Memorandum submitted by the Country Land and Business Association (CLA) (G8)
INTRODUCTION
1. The Country Land and Business Association (CLA) is making a written submission to this inquiry because:
— from 1976 to 2001 the CLA advocated the creation of a rural affairs department in Government, to deliver integrated policies for rural communities and businesses and the rural environment. Between 1997 and 2001 CLA submitted a number of papers to Government on the need for and objectives of such a department, and these submissions were reflected in the public statements made by the CLA over the same period;
— CLA's membership straddles a wider range of economic activities in the countryside. As land managers, generators of jobs and incomes, providers of housing, and of capital and land for investment, and as businesses in their own right, CLA members can help deliver Government's objectives for rural development, environmental conservation, and recreation and leisure, so long as public policy works with, not against, the grain of rural business;
— the future of our members' enterprises and the future of the rural economy are interlinked; they are imperilled by external pressures—such as global, political and trade factors in food and farming—and public policies (whether it be at European, national, regional or local level) which fail to recognise that the countryside is not something apart, to be "protected for its own sake", but a functioning part of the national whole. The countryside must be able to grow and change organically, to deliver products (food, conservation, recreation, goods and services) to the rest of the country and be kept clean, healthy and unpolluted;
— CLA wants to see DEFRA succeed in: promoting sustainable development; fostering viable rural communities; securing satisfactory access to services in rural areas; promoting profitable farming, food, forestry and other business in rural areas; encouraging environmental land management; and promoting increased recreation and leisure opportunities in the countryside—for those who live and work there as well as the wider population.
2. This submission follows the themes set out in the Committee's commissioning announcement, but brings in new subjects for consideration where justified. These have been linked to particular questions asked by the Committee wherever possible.
3. The submission cross refers—for information—to other statements made by the CLA. These can be accessed from CLA at 16 Belgrave Square, London SW1X 8PQ (020 7235 4696) or via CLA's website, www.cla.org.uk, but this submission is free-standing and produced in direct response to the Committee's inquiry.
4. CLA representatives, in particular those whose experience of farming and other rural businesses and conservation has brought them into direct contact with DEFRA officials or Ministers over the last year would be pleased to develop this submission or respond to questions on it at any oral evidence sessions that the Committee may organise.
SECRETARY OF STATE'S AND MINISTERS' VISION FOR THE DEPARTMENT—IS IT APPROPRIATE?
5. The vision is certainly a step forward from the consultation paper released by DEFRA last summer, in which the links between the economy, environment and community in rural areas were not understood or recognised, and the importance of a viable economy in rural areas underpinning the environment and the rural communities was placed too low down the list of priorities. In this vision the Secretary of State recognises that "diverse, economically and environmentally viable communities" are the first sign of a healthy countryside.
6. However, there is no sign in the vision of recognition by DEFRA of the importance that profitable farming plays in a thriving countryside and in the success of the national economy. Farming may provide only 2 per cent of GDP, but the food manufacturing and food service industries that it supports are responsible for a further 5 per cent or so of GDP, making the combined agriculture and food industry a major factor in the UK economy. Unless the Government believes that the manufacturing and all the food service industry would remain in this country without the support of a profitable primary production sector, then it is making a dangerous omission in ignoring the need for profitable agriculture. Does the Government really believe that food manufacturing and much of the food service industry would remain UK based if profitability ceased to return to British farming?
7. Furthermore, the benefits of profitable farming extend beyond the provision of food to the population, important though that is. Farming also supports related industries upstream, connects—a point made by the Curry report—the consumer with where their food comes from and provides a backdrop for tourism and inward investment. Farmstay UK, with some 1,200 accommodation properties on farm, trades on the desire of tourists to see working farming and livestock on the hills. Businesses re-locating to the countryside are interested not only in competitive rents; their employees want to enjoy rural surroundings, and this means the land being farmed, not decay and neglect.
