Memorandum submitted by English Heritage
IMPLEMENTATION OF CAP REFORM IN THE UK
INTRODUCTION
1. English Heritage welcomes the opportunity
to offer evidence to the Environment, Food and Rural Affairs Select
Committee, as we believe that the principles underlying CAP reform
and the manner in which reforms are implemented will have a major
effect upon the sustainability of the environment and landscape
and our national cultural heritage.
2. English Heritage is the Government's
principal adviser on the historic environment in England—including
historic buildings and areas, archaeology and the historic landscape—with
a remit encompassing both the urban and rural environments. We
are sponsored by the Department for Culture, Media and Sport,
but work closely with the Department for Environment, Food and
Rural Affairs, who along with the Office of the Deputy Prime Minister
contribute to the setting of our corporate objectives. While we
are not directly involved in agriculture or its related industries,
our interest in environmental and landscape issues provides us
with a considerable stake in the implications of farming and land
management policy. We are members of the national and regional
Rural Affairs Forums. In addition, we are closely involved in
the England Rural Development Programme (ERDP), sitting alongside
our sister environmental agencies on the National Rural Development
Forum, the Regional Programming Groups of the ERDP and its Regional
Rural Development Consultation Groups.
3. Alongside our statutory duty to conserve
the heritage, we are also required to advance its understanding
and accessibility to the public. As part of this function we manage
an estate of over 400 historic properties—attracting in
excess of 11 million visitors annually—the majority of which
are in the countryside.
Following what principles and by what method
the United Kingdom should implement the proposals contained in
the regulations formally adopted at the Council meeting in September
2003?
4. The linkages between the cultural heritage,
the landscape, and economic development are increasingly being
recognised by land managers and by Government at a regional, national,
and European level. Maintaining, and where appropriate enhancing
the historic and natural environment make an important contribution
to sustaining quality of life, generating income for rural communities
and increasing the liveability of rural settlements. We believe
therefore that:
— reforms to the Common Agricultural
Policy should deliver clear environmental benefits;
— the definition of "environment"
should be holistic, encompassing both the cultural and the natural;
— there is a need for these principles
to apply on a whole-farm basis, and across all farming sectors.
English Heritage's position is based upon the
environmental degradation that intensive agriculture has caused
to the historic environment, through undergrazing, overgrazing
and ploughing. English Heritage's campaigning document on damage
caused to archaeological sites as a result of cultivation, Ripping
up History: Archaeology under the Plough, has previously been
circulated to the committee.
5. It is our view that the decoupling of
Pillar I payments should be seen as only an interim measure until
supports can be moved wholly or more substantially into Pillar
II measures. We believe that the ERDP would offer a much better
mechanism for delivering support, and indeed restructuring. In
many respects the temporary "greening" of Pillar I payments
is unsatisfactory because it serves as a distraction from this
more environmentally desirable objective.
6. Notwithstanding this, we support the
principle that, temporarily, Pillar I payments will be linked
to environmental conservation, food safety, animal and plant health
and animal welfare standards, as well as the requirement to keep
all farmland in good agricultural and environmental condition.
However, English Heritage recognises that the definitions of good
agricultural and environmental condition will have a key role
in ensuring the effectiveness—or otherwise—of this
measure. It is important therefore that cross-compliance takes
a holistic approach to the definition of environment, and in particular
that future measures under Annex IV do not focus solely upon biodiversity
and landscape character. It is English Heritage's position that
the CAP Common Rules Regulation 1259/1999 provides a very good
case for protection to be extended to prevent active damage being
done to both designated and non-designated historic assets, including
archaeological sites and historic landscape features. We feel
that this view is given further weight by the failure of the current
Good Farming Practice requirements of the RDR to do anything more
than reinforce existing statutory protection. English Heritage
therefore believes that it is right to expect the future cross-compliance
regime to go beyond these existing measures. Ideally this decision
should be made on a community-wide basis, but given the intensity
of farming within the UK in comparison to other member states,
the UK should implement this higher level of environmental conditionality,
irrespective of whether it is adopted elsewhere.
7. On the basis of its belief that reforms
should deliver public and environmental benefits, English Heritage
has expressed a preference for Single Farm Payments to be calculated
using regional averages, because this would automatically extend
cross-compliance conditions across all holdings receiving support.
On the same principle we also feel that it would be wrong to use
historic entitlement as a basis for payments, as holdings which
had a history of more intensive farming—and consequently
a higher level of environmental degradation—would receive
more per hectare than those which were less intensively farmed.
The corollary to this would be that farmers who have already de-intensified
their operations would be penalised as a result. In addition,
payments calculated upon historic entitlement would also continue
to perpetuate the link between supports and production. This would
be a peverse outcome for a decoupling measure.
