSIDIES
11. Three broad types of inter-related factors
drive agriculture: economics and markets, adoption of new technology
and the governance of the sector through policies, subsidies,
advice and publicly funded research and development. The role
of governance, however, has been the primary and most important
driver of agriculture and has not only had a major influence of
farm business decision making, but also on shaping markets and
providing an important contextual driver for research and development.
12. Over the last 50 years, agriculture,
led by the policies and incentives outlined above was focused
on increasing food production irrespective of the environmental
costs. Farmers have responded by applying new technology and farm
management practices that have intensified and specialised farm
businesses to maximise production. This also contributed to a
massive decline in diversity of wildlife, the loss of natural
features and the erosion of distinctive local character. As a
general rule biodiversity has been pushed to the margins of modern
conventional agriculture, except where physical constraints prohibit
this, as in the uplands. On the majority of farms biodiversity
now subsists as a residual resource peripheral to most production
systems and farm businesses. The net effect of the processes of
agricultural intensification and specialisation has been to replace
ecological and landscape diversity with uniformity. The CAP has
also failed to give farmers the right policy signals to help them
adapt to consumer demands and build viable businesses.
13. The various ways in which the CAP encourages
unsustainable land management and leads to damage to the farmed
environment are illustrated in the three specific examples given
in the Annex: livestock subsidies and overgrazing; the loss of
England's species rich grassland; and the overuse of inputs.
HOW BETTER
STEWARDSHIP OF
AGRICULTURAL LAND
CAN BE
PROMOTED
14. The recovery of biodiversity on farmland
and freshwaters is the main objective for English Nature in the
development of new policies for farming and the food chain and
is also fundamental to achieving the Government's wildlife PSA
targets, fulfilling commitments to the UK Biodiversity Action
Plan and other international obligations such as the Water Framework
Directive.
15. In its recent submission to the Government's
Policy Commission on the Future of Farming and Food, English Nature
set out the key issues for nature conservation that need to be
addressed through active land management, these include:
— Reversing habitat fragmentation;
— Creating environmentally sustainable
grazing regimes, particularly with regard to overgrazing in the
uplands and the lack of appropriate grazing in the lowlands;
— Allowing managed realignment of coasts
where coastal habitats are squeezed between rising sea levels
and land defences;
— Reversing the decline in farmland
species both on arable land and intensive grasslands; and
— Reversing the decline in quality
of important freshwaters and wetlands, which have been damaged
by excess nutrients and sediment.
16. Removing production subsidies or quotas
alone with not achieve these objectives; what is required is an
approach that both removes the damaging subsidies and uses a range
of policy instruments including legislation, advice, and incentives
to enable farmers and other land managers to manage land in ways
that deliver positive environmental objectives. A radical CAP
reform agenda, therefore, needs to be about dismantling production
subsidies and production quotas while simultaneously greening
remaining support regimes and transferring resources into new
agri-environment and rural development measures.
17. In advocating this process of reforming
the CAP it is important that the distinction between a production
subsidy and a payment for an environmental public good is both
understood and the distinction clearly maintained.
A TIERED APPROACH
TOWARDS BETTER
STEWARDSHIP OF
THE COUNTRYSIDE
18. English Nature advocates a tiered approach
for achieving better stewardship of the countryside. The foundations
of the approach should be the basic standards that farmers and
land managers should meet without publicly funded incentives.
This includes meeting requirements of legislation and various
codes of good farming practice. Such standards should cover environmental
protection, food safety and animal welfare.
The UK should be in the vanguard of countries
setting high standards for agriculture while ensuring that UK
competitiveness is not undermined.
19. UK competitiveness should be based on
producing high quality food based on high standards with clear
labelling and marketing to ensure consumers can make an informed
choice to buy such produce. It is not acceptable to try and maintain
short-term competitive advantage by reducing standards to the
lowest level adopted by either other EU countries or those outside
EU. Where new agricultural standards are being proposed or have
been agreed then the Government should develop a strategy, in
partnership with statutory agencies and the industry, to help
the industry prepare for the higher requirements before they become
a legal obligation. This could include information and advice
and where appropriate help with investment and grant aid.
20. High standards of land management should
also be reinforced through applying environmental conditions to
all farm support payments.
21. Above this foundation should be a "broad
and shallow" agri-environment scheme, such as English Nature's
proposed Basic Stewardship Scheme, which would be available to
the majority of farmers and land managers and be applicable to
achieving environmental objectives across the great proportion
of the farmed countryside. Such a scheme would help address the
protection of the quality of land, air and water, protect and
enhance the landscape and historic environment and help deliver
the Government's commitments to UK Biodiversity Action plan targets
and meet the Government's PSA targets on reversing the decline
of farmland birds by 2020. A Basic Stewardship Scheme should also
be administratively simple and have lower transaction costs than
the current range of schemes.
