Memorandum submitted by the Environment
Agency (V24)
SUMMARY
The Environment Agency has a central role in
delivering the Rural Strategy and works closely with the bodies
affected by the new arrangements. We want to make sure that implementation
of the strategy will protect and enhance natural resources (air,
land and water) and provide a healthy rural environment vital
to the whole country. This needs:
— Close collaboration between the new
integrated agency and the Environment Agency.
— Environmental targets and associated
funds for protection of soil air and water in streamlined funding
programme.
— Priorities for environmental outcomes
which will meet statutory obligations and delivery arrangements
which lead to the necessary consistent standards.
— Focus of effort and resources on
delivery during this period of institutional change.
A number of our international environmental
obligations, including the Water Framework Directive, rely on
delivery of the rural strategy in this way. The Environment Agency
is working with English Nature and the Rural Development Service
testing catchment-based delivery to show how best it can be done.
1. INTRODUCTION
1.1 The Environment Agency is the leading
public body protecting and improving the environment in England
and Wales. We advise government on sustainable development. We
have a central role in delivering the Rural Strategy. For example
we are the competent authority for European legislation that underpins
the strategy, the Water Framework Directive. We work in close
partnership with the bodies involved in the new delivery arrangements,
for example with English Nature in delivering the Habitats Regulations
where we are a competent authority responsible for protecting
and improving European wildlife sites.
1.2 We have a direct interest in the outcomes
of the strategy. We are pleased that the strategy recognises the
importance of natural resources in rural areas and the social
and economic value of the rural environment, including tourism
and recreation. We want to make sure that the way it is implemented
and its delivery arrangements bring the necessary protection and
enhancement to air, soil and water and provide a healthy rural
environment for everybody.
2. THE PROPOSED
INTEGRATED AGENCY
AND ITS
RELATIONSHIP WITH
THE ENVIRONMENT
AGENCY
2.1 We welcome the proposal to create a
new integrated Agency because it will complement the Environment
Agency's approach to environmental management. This requires strategic
use of a range of measures including incentives, regulation, advice
and voluntary action. Bringing these together via the two Agencies
will allow a sharper focus on outcomes and a simpler system for
our customers.
2.2 The new agency will have a distinct
role from the Environment Agency (and the title chosen for it
must reflect this). The focus of the new agency will be on biodiversity,
landscape, access, recreation; the focus of the Environment Agency
will remain protection and enhancement of air, land and water,
management of waste and flood risk. However Lord Haskins stated
that working closely with the Environment Agency will strengthen
the benefits of the new agency.
2.3 We already work effectively with the
constituent parts of the new agency. For example at a national
level through the Land Use Policy Group and locally through conservation
initiatives. A specific recent example of where we have worked
very closely and effectively with English Nature is on the PR04
process (influencing the asset investment programmes of Water
Companies through the pricing round set by Ofwat). This has ranged
from providing joint advice to ministers, to joint working at
both policy and operational levels. One of the challenges that
will face Government, the new agency and the Environment Agency
is to build on this good practice and capitalise on the opportunities
offered by the new arrangements.
2.4 We have identified a number of areas
where we need to work together, including:
— Tackling diffuse pollution.
— Managing the impacts of land management
on natural resources and flood risk.
— Protecting SSSIs and Natura 2000
sites and other biodiversity issues.
— Access and recreation, including
joint planning for recreation on land and water.
— Implementing the European Agricultural
Fund for Rural Development.
— Co-ordinating advice for farmers
and land-managers.
Catchment Management
2.5 The biggest challenge for close collaboration
is to tackle diffuse pollution from agriculture on a catchment
wide basis. The costs of diffuse pollution are substantial: for
example costs of removing fertilisers and pesticides from drinking
water are estimated at £120million per year. The impact of
siltation of rivers (often the result of poor soil management)
on rural flood risk is also becoming increasingly apparent. Reduction
in pollution will require shifts in farming practice[9]
and regulation will deliver only part of the solution. A range
of techniques including incentives, advice and voluntary action
are needed to address a number of farming practices, including
waste management, soil husbandary, cropping practices and pesticide
use.