8. However, if Good Agricultural and Environmental
Condition is ultimately defined purely in relation to biodiversity
and landscape character, a valuable opportunity to deliver enhanced
environmental conservation benefits on a holistic, whole-farm
basis will have been missed. In this instance area-based Single
Farm Payments would also fail to deliver anything more for the
conservation of the historic environment than the historic approach.
This in itself would be regrettable, but is doubly unfortunate
because the EIA regulations for Uncultivated Land and Semi-Natural
Areas currently also base the definition of permanent grassland
upon floral diversity and fail to take into account in the screening
process the presence or otherwise of historic environment features.
These considerations mean that neither area payments, cross compliance
nor EIA would deliver any tangible conservation benefits for the
historic environment.
9. English Heritage also supports the use
of national envelopes as a means of offsetting or mitigating against
any adverse environmental impacts brought about by decoupling,
such as a reduction in grazing in upland areas. However, we also
recognise that a move towards Single Farm Payments calculated
upon an area basis would potentially have a significant economic
impact upon specific sectors, such as dairying. We would therefore
particularly support the use of the national envelope to deliver
environmental benefits, but we would not object to its use in
relation to specific sectors, where enhanced marketing might be
more of a necessity.
10. However, in general terms English Heritage
also feels that there is a need for a clearer policy framework
for CAP reform, including an assessment of farm value for money
in respect of SFPs and other reform measures, a regulatory impact
assessment and a clear programme for monitoring the environmental
impact of reform.
11. We feel that much greater progress is
needed in respect of the planned Farm Advisory Service. This will
undoubtedly provide an important mechanism for advising farmers
upon environmental standards and how they can meet them, and in
this respect will also underpin the effectiveness of measures
such as cross-compliance. It is important that device is delivered
on a whole farm basis, and Defra also needs to further develop
its thinking on the precise function and role of agencies in the
inspection and compliance regime.
What impact implementation will have on the
agricultural sector, particularly when taking account of approaches
to CAP Reform in other European Union Member States?
12. English Heritage has no specific technical
expertise in this area and no comments to make.
What progress has been made in implementing
the proposals made by the Policy Commission on the Future of Farming
and Food, and how that work meshes with wider reform of the CAP?
13. English Heritage is encouraged by the
progress made in implementing some of the key recommendations
of the Policy Commission on the Future of Farming and Food, particularly
in respect of agri-environment policy.
14. Initial assessment of the Entry Level
Scheme pilots indicates that, if rolled-out nationally in a similar
format in 2005, it will do much to reduce the negative impacts
of farming by helping farmers to identify and value environmental
assets, and providing a welcome additional funding-stream for
their maintenance and enhancement. We expect the ELS to deliver
key benefits in terms of nationally and regionally important heritage
assets, which would otherwise fail to benefit from either protective
legislation and existing agri-environment schemes. These include
halting the loss of extensive earthwork remains and securing the
maintenance of traditional farm buildings. English Heritage has
estimated that through savings on avoiding future repairs the
latter will deliver benefits of at least £40 million per
annum.
15. English Heritage is also optimistic
about the development of the Higher Level Scheme. We particularly
support the completion of environmental Farm Audits as a basic
condition of entry into the scheme and the more targetted approach
to environmental enhancements that we hope this will foster. We
support the principle of regional targetting statements and the
option to vary payments in relation to delivering enhancements
to regionally distinctive assets.
16. However, to reiterate the comments made
under 4 (above), we feel that much greater tie-in between the
recommendations of the Commission and CAP reform could be achieved
by utilising the ERDP as the primary delivery mechanism for support
payments.
17. Given the environmental degradation
caused by the earlier CAP funding regime and the moves to repair
existing environmental damage we also believe that the UK will
need to steadily expand its funding for agri-environment schemes.
However, the Government has made it clear that the community-wide
compulsory modulation benchmark of 5% by 2007 will not in itself
be sufficient to finance the roll-out of the Entry Level Environmental
Stewardship scheme currently being piloted in England. We understand
that the Commission have however given a clear undertaking to
those Member States, including the UK, which have been operating
schemes financed by voluntary modulation that transitional regulations
will enable them to continue to operate those schemes and that
any shortfall on funding could be made good through the continuation
of a higher level of modulation in that Member State on a transitional
basis. English Heritage therefore believes that there is a strong
case for the UK to go beyond the community-wide compulsory modulation
benchmark and move more rapidly towards the 20% ceiling permitted
under the Rural Development Regulation.
18. We have no objection to this memorandum
being made available for public inspection.
English Heritage
January 2004
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