8. CLA would wish to see explicit commitment from Government in two other ways. First, to seeking non-regulatory methods to achieving policy objectives, wherever possible. This would apply most importantly to the measures needed to achieve the UK's Kyoto's commitments on climate change; to the implementation of already existing EU legislation on environmental protection; to the conservation of landscape and biodiversity in rural (and urban) areas; to the maintenance of the heritage quality of listed buildings. It is notable that the Environment Agency is coming to believe that its objectives of ensuring environmental protection could be more effectively—and ultimately less expensively—achieved through a more risk based approach, and through co-operation agreements with land managers. Sweden and Finland have found that the EU Nitrate Directive bears less heavily on those countries because they engaged in major programmes of voluntary agri-environment before they fell under the aegis of EU legislation. The ESA and stewardship schemes in the UK have brought farmers and conservation closer together in parts of the country. A Broad and Shallow Agri-environment Scheme—CLA would prefer the name "Broad Stewardship Scheme" could extend these benefits across the whole country and, by embracing natural resource protection as well as landscape and habitat management, avert an excessively heavy regulatory approach to environmental protection in future.
9. Second, CLA would wish Government to express its commitment to enabling the economy of rural areas to be competitive. Britain has high standards of welfare, food safety and environmental legislation—in some cases higher than elsewhere in the EU. This already makes it more difficult for British producers to put British products in front of our and other consumers at a competitive price. The weakness of the euro against the pound has weakened our competitive position further. Government must be mindful of this position each time it considers how to pursue its environmental and other objectives. Every time a British consumer decides to buy products imported, especially from outside the EU, he or she is acting in a way that supports lower standards of welfare, food safety and environment than our own. Not only do our producers suffer, but our environment suffers too, and so do our consumers, as members of the population. Such a commitment to competitiveness would concentrate the mind of Government when considering such ideas as a pesticides tax, which would have the effect of exporting production from our high standard economy to our importers'.
ARE PROPER WEIGHTS BEING GIVEN TO FARMING, FOOD, ENVIRONMENT AND CONSERVATION CONCERNS?
10. DEFRA is certainly trying hard to understand all these concerns, although, without repeating the points above, the economic importance of successful farming and rural businesses is not yet fully understood.
11. As important is an understanding in DEFRA of the linkages between different aspects of its work, and with work done in other departments:
— CLA produced a policy document in 2001 on the implications of climate change for the rural economy, and the opportunities for land management practices in rural areas, encouraged by Government as necessary, to mitigate the onset and effects of climate change. Climate change and the rural economy are linked.
— Public access and conservation are linked. While access can alert managers to the changes in environmental quality, they can also endanger that very environmental status. The effects on the environment of the Countryside and Rights of Way Act need to be measured and acted on as necessary.
— Farming and tourism are linked. The FMD outbreak showed not that in another outbreak farming should be sacrificed to tourism, because tourism is a bigger industry in its own right, but that without the attraction of healthy farming, tourists did not want to visit the countryside.
— Farming and food are linked in the ways described above.
— Rural development and planning policy are linked. Planning policy has a significant effect on the success of rural diversification, and in turn successful diversification has a positive effect on the viability of rural services serving the local community. Positive planning solutions can be a relatively cost-effective way of generating viable rural development.
— Policies for rural communities, local government and the survival of rural culture are linked. Recent decisions to require Parish Councillors to publish details of their sources of income run the risk of deterring just those people who have an economic stake in the future of their local economy and community.
12. These linkages are not yet well understood in DEFRA, especially at national level. This is not surprising given the newness of the department, and the previous experience of many officials, which may have been associated more with the complex running of CAP regimes, or with regulatory measures in DETR, than with initiatives and experiences on the ground in rural areas. Secondments to the Countryside Agency, and between regional offices and the national office, can only help.
IS DEFRA ENGINEERED TO DELIVER ITS OBJECTIVES?
