Memorandum submitted by The Game Conservancy
Trust (CAP 05)
EXECUTIVE SUMMARY
1. The joint Treasury-Defra report rightly
sets out the costly failings of the current CAP but it appears
to lack a proper appreciation of the link between farming and
farmland wildlife. Without farming the quality of our countryside,
and the biodiversity it supports, would dramatically deteriorate.
2. The Government's attitude to CAP reform
should be informed by a better understanding of the relationship
between farming and the environment. The environmental consequences
of the report's proposals are poorly understood and may be counter-productive.
Support should be targeted at retaining land in good agricultural
and environmental condition, and where land management supports
wildlife. We have a number of suggestions as to how the CAP could
be improved.
FARMING, THE
COUNTRYSIDE AND
THE ENVIRONMENT
3. The Treasury-Defra report is right to
point out that some aspects of today's more intensive farming
methods, promoted by the CAP and long deplored by the Game Conservancy
Trust, have damaged bio-diversity in the UK among other adverse
effects on the environment. However, in pursuing that argument
it is all too easy to overlook the essential point that much of
our wildlife actually depends on farming.
4. Farming has not only shaped our landscape
but it has engendered and sustained the UK's biodiversity. Over
the several thousand years that Britain's agriculture has been
dominated by growing cereals and raising livestock, our unique
flora and fauna has become adapted to it. The current breadth
of species in our countryside is to a very large extent dependent
on agriculture for its survival.
5. For example, many flowers like poppy,
corn cockle, corn marigold and cornflower depend on annual cultivations,
while others in hay meadows and pastures like clovers, vetches,
trefoils and fritillaries depend on grazing and periodic mowing.
Mammals like the brown hare and the harvest mouse live in farmers'
fields, as do birds like partridge, skylark, corn bunting and
field fare. The report illustrates the impact the CAP has had
on some of these by highlighting the decline in farmland birds
since the 1970s. However, it fails to point out that many of these
species would be in far greater decline if cereal farming were
to be much reduced.
6. The report states that "European
Agriculture ... should be ... rewarded by the market for its outputs,
not least safe and good quality food, and by the tax payer only
for producing societal benefits that the market cannot deliver".
Given the intrinsic link between farming and farmland wildlife
we question whether the two can be divorced to the extent the
report seems to believe. If farmers operating "without reliance
on subsidy or protection" fail to be internationally competitive,
they will cease to farm. Admittedly the 2003 CAP reform seeks
to prevent that land becoming wholly abandoned, reverting initially
to scrub, and then woodland, by stating that "Member States
shall ensure that all agricultural land, especially land which
is no longer used for production purposes, is maintained in good
agricultural and environmental condition". By this they mean
that land that is out of production should be kept in such a condition
that it could rapidly be restored to production. We would question
whether large scale non-production can mean "good condition"
from a wildlife and farmland bird viewpoint.
7. In "The future of food and farming",
Sir Donald Curry recognised that the environment was something
the taxpayer would be prepared to pay for. He recommended the
development of a "broad and shallow" agri-environment
scheme that could be adopted by most farmers. This idea has been
adopted by Defra and the new Entry Level Stewardship (ELS) scheme
was launched last year. It promises to be the best conservation
initiative on farmland since the war.
However, the logic of the Treasury-Defra proposals
would involve dismantling the existing ELS scheme, which is predicated
on the fact that the land is already being farmed.
8. It would be helpful if the statement
in the report could be clarified: "EU spending on agriculture
would be based on the current Pillar II and would support these
objectives as appropriate, allowing a considerable reduction in
total spending by the EU on agriculture". Is the report suggesting
that EU spending on agriculture should be reduced to Current Pillar
II (€7 billion) or that Pillar II spending should increase
to "support these objectives as appropriate"?
9. In particular, we believe that future
agricultural policy should be based on two objectives: (1) support
for land management that retains land in good agricultural and
environmental conditions, and (2) ensuring that land is managed
in a way that supports wildlife (which may mean that a considerable
proportion of it has to be actively farmed). We think the recent
2003 CAP reform, as implemented in England, comes very close to
doing just that.
10. However, there is room for improvement,
and we would suggest the following:
(a) Correcting some unfairness that is presently
built into cross compliance (particularly 2m field margins) which
penalises small traditionally-run farms more than large intensive
ones.
(b) Allowing for greater rewards within the
current ELS Scheme so that high value conservation options are
taken up on a wider scale.
(c) Re-configuring set-aside so that it only
refers to genuine conservation land.
(d) More comprehensive cross-compliance rules
to reduce soil erosion, diffuse pollution and to improve soil
organic matter content.
January 2006
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