Annex
ENVIRONMENT AGENCY CONSULTATION ON THEIR
CORPORATE STRATEGY 2006-11
18. The CLA welcomes the opportunity to
respond to the Environment Agency's consultation on their proposals
for a new corporate strategy for 2006-11. We represent 40,000
land managers who between them own and manage half of the rural
land in England and Wales. Our members are involved in many businesses
including agriculture, forestry, fishing, tourism, waste management
and delivering environmental services such as biodiversity and
landscape. We therefore have a strong interest in the Agency's
strategy for the next six years. Our comments are below.
19. We are pleased to see that EA will be
championing the environment in the context of sustainable development.
This is key, demonstrated by the vital role of economic prosperity
to the delivery of environmental goods. We are also pleased that
the EA will continue the role of influential adviser and active
communicator—we believe that advising and informing land
managers on issues of concern, such as water quality, is essential
to raise awareness, have a positive influence on changing behavior
and ultimately achieve environmental outcomes.
20. We would like to direct the EA to the
CLA's recently published environmental policy paper "Public
Goods from Private Hands—why Nature needs Farming"
available on our website www.cla.org.uk/environment and from CLA
London Office, which lays out our principles for the delivery
of environmental outcomes—ie increasing the delivery of
environmental goods (eg landscape, biodiversity, heritage) and
reducing the environmental bads (eg protecting water resources,
water quality, soils) by following a series of core principles,
taking an intergenerational time view, taking a science based
approach, pursuing voluntary participation and working in partnership,
adhering to proportionality, taking a decentralised approach,
working with nature cycles and working with private property rights
and responsibilities.
BIG PICTURE
21. Under the big picture we note that diffuse
water pollution is raised, as it should be, but we would not like
the emphasis on point source pollution to diminish. We recognise
that point source pollution has reduced over the last 15 years
but it is still makes up a significant percentage of the overall
pollution in rivers, ie current figures state water companies
contribute 50-60% of the phosphorus, the key nutrient for triggering
eutrophication, in rivers.
OUR PRIORITIES
FOR THE
NEXT FIVE
YEARS
An enhanced environment for wildlife—Should
this read aquatic wildlife?
22. We would like the EA to recognise that
their vision must also be a "land managers' vision"
if it is to be delivered, after all 75% of England and Wales is
managed by rural land managers. We do not consider that the Vision
adequately engages with these individuals and for positive improvements
in environmental delivery they must be using our principles set
out in our Environmental Vision.
23. We note that the releasing of mink has
had a significant impact in the decline of water voles by 90%
and this is not mentioned—it is inferred that it is principally
due to land management decisions, which is not correct.
24. The EA will be required to work with
the new agency, Natural England, on sites of high environmental
values, such as SSSIs. We would like to emphasise the need for
good working relationship between these two agencies and good
management of how this arrangement works on the ground for the
individual land manager.
25. We would like clarification of the need
for "providing new sites for wildlife . . . ". There
is currently a network of high value sites, and with the new agri-environment
schemes which are expected to cover at least 70% of the land in
England. Through this we are expecting to see an increase in wildlife—rare,
uncommon and common species on rural land. We are concerned that
the designation of more wildlife sites is a backwards step and
likely to discourage participation in schemes designed to bring
about good environmental results. Instead conservation policy
must be outcome driven, recognising the huge efforts of land managers
towards delivering biodiversity.
Cleaner air for everyone
26. We would contest the comment that "in
the countryside the fertilising effects of nitrogen . . . affect
human health, wildlife and crops" and would like to see the
research that has been used to come to this conclusion. Over time
with better knowledge and technology and driven by cost/price
pressures land managers have been more skilled in applying only
the nitrogen that the crop requires, thereby reducing the leakage
of nitrogen from the system. This is to being further encouraged
by NVZs and nutrient plans under the ELS.
Improved and protected inland and coastal waters
27. Again we make the point that point sources
of pollution should not be dismissed, although we note that it
has reduced over the years, but it is still significant. Other
sectors should have proportionate measures to reduce diffuse pollution.
Engaging the land managers is key to tacking the agricultural
diffuse pollution problem—this is done by raising awareness
of concerns and allowing land managers to work within their businesses
to come up with solutions in the context of other sectors also
"doing their bit". We are concerned as to the meaning
of the point "regulate to tackle water pollution . . . ".
We are in no doubt that a top-down regulatory approach will not
achieve the best environmental outcomes achievable from land management.