13. Inevitably, the need to ensure delivery of required functions, such as CAP management, mean that DEFRA will continue to look like an amalgamated department for some time to come. Therefore the urgent consideration is to introduce staff mobility between different parts of the department, to work by task groups that bring different disciplines together, and to educate minds on the practical realities of environmental protection, land management, conservation and food production. Senior management in DEFRA is undoubtedly working to implement such initiatives. There have been such staff changes and there is undoubtedly internal discussion on how best to deliver DEFRA's objectives to the public, and its services to its customers. The latter has involved welcome seminars with industry representatives and others.
14. The Rural Affairs Forum for England, and the regional Rural Affairs Forums should help in this process of "know how transfer" between staff, and from the outside world into DEFRA. Here, the regional forums may prove to be more useful than the national forum in delivering a message from the grass roots on the success of government policies on the ground, and on the practical needs of rural communities and businesses.
15. The contacts between DEFRA at national level and with its regions, and between the regional offices and local businesses and communities are of great importance in ensuring that DEFRA is in touch with its rural constituency. The disastrous FMD outbreak of 2001 exposed the extent to which these contacts had broken down. In the South West, for example, it was the initiative of the RDA, rather than MAFF, that brought together organisations representing a range of interests affected by the outbreak, and provided a means for channelling information back up the line to MAFF in London. By the time DEFRA was created, some contact had been restored, but there is still some confusion as to lines of communication. The South West is again an example. For rural economy matters, CLA is in contact with the DEFRA senior staff member in the Government Office of the Regions in Bristol. On CAP and rural development programme matters the contact is with the Rural Payments Agency in Exeter. On other DEFRA policy matters the contact is with DEFRA back in Bristol. What appears to be missing on the agricultural side is an equivalent replacement for the regional panels under MAFF, which communicated practical information to the MAFF regional office. The new regional forum may achieve a similar purpose, but a quick contact agricultural sub group should be considered as a means of getting practical information to DEFRA at regional level. Sub groups on other sectors could also be considered, but more as quick contact groups, rather than as the task and finish sub groups that are being set up under the aegis of the national forum.
16. Overall, CLA experience in the regions is that DEFRA is becoming less in contact with its constituency—at grass roots level—not more, despite efforts to improve RPA service delivery. The evidence of this is that some of the regional forum meetings have revealed a knowledge gap among DEFRA staff. If this develops, it will affect the quality of information going to London and the quality of advice going into policy formulation.
IMPACT ON THE ENVIRONMENTAL PROTECTION GROUP AND WILDLIFE AND COUNTRYSIDE DIRECTORATE (FORMERLY DETR)
17. Overall, beneficial. While the former MAFF parts of DEFRA are adjusting to a new culture and the need to adapt their policies to the overall vision, so the former DETR divisions are too, and there is beginning to be a greater appreciation that without economic viability, there can be no environmental sustainability.
18. However, there is still a strong tendency to look at regulation where advice and co-operation might be a possible alternative. In the view of the CLA—and the NFU—there is also still some "goldplating" in the implementation of EU legislation, for example on the Environment Impact Assessment Directive, and in the Government's consultation proposals for further implementation of the Nitrate Directive. This is despite explicit commitments from the Prime Minister to avoid excessive burdens on the hard pressed farming sector, and goldplating.
19. In one area, noted above, the prospects are better, ie the Environment Agency's exploration of the possibility of a more risk based approach to regulation of environmental protection.
20. The Wildlife and Countryside Directorate has remained open to discussion, as it was before. However, it now seems to be adapting to the wider and more integrated remit of the new department. This is a positive move for those who live and work in the countryside. One significant test will be when the Government considers the future role of national parks. There have been conflicts in the past between the needs of those with livelihoods in national parks and those who have seen them as refuges from economic development. With agricultural and forestry employment falling, the holistic approach to the countryside adopted in Defra's vision will be needed in the national parks— and AONBs, and Green Belts—as it is in the rest of the countryside.
HOW DEFRA HAS MADE THE CASE FOR RURAL AREAS OUTSIDE ITS OWN DEPARTMENT
21. The CLA has welcomed Government efforts to secure better co-ordination and co-operation between departments—rural proofing. However, a fundamental prerequisite of successful rural proofing has to be at the conceptual stages of policy-making—not simply as a measure of last thought in the determination of central government policy. Moreover, it has to be seen to deliver practical and tangible benefits to those living in rural communities.
