Memorandum Submitted by The Wildlife Trusts
(CAP 24)
1. INTRODUCTION
1.1 The Wildlife Trusts welcome the opportunity
to comment to the EFRA Committee's inquiry on the HM Treasury
and Defra's joint paper "A Vision for the Common Agricultural
Policy".
1.2 The Wildlife Trusts are a unique partnership
of 47 local Wildlife Trusts covering the whole of the UK the Isle
of Man and Alderney. We campaign for the protection of wildlife
and invest in the future by helping people of all ages to gain
a greater appreciation and understanding of nature. Collectively
The Wildlife Trusts have more than 600,000 members and manage
almost 2,500 nature reserves, covering 80,000 hectares of nature
reserves including 700 SSSIs, ranging from inner city urban sites
to the UK's finest wildlife areas. These include some of the UK's
finest wildlife sites in both inner city locations and rural areas.
The Wildlife Trusts therefore have unparalleled
knowledge of the opportunities and threats that face the natural
world and also of the legislative and fiscal framework affecting
it. As advocates and advisors on the natural world, The Wildlife
Trusts work with local communities, farmers, business, local authorities,
statutory bodies and others in protecting and enhancing our biodiversity
for people's use and enjoyment, both now and in the future.
2. GENERAL COMMENTS
2.1 The Wildlife Trusts have actively sought
reform of the Common Agricultural Policy (CAP) for many years
and are pleased with the changes introduced in the most recent
reforms. The severing of any links with production and the inclusion
of all land in England [excluding woodland] as eligible land for
the Single Payment Scheme (SPS) is an ambitious approach that
takes full advantage of opportunities for national governments
to adopt differing mechanisms within the overall framework. In
our view in England, the SPS will operate in a more sustainable
and equitable way than in Scotland and Wales where payments will
be made on the historic basis only.
2.2 In terms of further reform, The Wildlife
Trusts wish to see the beneficial aspects of the CAP retained
and expanded. This will not necessarily mean a reduction in the
cost to the taxpayer and we suggest that this should never be
a driver for reform. The need for financial mechanisms to support
appropriate management of the countryside will never diminish.
Biodiversity has become a by-product of farming by necessity;
the high proportion of land utilisation for agriculture leaves
much of our wildlife seeking food and refuge from within the farmed
area. It is unlikely that there will be widescale abandonment
of land under the current reforms. As The Wildlife Trusts appreciate
from their experiences of managing more than 80,000 hectares of
land, appropriate management for conservation has a considerable
cost, not least of which is the retention of grazing as the most
favourable means of land management.
2.3 Any vision for the CAP must look forward
to the dismantling of the Pillar 1 and Pillar 2 [England Rural
Development Programme] elements that have historically competed
with rather than complemented each other. Both pillars will need
to be merged to create a new Rural Development Programme that
must predominantly focus on the environment. It is here that the
greatest need exists and here that the best value for taxpayers
money will be achieved. We wish to see a high percentage of future
funds being used to support a Land Management Scheme and minimal
funds being available for the Rural Enterprise Scheme type approach
that supports alternative businesses [and which tends to be accessed
by the more affluent farmers]. Only new businesses that can demonstrate
environmental gain [eg eco-tourism] should be considered eligible.
2.4 We will not attempt to cost The Wildlife
Trusts' "Vision" at this time. When the inevitable change
detailed here becomes a reality there will need to be an assessment
of cost which must include realistic payments to cover management
costs together with "compensation" to support changes
of land use or retention and improvement of existing habitat.
Such payments will inevitably need to reflect the profitability
of farming at the time; it is naive to expect farmers to change
business strategies unless the financial performance of that business
remains at the same level.
SPECIFIC COMMENTS
ON HM TREASURY
VISION
3. The Enviromental Costs of the CAP
3.1 The Wildlife Trusts have been very concerned
that the CAP has caused significant environmental problems such
as water pollution and damage to the environment and biodiversity.
In some circumstances, such intensification has been encouraged
by high commodity prices. These prices have been artificially
maintained through the CAP. But this is not the sole driver of
intensification. Technology, innovation, the cost of labour, the
economies of scale and price versus benefit relationship of farm
inputs such as fertiliser will always have a greater effect. For
example, if using fertiliser to the value of £60 per hectare
gives a yield increase to the value of £300 per Hectare,
very few farmers will reduce this input. The CAP has been more
particularly responsible for changes in land use such as the move
to arable in the East and the general polarisation of certain
commodities to certain areas.
4. The Effect of Reducing Levels of Market
Price Support
4.1 We do not accept that the reduction
of price supports will lead to the scale of reduction in environmental
damage that is now required. There is certainly some land in England
that will not support intensive production. This tends to be marginal
land that in turn tends to be some of the best land for biodiversity
value or land where the best environmental opportunities exist.
This land should be taken out of production, given over to conservation
and appropriate management supported by the agri-environment route.
4.2 It is therefore a dangerous strategy
in our view to rely on price mechanisms alone to drive this extensification
of agriculture in some areas. It will only need an increase in
commodity prices to change land use again and fuel further intensification.
As unlikely as this scenario may appear, at some point in the
future it is inevitable that price changes will occur. Support
payments for environmental activities, supported by agri-environment
schemes in the short-term and Land Management payments in the
longer-term, are the only safe mechanism to ensure the continuity
of land management that we seek.
4.3 An example of the fragility of a sector
that relies on price stability is organic farming. Without doubt
the most environmentally friendly form of agricultural production,
organic farming can receive on-going support under the Environmental
Stewardship Scheme at a rate of £30 per hectare. This is
in addition to the basic rate payment of £30 per hectare
available to all farmers. However, these payments will not be
adequate to retain organic farms in the future if the commodity
price drops. For example, the organic dairy industry has been
severely affected in the past by imports, over-supply and subsequent
low prices. As a result, some organic dairy farms have ceased
operation. The high costs of production, compounded by low yields,
make organic farming particularly vulnerable.
CONCLUSION
5. Delivering our objectives through the CAP
5.1 The Wildlife Trusts wish to see the
following environmental objectives retained after any future reforms
of the CAP:
— The creation and enhancement of habitats
that are linked and more evenly distributed, with the further
development of ecological networks and stepping stones.
— The preservation and protection (by
buffers) of existing habitat.
— The improvement of farm habitats
and farmland management practices.
— The creation of new farmed habitats
[such as organic].
— The incorporation of existing and
future environmental legislation.
— The delivery of measurable contributions
to Biodiversity Action Plan targets for habitats and species.
— The provision of funding for monitoring.
— The provision of help for the rural
infrastructure that enables people to meet environmental objectives.
— The provision of skills training
in environmental and associated industries.
— The provision of opportunities for
exercise and quiet enjoyment of the countryside.
5.2 The Wildlife Trusts believe that in
any vision for the CAP these objectives must be retained, enhanced
and financially supported. The CAP must be completely focussed
on the environment and must deliver and protect our wildlife,
historic heritage and landscape while encouraging the production
of food and fuel in ways that will help achieve targets for the
reduction of emissions, thus helping to reduce the implications
of climate change.
February 2006
| 
