Memorandum submitted by the Woodland Trust
IMPLEMENTATION OF CAP REFORM IN THE UK
1. The Woodland Trust welcomes the opportunity
to give written evidence to this inquiry. The comments that follow
are delivered on behalf of the UK's leading woodland conservation
charity. We achieve our purposes through a combination of acquiring
woodland and sites for planting and through advocacy of the importance
of protecting ancient woodland, enhancing its biodiversity, expanding
woodland cover and increasing public enjoyment. We own over 1,100
sites across the country, covering around 19,000 hectares (47,000
acres) and we have 250,000 members and supporters.
2. Our comments are restricted to areas
of concern to us, where we believe we have a contribution to make
in terms of improving woodland biodiversity specifically, and
the wider countryside more generally, within the context of CAP
reform.
GOOD AGRICULTURAL
AND ENVIRONMENTAL
CONDITION
3. We believe that absolutely fundamental
to the implementation of CAP reform is cross compliance, particularly
the issue of "Good Agricultural and Environmental Condition"
(GAEC) (Article 5, as defined in Annex IV). However in view of
the move to greater delivery of public benefits we believe that
implementation of GAEC in England includes taking good stewardship
of the countryside into consideration.
4. In this regard we believe it is vital
that wood pasture and other woody habitat mosaics[1],
such as woodland edge, the important gradient between woodland
and open ground, now lost from our countryside, are not "shut
out" of the definitions of GAEC in England. We accept that
closed canopy woodland will not generally be acceptable vegetation
on agricultural land. However we do believe that in certain areas
of the country, as stated in Article 5 (1) of the CAP reform document,
particularly, in our view, areas where there are high densities
of ancient woodland, and/or where woodland is an important landscape
characteristic, GAEC should include wood pasture and other grazed
woody habitat mosaics to buffer and extend ancient woods. Land
allowed to regenerate to this sort of habitat, where it lies adjacent
to existing ancient woodland for example, should still be eligible
for the Single Farm Payment (SFP) as fundamentally this is good
environmental condition.
5. These woody habitats would continue to
be grazed, albeit extensively, thereby delivering an agricultural
product. Whilst Annex IV, uses the term "prevention of the
encroachment of unwanted vegetation", and generally we would
take this to include trees and shrubs, we believe that wood pasture
and other woody habitat mosaics have an important role to play
in the future of our countryside particularly in terms of delivering
public benefits.
SINGLE FARM
PAYMENT
6. The Woodland Trust welcomes decoupling
of subsidy from production, and particularly Defra's decision
to introduce the SFP from 2005. These changes clearly signify
a major and welcome policy shift away from an intensive production-oriented
approach to farming to a more sympathetic public benefit-oriented
approach.
7. Of course in negotiating a major reform,
which includes decoupling subsidies from production and ensuring
that subsidies are subject to cross compliance, this itself implements
one of the Policy Commission's key recommendations (p 23—Policy
Commission report[2])
8. We have concerns that Defra are intending
to introduce the Farm Advisory System only in 2007, two years
after farmers will have to come to terms with the new SFP and
the associated cross-compliance. We believe it is fundamental
that the advice farmers need is available to them in 2005.
AREA/HISTORIC
PAYMENT
9. Defra's own consultation poses the question
of an area-based or basic (historic entitlement) approach to introduction
of the single payment. Furthermore Defra's own Supplementary
Regulatory Impact Assessment on Options for the Reform of the
CAP—Sept 2003, discusses the pros and cons of both approaches.
10. The Woodland Trust's view is that from
an environmental point of view an area-based approach would be
the best option. As Defra's above named document highlights, an
area based approach would:
— Extend cross-compliance to more land.
— Assist farmers who are not currently
in receipt of subsidy.
— Would reduce anti-competitive effects
of the payment of subsidy based on historic receipts.
— Would help to protect farmers in
unsubsidised sectors.
Clearly in the context of more land coming under
cross-compliance, there are obvious benefits to the environment.
11. The disparity of 20% of farmers receiving
80% of subsidies has long been recognised. An historic receipts
approach would simply perpetuate this unfair state of affairs.
It would certainly seem perverse if in 10 years time we still
have large farms receiving biased and outdated payments, relative
to the intensity of their farming operations in the reference
period, ten years before.
RDR—PILLAR
2
12. Whilst it is accepted that the CAP
reforms will be beneficial for the environment—subject to
the UK countries' decisions on cross compliance of course, there
are still likely to be areas of England where there are negative
impacts of decoupling or specific issues that need to be addressed.
In this regard we would support the use of national envelopes.
13. However we would urge caution on how
national envelopes are applied. National envelopes will still
be pillar 1 payments, and as such should not be used to undertake
measures that are more suitable for the ERDP. Nor should the national
envelope be used to "green" pillar 1 such that pillar
1 is seen to undermine the RDR, which is of course wider in its
scope of rural support.
14. Modulation should be set at the maximum
possible level and increased if any future opportunity permits.
Shortfalls in funds in the ERDP must be made up by a longer-term
goal of increasing the pillar 2 budget, over and above the 5%
planned within the time frame of these reforms.
15. We congratulate the UK delegation on
negotiating transitional arrangements that will financially enable
the roll-out of the entry-level scheme in England, however with
modulation at this stage fixed at 5% until 2011, there seems little
scope for significantly increasing the funding to the ERDP, a
further key recommendation of the Policy Commission (p 77 Policy
Commission report).
16. On a more positive note, however, we
are very encouraged by the increased communication between Defra
and the Forestry Commission in developing the new Agri-Environment
Scheme in England, "Environmental Stewardship-Higher Level".
There is now a full suite of woodland options within the proposals
for this scheme, reflecting the Policy Commission's recommendations
(p 84). The Woodland Trust has lobbied for some time on the need
to integrate woodland properly within the agri-environment scheme
framework, both for reasons of public benefit delivery, but also
because it makes more sense for the applicant, so we are very
pleased with this development.
Woodland Trust
December 2003
1 Wood pasture and woody habitat mosaics include patchworks
of grazed land on which scrub and woodland features such as bushes,
thickets and trees are allowed to establish. This kind of habitat
is very natural in its structure, of value in terms of landscape,
of immense value for wildlife as it is the ideal transitional
habitat to buffer and expand existing ancient woodland, but most
importantly, in terms of GAEC, while there is some permanent woody
vegetation on the land, it continues to deliver an agricultural
product from the livestock used to maintain it. Back
2
Farming and Food-a sustainable future. Report of the Policy Commission
on the Future of Farming and Food. January 2002. Back
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