22. Above the Basic Stewardship Scheme should
be an agri-environment scheme, or schemes, which reward land managers
for more ambitious protection, enhancement and restoration of
the farmed environment. Specific areas of farms or areas of the
countryside that have particular environmental quality, such as
Areas of Outstanding Natural Beauty, scheduled ancient monuments
and Sites of Special Scientific Interest may need more detailed
environmental management requirements to maintain, enhance or
restore them. This kind of scheme would be available on top of
the Basic Stewardship Scheme and would complement rather than
duplicate. Such scheme can, again, help meet various Government
targets including the PSA target of getting 95 per cent of SSIs
into favourable condition by 2010.
23. Markets have a complementary role in
ensuring food production meets food safety, animal welfare and
environmental standards, although markets alone are currently
unable to deliver a diverse, attractive and wildlife rich countryside.
Industry led assurance schemes can help build consumer confidence
and make the link from "farm to fork". Current farm
assurance schemes, however, offer little in terms of guaranteeing
food was produced to high environmental standards. There are also
marketing opportunities that capitalise on meeting higher production
standards, built on a range of attributes such as health, convenience
and locality. There are also opportunities for greater added value,
direct marketing and more direct selling to consumers, such as
through farmers' markets. This would also help farmers achieve
a higher farm gate price for their produce.
PROSPECTS FOR
PRODUCTION SUBSIDIES
AND QUOTAS
24. The prospects for production subsidies
and quotas can be considered in relation to opportunities in the
short, medium and long term.
25. Short term opportunities—the Agenda
2000 agreement still provides scope for further movement away
from production led subsidies:
— Modulation provides a way that member
States can re-deploy funds from farm subsidies and into incentives
for providing environmental public goods through agri-environment
schemes. English Nature welcomes the Government's decision to
modulate direct farm subsidies at 2.5 per cent rising to 4.5 per
cent by 2006, but recommends that the Government should use the
discretion given to it under the Rural Development Regulation
to modulate to the 20 per cent allowed.
— Under the beef (and possibly the
sheep regime by 2002), member States can use a proportion of the
direct subsidies to support particular elements of the Industry
through so called National Envelopes. English Nature urges the
Government to use whatever discretion it has open to it to change
the nature of funding away from headage payments to area based
payments to encourage environmentally sustainable production systems.
26. Medium term opportunities:
— The mid-term review of the Agenda
2000 CAP reform agreement provides an opportunity to revisit the
need for further reforms, particularly with regard to the livestock
and dairy regimes which are at various stages of being decoupled
from production. The beef regime is very complex and comprises
a confusing range of headage and extensification payments for
breeding cows and some finished stock with limited additional
price support. The sheep regime is based on a premium on the breeding
ewe controlled by quotas, and as shown in the Annex, encourages
production at the expense of environmentally sustainable land
management. The dairy sector is largely unreformed and remains
a price support system with production controlled by milk quotas.
In terms of land and farm management the beef, sheep and dairy
sectors are inextricably linked and future support needs to be
considered as a package and not looked at separately. The key
reform should be the move away from headage payments and quotas
towards an integrated area based payment linked to environmental
land quality and the protection and production of environmental
goods. The mid term review is an opportunity to put forward proposals,
start a debate on the future of the dairy and livestock support
and begin a clear progressive process of reform.
27. Long term opportunities:
— In the long term the only justification
for paying public money should be for the provision of public
goods. This should be the aim of the 2006 CAP reform process.
This should include all the major regimes; particularly from a
UK perspective, the livestock regimes and the arable regimes.
This would allow the EU to reform the CAP in line with the position
adopted as part of the Doha WTO agreement, which put a significant
emphasis on the removal of export subsidies for surplus agricultural
products.
THE OPPORTUNITIES
AND DIFFICULTIES
FACED BY
AGRICULTURE AS
A RESULT
OF POSSIBLE
REDUCTIONS IN
PRODUCTION SUBSIDIES
28. For entrepreneurial farmers and land
managers there are major opportunities from the move away from
production subsidies to a more market orientated approach. Future
production, however, must respect the environment, animal welfare
and food safety standards. Public money should be redirected away
from production subsidies and made available for the production
of public goods, such as wildlife and the maintenance, enhancement
and restoration of habitats.
29. Current production subsidies, however,
represent a significant proportion of farm incomes and adjustment
to a new basis for the public support for farming will be difficult
for many. There needs to be a phased transition of measures to
help the industry readjust to the different expectations on them.
Farmers need to embrace the concept that as land managers they
fulfil a variety of valuable roles for society and are not only
food producers.
English Nature
19 December 2001
| 
