Memorandum submitted by the Family Farmers'
Association (Appendix 2)
1. The purpose of this association is to
promote family farming. We believe that this is better than corporate
farming, both for the environment and the community. Productive
and profitable farming needs people, and produces food for the
nation. We regret that there is no mention in the Bill of food
production as we think that many people share our concern at this
government's lack of concern about food security. There is a danger
that following decoupling large scale industrialised farming will
increase as it becomes more difficult to produce food and make
a profit. It will be extremely difficult to care for the environment
in the absence of farmers and their livestock, or even if they
become much scarcer.
2. We therefore examine the Bill from the
point of view of both farmers and the environment.
In the first place, to abolish both the Countryside
Agency and English Nature is a draconian action, and possibly
unwise. Both organisations have only been created relatively recently
and if they are found not to be fulfilling their intended purposes,
it might have been better to improve them than to move their necessary
functions to an entirely new body. The new Agency created in their
place is to have a very wide remit in relation to the natural
environment. It is to be hoped that it will appreciate the importance
of farming and food production in the maintenance of the natural
environment. (What we now enjoy is not, in fact, "natural",
it is mainly the result of farming activities.)
3. The greatest concern to farmersour
remitis the future of the Rural Delivery Service. This
has the vital and practical function of actually administering
all sections (as far as we know) of the ERDP. Organic and disadvantaged
farmers are supervised by the Rural Delivery Service. So are all
the environmental schemes. The RDS is the body which actually
knows what is happening on all farmed land that is of importance
to the environment. It appears to be playing a vital part in developing
the new Environmental Schemes. No doubt it is being advised on
the ecological aspect by EN, but it is the RDS which, when told
what result is needed, organises actual on farm schemes. It is
the officials of the RDS with whom the farmers have personal contact,
negotiating details of their activities.
4. There is mention of making the "delivery"
(not clearly defined) function local, possibly under the RDAs.
However, as this delivery is a matter of judging whether farmers'
practice, or proposals, fit the specifications of the relevant
scheme, chaos could ensue if there were variations of application
between different areas. The new Agency seems to be given most
of the powers now performed by the RDS; specifically Management
Agreements, often with farmers. A name will have to be given to
the Section or Division which performs these functions. Why not
Rural Delivery Service, which we are used to? We look upon it
as a section of Defra, similar to the RPA which actually disburses
the money . If the administration of the agri-environment schemes
is to be by a body apparently quite separate from Defra, more
confusion may be created among farmers, not less. (Remembering
that environmental schemes are becoming ever more vital for farmers'
survival.)
5. The Commission for Rural Communities
appears to have rather vague purposes and functions. It may be
intended to take over the social and economic functions of the
CA? It is to be hoped that if/when it finds rural areas "suffering
from social disadvantage and economic underperformance" as
a result of the new CAP arrangements, it will be able to rescue
them.
6. The Joint Nature Conservation Committee
does not appear to have much relevance to farming or food production.
What is of concern is the power to abolish existing
bodies, eg the MLC, and create new ones. Taking the MLC as an
example, this organisation costs farmers a lot of money. It also
performs a lot of functions, which it says are vital. Most of
the existing bodies have been set up in response to a perceived
need to help or advise farmers. There should be provision for
proper examination both of the need for each body or board, and
its effectiveness, before decisions are taken as to its future.
Formal consultations should be specified, even possibly votes
from those who are, or would be, levied.
7. We are concerned that the Secretary of
State will have enormous power over all these new organisations.
By grantingor not grantingsufficient funding, and
by appointing competent or incompetent people to run them, she
(in the present case) will have absolute power as to how well
they function and whether they will, in fact, benefit the environment.
We have already pointed out that the environment is very largely
dependent on how farming develops under the new CAP, and this
cannot be too strongly stressed. The new bodies must have both
the means and the determination to ensure that farming does not
languish, leading to the dereliction of the countryside.
8. From the Schedules it is not clear if
the new Agency and the CRC are to be regarded as government departments,
as they will not be "servants or agents of the crown".
We are obviously not expert in constitutional matters, but hope
their status and importance will be made clear.
9. We do not have the technical expertise
to comment on the rest of the details given in the schedules.
Nor have we had time, unfortunately, to consider the whole of
the explanatory notes or the RIA in detail. There is more about
transferring the functions of the RDS to local organisations,
which, as we have already said, could be a recipe for disaster.
Apart from the difficulty of uneven interpretation of rules and
regulations, it would hardly encourage the establishment of competent
and dedicated staff if each area office had a different employer.
As the RDS is virtually in control of all farming's environmental
activities, which are legion, its smooth functioning is absolutely
vital. The management of the ERDP is absolutely vital under the
new CAP, and it must be organised as a whole, no matter what the
whole is named or its nominal status under Defra.
We note that the CRC is scheduled to be instituted
next month, which seems a little hasty!
The Family Farmers' Association
February 2005
|