28. We would urge the EA catchment officers
and Natural England catchment officers who will be both advising
land managers on reducing diffuse pollution from agriculture to
work together to ensure that the advice is coordinated and not
confused.
Restored, protected land with healthier soils
29. Defra in their soil action plan 2004
quoted that "For much of England's soils there is no evidence
of unsustainable management"—this does not seem to
be recognised in this chapter. We are disappointed that the Agency
does not seem to support working with farmers and engaging them.
For true engagement the Agency must start to work in partnership
with farmers allowing them to find the solutions that work on
their farm. We are concerned that the Agency wishes to regulate
the application of organic material to land...this is not the
best approach to encouraging farmers to work with natural carbon
and nutrient cycles. This should be done through plans and setting
up a carbon trading mechanism for land managers to work within.
There are many tools that will assist land mangers to improve
their soil management—raising the awareness of these tools
to land managers—eg soil plan in ELS and EA's best farming
practices and we would be happy to work with the Agency to help
promote these. We agree that we need to learn more about soil
health through research which we hope will assist land managers
to help inform their decisions about land use. It is not clear
that land managers will be the recipients of this research.
A "greener" business world
30. Fly tipping is a huge problem for those
who own rural land. A survey of fly tipping on agricultural land
(funded by Government and the Environment Agency) highlighted
the enormous problem of fly tipping in the countryside—ie
25% of farmers in the last five years have become victims of fly
tippers at a cost of removal of £50 million. At present there
is not a satisfactory mechanism for the removal of the increasing
volume of fly tipped material on private land. A common and unfair
occurrence is that it is often left to the innocent occupiers
to pay for clean up of the sites. As well as being an eyesore
in the countryside, fly tipped waste can cause also harm wildlife
and livestock. For example, one of our members has found broken
glass and battery acid dumped in a livestock field. This happens
almost on a weekly basis, and must be cleared up by the occupier
to protect the cattle from harm. Another member has persistently
had the locks on a field gate cut and, as well as building rubble
and domestic waste, has had 500 tyres dumped, with a cost of £5/tyre
for clean up.
31. In addition to our suggestion that the
local authority should be required to clean up waste on private
land (if the occupier can establish that he has taken reasonable
steps in all the circumstances to prevent fly tipping), we offer
some other solutions which may help and the EA could become involved
in/support, such as:
— allowing those disposing of fly-tipped
waste to be exempt from paying landfill tax;
— having longer opening hours on the
local landfill/recycling site which can significantly reduced
evening and weekend flytipping;
— providing more education and information
about fly-tipping, its unacceptability and proper disposal options;
— improving the quality and number
of civic waste disposal sites;
— ensure that new EU Directives are
"fly tipped" proofed—ie to be aware of the impact
a new directive will have on fly tipping so that measures can
be put in place to minimise it; and
— establish a fly-tipping "rescue
fund".
Wiser, sustainable use of natural resources
32. We are pleased that the EA will work
with water companies to promote more efficient use of water, which
we understood was, in any case, their obligation . . . We are
concerned that some new housing developments do not take into
account the demands and availability of water resources, and that
this can have a negative impact on farming enterprises which are
reliant on abstracted water. We would urge the Agency to encourage
environmentally sustainable projects, such as composting, which
reduce the amount of organic material that goes to landfill and
provides a good soil improver, rather than over-regulating and
adding unsustainable costs to these new businesses which makes
them unviable.
Limiting and adapting to climate change
33. The Agency's high inspection fees for
biodiesel facilities and biogas installations do not help the
Agency's or the nation's overall vision of reducing the production
of greenhouse gases. We would like to see the cost and impact
of regulation on those who are investing in business activities
that are friendly to the environment, such as these, minimised.
Reducing flood risk
34. We would like to see the Agency put
a greater priority for maintaining existing flood defences which
includes keeping clear river channels. We agree that climate change
is going to put more pressure on flood defences, and that rural
communities, as well as towns and cities, which have social needs
and entitlements, should be protected. It should not be assumed
that the loss of quality or value of rural property—which
may include significant investments in agricultural buildings
and equipment—arising from reduced flood defences, is an
acceptable price for them or the economy of these areas to be
required to pay. We suggest that the Agency should support schemes
from the flood defence budget that reward land managers for protecting
towns and villages downstream by allowing their land to flood
next to rivers and the coast. Thought should also be given to
the role of and rewards to forestry for its water infiltration
role.
Improving the way we do things
35. We agree that the EA needs to be a "high
performing organisation that uses resources efficiently and hope
that they will strive to achieve maximum efficiency.
Country Land and Business Association
November 2005
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