2.6 Tackling this challenge is central to
meeting our obligations under the Water Framework Directive. The
new agency and the Environment Agency will need to work together
with farmers who manage land around river catchments. We are therefore
putting in place now, with English Nature and the Rural Development
Service, catchment management projects which will bring together
the range of measures available together with specialist officers
who can co-ordinate effort, target areas most at risk and provide
advice to farmers.
Agri-environment Schemes
2.7 The new agency will be responsible for
delivery of the new Environmental Stewardship Scheme. This is
the single most important incentive available to help farmers
adjust land management practices to meet the type of challenges
outlined above. Goals for biodiversity, recreation and landscape
will only be secured if we have a clean air, water and land. We
welcome therefore inclusion of measures for their protection.
2.8 Priorities and targets for the Scheme
must be lead by environmental considerations and in particular
by our international statutory obligations. For example, the Higher
Level agri-environment scheme should be focused on vulnerable
environments, such as wildlife sites protected under the Habitats
Directive, or catchments that are at high risk of failing to meet
good ecological status under the Water Framework Directive.
2.9 In order that the schemes tackle soil,
air and water quality and flood risk management, the Environment
Agency must to work in partnership with Defra and the new agency
to determine the policy and national priorities for schemes (and
allocation of resources). It will also work with the new agency
to determine local targets and to promote and deliver to farmers.
2.10 There is a major opportunity for the
Environment Agency and the new agency to work together to ensure
that guidance and advice to farmers on the range of tools and
techniques affecting them (for example: incentives, voluntary
action, cross compliance, regulation) is co-ordinated and simplified.
The Environment Agency's view is that all farmers should:
— have access to the Entry Level Stewardship
Scheme—for which there should be simple guidance available;
— have ready access to accredited guidance
and advice, including through the forthcoming Farm Advisory System
but also independent / NGO / farm assurance advisory networks,
geared up to the provision of natural resource protection advice
(this can also be provided through Environment Agency local environment
officers); and
— be confident that regulatory and
cross compliance visits will be targeted on the basis of risk.
In vulnerable/priority catchments such as those
referred to in 2.8 above farmers should:
— have access to Higher Level Stewardship
scheme;
— have access to a Catchment Officer,
as referred to in 2.6 above, who has a detailed understanding
of the local environment and is competent to advise on specific
Higher Level Scheme provisions and availability of further advice
and guidance; and
— use other sources of qualified advice
and support such as those from the Environment Agency local environment
officers.
3. STREAMLINED
FUNDING STREAMS
AND ENVIRONMENT
3.1 The Environment Agency welcomes the
proposed streamlining of the numerous rural funding streams. This
will mean more clarity for the customer and help bring into sharper
focus the outcomes to be "bought" and relative priorities.
However there is a risk that separation of funding into economic,
environmental and social strands will run counter to Government's
objective of sustainable development. Design and delivery of the
each of the three funds must not be exclusive of other elements:
eg economic regeneration must consider environmental impact and
opportunity.
3.2 The EA therefore welcomes the emphasis
placed in the strategy on sustainable development and the need
for bodies responsible for delivery of the three funding streams
to work with others. We already work closely with Regional Development
Agencies (RDAs) and look forward to our role in advising RDAs
on securing environmental gains through rural regeneration. In
their new role to deliver the rural regeneration funding programme,
RDAs need to:
— Recognise the place of a healthy
environment in a prosperous countryside and regional growth and
reflect this in strategic priorities.
— Appraise environmental impacts of
investment and funding decisions.
— Support environmental enhancements
as part of rural regeneration programmes
National and Regional funding priorities
3.3 Protection of air, soils and water must
remain a core strategic priority for rural funding and specific
funds for environmental goods increased to support statutory international
commitments. These decisions on prioritisation of funds must be
made at a national level (even where delivery is devolved). The
Environment Agency must work closely with Defra in determining
the broad outcomes required from all three funding programmes
including Rural regeneration and Agriculture, Food and Industry
to ensure that all deliver sustainable development.
3.4 We will also work closely with RDAs
and Government Offices for the Regions to help determine rural
priorities in each region and to ensure that these are in line
with Defra's policy principle "to have sustainable development
at their core".