Rural economic regeneration
22. The central priority for rural proofing has to be the regeneration of the rural economy through better targeted investment by government. Areas such as business rates, VAT and National Insurance Contributions necessarily involve actions by HM Treasury and the Department of Trade and Industry (DTI) requiring greater transparency and co-ordination of the work of these departments in delivering rural proofing. The Government's recent decision to extend business rates deferrals is welcome as a clear case of rural proofing in action.
24. The policies of the Regional Development Agencies have to be rural proofed and Central Government has to ensure that the allocation of funding is conditional upon there being in place adequate and effective rural proofing measures. This also has to extend to the allocation of grants to Local Authorities. Consideration has to be given to the issue of standard spending assessments and the sparsity factor. In order for rural proofing of Central Government policies to be effective, there is a clear case for examining the allocation of services to rural areas provided by Local Authorities. Central Government should require Local Authorities to implement rural proofing at the conceptual stage of Local Government decision making. Policies adopted at this level have a significant impact on the economies of rural areas. Without clear direction from Central Government, it remains likely that policies emanating from town and country halls will neglect the opportunities that arise from rural proofing.
25. Rural proofing of Central Government policies must also recognise the essential need for an adequate infrastructure for rural business. This extends to policies on IT and the provision of broadband in rural areas. If rural proofing is to succeed, there has to be recognition that those in rural areas need access to the latest communication technology in order to remain competitive in e-commerce. Rural proofing of Government policy has to reflect this fact.
26. Central Government policy has to be tailored in a way that promotes both a vibrant and secure rural community. The CLA believes that national polices on the prevention of crime need to take into account better police provision in rural areas as well as the psychological effects of crime on the individual.
Planning
27. Planning policy must adequately reflect rural needs. Whilst we welcome the changes to PGG7 last year to encourage farm diversification, the current commitment to urban concentration and priority to brownfield sites acts against much needed rural development. In addition, housing policy needs to be rural proofed and has to reflect the need for greater resources to be targeted to affordable housing in rural areas. Policy on housing must not have unintentional consequences for rural areas and the CLA believes that the rural proofing of housing policy is an important way in which to mitigate against such a possibility.
28. Planning policies also need to be more positive to rural tourism. PPG 17 Tourism needs to include a specific section on this issue, which is consistent with the positive guidance in PPG 7 and PPG 13. Too often Local Authorities have reverted to the old key settlement policy, that is, identifying larger settlements and concentrating, what little development there is in these areas. Planning policy needs to recognise the needs of wider rural areas in order to achieve sustainable rural communities such as providing homes, employment and services to communities.
Rural tourism
29. The FMD crisis highlighted explicitly the link between agriculture and rural tourism in generating an economically sustainable rural economy. It is certainly the case that rural tourism can not play the significant role it does without agriculture, and the income generated through rural tourism diversification is often the main means of cash flow for many farming businesses. It therefore remains imperative for the tourism remit of the Department of Culture, Media and Sport (DCMS) to be rural proofed. Indeed, there should be an explicit and separate rural tourism policy.
30. Those involved in rural tourism recognise that the fragmentation of the industry is its main weakness. There is evidence of difficulties of DEFRA communicating with DCMS on the "Your Countryside, You're Welcome" initiative. DEFRA has responsibility for rural tourism (that constitutes the largest industry in the rural economy) whereas DCMS has responsibility for tourism in general. Therefore, effective communication between these two departments is necessary as a permanent fact. The CLA regards this issue as integral to the promotion of the countryside.