4. ARRANGEMENTS
FOR DELIVERY
OF ENVIRONMENTAL
POLICY
The Environment Agency welcomes the emphasis
in the rural strategy on local delivery. The Agency is organised
so that we deliver environmental outcomes to meet local needs
and can work closely with others. We define nationally the overall
environmental outcomes we are striving to achieve, many of which
are designed to meet European and International obligations. The
outcomes are delivered via a network of 26 Area Offices throughout
England and Wales, where our local teams work in partnership with
other stakeholders to deliver the necessary actions.
Environmental policy needs delivery arrangements
that ensure we can meet national and international targets, which
depend on achieving nationally consistent high standards. As Lord
Haskins observed, environmental issues do not respect administrative
boundaries: a delivery failure in one area will have potential
implications for the whole country. National frameworks and targets
are needed for environmental outcomes.
Defra are currently carrying out a survey of
the organisations involved in delivering environmental regulation
to determine how they should respond to Lord Haskins recommendation
28 (that the Environment Agency should agree with local authorities
a supplementary role in environmental regulation). The Agency
already works closely with local authorities: for example we have
complementary roles (prescribed in regulations) in permitting
and pollution control.
It is vital however that delivery of environmental
policy for rural areas is consistent with the same issues in urban
areas; that it is nationally consistent and that it integrates
across environmental media (soil, air and water) and works alongside
other policy instruments, such as advice and incentives.
For example, the Agency's approach to delivery
of regulation and cross compliance on farms is designed to minimise
the bureaucratic burden. We operate a risk based and proportionate
process (which needs staff with land based skills and the ability
to deal with all environmental issues on a single holding). Regulation
is only part of a wider strategy to achieve environmental outcomes,
which means close collaboration with other agencies. And in order
to tackle the very real challenges of diffuse pollution we need
to operate at a catchment, not administrative level. We believe
that the Environment Agency's model of national priorities and
processes delivered locally on a catchment basis best meets these
needs.
5. THE IMPORTANCE
OF ONGOING
DELIVERY
5.1 The Modernising Rural Delivery Programme
(which underpins implementation of the Rural Strategy) is only
one of a number of reviews which may have implications for the
Environment Agency and the other bodies who must deliver the strategy.
Defra need to ensure that the principles established which are
vital to delivery of the strategy are not adversely impacted by
other reviews.
5.2 Implementation of the strategy and the
institutional and legislative changes needed are costly (of both
time and money). At the same time there are a number of vital
new delivery targets to met: for example delivery of the Environmental
Stewardship Scheme: neither Defra nor its delivery bodies can
afford to divert their attention from these. The change programme
must then be delivered within the £24 million budget set
aside for this and there must be certainty that the projected
resource benefits will be realised. If not, the programme risks
becoming an opportunity cost on delivery of environmental and
other rural targets.
5.3 Defra has now set out its vision for
rural areas and the direction for its delivery. As far as possible
it should delegate implementation to the agencies responsible
for delivery.
6. CONCLUSIONS
6.1 The important question for the Environment
Agency (which it also posed during the Haskins review) is whether
the strategy and the arrangements for its delivery will result
in better environmental outcomes.
6.2 We believe that it will do so only if
the issues outlined above are addressed in implementation: by
Defra, and by the new integrated agency, the Regional Development
Agencies and by the Environment Agency. This means that:
— The Environment Agency and the Integrated
Agency need to work closely together, particularly in tacking
the environmental challenges from farming in water catchments.
The new Environmental Stewardship Scheme must
encompass action for soil water and air and be targeted areas
where we need to meet statutory environmental considerations:
— The streamlined funding streams cannot
be operated in isolation: those responsible for delivery must
all consider environmental, economic and social targets in order
to achieve sustainable development.
— Resource allocations must ensure
adequate funds for environmental outcomes, and regional priorities
must be lead by a clear national framework of environmental outcomes.
— Funds for Rural Regeneration must
also support environmental improvements.
— Environmental policy must be set
at a national level and be driven by international statutory obligations.
— Delivery of environmental policy
must be driven by a clear national framework and must ensure:
— consistency across administrative
boundaries;
— integration of regulation with
other policy instrument (advice, incentives, cross compliance,
voluntary action); and
— integration of measures to protect
soil air and water together.
17 September 2004
9 Agriculture is not the only source of catchment pollution,
but as the major rural land use, and as an industry characterised
by numerous and diverse small businesses the challenge is greatest
here. Back
| 