Transport
31. The rural economy is regionally based: National policies are integral to the development and co-ordination of policy but it remains the responsibility of the country's regions to deliver. This is why the CLA believes that rural proofing of transport policy is an essential pre-requisite of the success of the rural economy. Without adequate public transport the opportunities for tourists for example to visit the countryside are dramatically reduced. Moreover, rural transport remains a key requirement in maintaining the fabric of rural communities. The CLA recognises that a great deal has already been done to improve public transport provision in rural areas. However, it has to be recognised that a poor transport infrastructure in rural areas is to the detriment of all rural businesses. Consequently, we believe that rural proofing of national transport policy is crucial and one that must be able to deliver the practical benefits.
32. Policies affecting the road and rail network need to be rural proofed to ensure that the impact on the rural community is positive. The CLA believes that Central Government has to recognise the importance of maintaining the road and rail network in rural areas, which is seen by many as the arteries of the rural economy.
Health
33. The CLA recognises the valuable part played by the National Health Service in providing essential services to rural areas. Rural proofing of health policy again must be seen as a priority. It is in the interests of rural communities and central government to comprehend the importance of the role of the NHS. This would require NHS spending decisions to take account of rural priorities, thus, indicating the better targeting of resources. Provision must also be made for contingency planning in the event of emergency. For example, during the fuel crisis in 2000, essential supplies of petrol for health visitors in rural areas were suspended, having the effect of curtailing a much needed social service for rural areas. The CLA believes that clear and consistent proofing of health provisions would increase awareness of the needs of rural communities to NHS decision makers as well as highlighting the benefits of rural proofing Central Government policy in a transparent and consistent manner.
Education
34. The CLA believes that education policy should be seen as rural proofing in action. We welcome the increase in the number of schools located in rural areas (Countryside Agency 2001). We note with interest the government's intention to increase the number of school terms per academic year but we feel that it is essential before any final decision is made to carry out research as to the impact such changes would have on rural communities. Anecdotal evidence suggests that it could have a beneficial impact on rural tourism given the culture change of the public to short breaks. Nevertheless, more work is required in order to identify potential problem areas.
35. The CLA also believes that rural proofing provides an opportunity of increasing the public's awareness of the rural community. This is particularly true within education and clearly it is important for the national curriculum to be rural proofed. This can be achieved with the creation of a new compulsory school subject on rural affairs.
ROLE OF THE COUNTRYSIDE AGENCY
36. The creation of DEFRA has altered the relationship of the Agency with Government since there is now a department covering a similar range of policy matters to those covered by the Agency. For the following reasons, CLA believes that the Agency should retain its current status and independence separate from Government:
— It can give independent advice to Ministers, throughout the Government, and its Chairman can act as Rural Advocate. Its State of the Countryside reports are very useful.
— It can pilot initiatives in a way that might be considered too risky for central government. The Countryside Stewardship Scheme was a pilot of its forebear, the Countryside Commission.
— It can be quicker to react to trends on the ground than a central government department.
37. At the same time, the Agency should be careful not to do work that can be done by others. It works best as a catalyst.
CONCLUDING REMARKS
38. Even if the creation of the new department had not coincided with the FMD outbreak, there would have been a major job to do in terms of integrating MAFF and the divisions from DETR, and in creating a new culture. The task of pursing sustainable development in its three elements of economic, environmental and social sustainability would have been a major one. At the same time the reforms already in train to establish the Rural Payments Agency and to reduce the number of MAFF offices have created an extra administrative strain at a difficult time.
39. Add to this the impact of the FMD outbreak, and it is hardly surprising that DEFRA has taken time to come together. In hindsight we may see that the FMD outbreak actually accelerated the process of cultural integration, because DEFRA has learnt fast about the interdependence of farming, tourism, the wider rural economy and the environment.
40. The next test for DEFRA will be its response to the Curry, Anderson and Follett reports. If that response is positive, for example with a simple and properly funded Broad Stewardship scheme, this will be an encouraging sign of its commitment to regenerating rural areas, and serving its urban constituency too. However, if there is a retreat from the recommendation of these reports, this will re-ignite fears that DEFRA has yet understood the scale of the needs of its rural constituency, and that it does not have the commitment to address these needs, and to promote the thriving and well managed countryside that can be enjoyed by the whole population.
Country Land and Business Association
31 May 2002
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