Memorandum submitted by the National Farmers'
Union (NFU)
SUMMARY
1. We are the largest organisation representing
agricultural and horticultural businesses in England and Wales.
Our members are farmers, growers and land managers and, consequently,
they are at the forefront of climate change impacts. The industry
also considers itself to be part of the solution to climate change
through its role in harnessing and exporting low-carbon renewable
energy services.
2. Through their capability to adapt to gradual
change, UK farmers and growers will respond to the challenge of
future food production. However, whilst adaptation to gradual
changes is relatively easy to undertake, and may not cost much,
adaptation to low-probability catastrophic events may be very
costly and anticipatory adaptation may even be impossible. The
NFU believes that that capacity-building and regulatory flexibility
to cope with extreme weather events should be a future priority.
3. Adaptation responses required of agriculture
must be cognisant of the complexity of economic and public policy
goals facing the industry.
4. There is a need for a continuation of
capacity-building activities in the agriculture sector, underpinned
by investment in agricultural science, a shift to focus on production,
and the strengthening of resources and facilities for knowledge
transfer.
5. The NFU strongly advocates a fully joined-up
approach to identifying, mitigating and managing climate change
risks in and across Government Departments and their agencies.
MAIN RESPONSE
This consultation response sets out the National
Farmers' Union (NFU) view of adapting to climate change and addresses
some of the issues highlighted by the Committee in its call for
evidence.
THE NFU AND
ADAPTING TO
CLIMATE CHANGE
6. The NFU represents 55,000 farm businesses
in England and Wales involving an estimated 155,000 farmers, managers
and partners in the business. The NFU's policy on climate change
entails viewing this as an opportunity rather than a threat to
our sector and encourages farmers to adapt and diversify into
harnessing and exporting low-carbon renewable energy services
in order also to play a role in the mitigation of climate change.
7. Farmers are on the frontline of climate change
and adapt to the weather on a daily and yearly basis. Furthermore,
they also make adaptations from generation to generation, eg through
the introduction of new varieties and new crops. The NFU has been
engaged with Government on this subject over the past five years.
Through their capability to adapt to gradual change, UK growers
will respond to the challenge of future food production. We are
in agreement with the observation in the NAO review[49]
that there may even be opportunities for our sector to exercise
a comparative advantage over our competitors, eg in water availability,
as a result of the projected moderate changes to our climate.
8. In 2005, the NFU conducted a survey on
the weather and climate change. The results exemplified the importance
of weather to the farming community as the weather-recording period
was on average 22 years, with some farms having records going
back 65 or even 100 years. 97.7% of the respondents to the survey
agreed with the UKCIP02 scenarios for climate change.
9. Adaptation to climate change is very
much dependent upon the way in which impacts appear, whether as
gradual changes or by catastrophic events. Adaptation strategies
can also be very diverse, specific to given time and location.
While adaptation to gradual changes is relatively easy to undertake,
and may not cost much, adaptation to low-probability catastrophic
events may be very costly and anticipatory adaptation may even
be impossible. The NFU believes that that capacity-building and
regulatory flexibility to cope with extreme weather events should
be a future priority.
10. The NFU has been a leading participant
in a number of sector initiatives addressing both adaptation to
and mitigation of climate change. The Climate Change Task Force
report[50]
presented proposals for the rural sector and Government to act
on climate change and reduce greenhouse gases from agriculture.
We are also a key member of the Farming Futures project[51]
which raises awareness amongst farmers of climate change impacts,
adaptation and mitigation.
The suitability of the processes and structures
in and across Government Departments for identifying, mitigating
and managing climate change risks
11. The NFU strongly advocates a fully joined-up
approach to identifying, mitigating and managing climate change
risks in and across Government Departments and their agencies.
Addressing water management issues—considering flood and
coastal erosion risk, water resource and water quality—provides
a good example of where this is not the case.
12. In our response to the recent draft Floods
and Water Bill, we highlighted our concerns about the changes
to the reservoir safety regime that the Bill contains. We agreed
that a risk- rather than standards-based approach to reservoirs
is the right way forward and were pleased it would lead to significant
de-regulation for owners of low-risk, large reservoirs. But we
argued that the inclusion of all reservoirs of over 10,000 cubic
metres within the revamped regime was, to be blunt, using the
proverbial hammer to crack a nut.
13. Many small reservoirs are on-farm irrigation
reservoirs, sited away from urban populations and critical infrastructure.
These on-farm reservoirs are encouraged by the Environment Agency
and others as a way of using water more efficiently and reducing
the environmental impacts of summer abstractions. If water is
needed for irrigation of crops, on-farm storage reservoirs can
store water abstracted in the winter period and the water can
then be used in the summer to help meet peak demands. They therefore
provide an excellent example of adaptation to climate change.
As the Environment Agency says in its recent Water for People
and the Environment publication, "Having suitable sites available
for reservoirs and access to funding will be important in managing
water resources, particularly for agriculture".[52]
14. However, if what is proposed in the
draft Bill is implemented without regard for the potential burden
it will place on existing and future owners of small on-farm irrigation
reservoirs, there is a real risk that what the Government are
encouraging with their water resources arm will be made considerably
less attractive by their flood risk management arm. This is hardly
in line with the holistic, integrated approach to water issues
that would deliver successful adaptation.
15. We are concerned that in DEFRA's self-assessment
of its progress on adaptation in the NAO review that it did not
identify any key partners in the food and farming sector—a
surprising omission.
The effectiveness of the statutory framework (including
the use of the Reporting Power and its accompanying statutory
guidance)
16. In our response to the consultation
on the Adaptation Reporting Power[53]
the NFU was very pleased to see that the importance of the food
sector to the adaptive capacity of the UK was recognised. We acknowledged
that the food sector is made up of a large number of businesses.
The farmers and growers of the UK represent thousands of small-
and medium-sized businesses and a requirement to report would
be, as the Reporting Power consultation recognised, disproportionate.
In line with the principles of Better Regulation, adaptation reporting
by public authorities and/or regulators should be limited to their
own actions and not necessarily those that they regulate.
17. However, we urged the Government to emphasise
the need for reporting authorities (both priority organisations
and those invited to voluntarily report) to consult other stakeholders
to reflect particular inter-relationships. Section 1.19 of Annex
B of the consultation suggested that "authorities need to
work in partnership with other organisations, and their process
should include some form of consultation with interested parties,
particularly when considering what measures to take to adapt".
The NFU feels that where integral linkages exist between reporting
authorities and food producers—not only in the food sector,
but also for water, energy, environment and the natural environment—there
should be a requirement to consult farmers. This is especially
relevant "when considering what measures to take to adapt".
Successful on-farm adaptation strategies will need be diverse,
specific to a given time and location, and dependent on the economic,
environmental and social costs and benefits to the farm business.
The funding, support, training and other resources
available, including at a local and regional level, for: building
capacity to adapt to climate change
18. Since its launch in 2006, the Farming
Futures project has been funded by DEFRA, and match-funded by
in-kind contributions by the other project partners. The project
has delivered 24 fact sheets and 21 case studies addressing the
impacts, challenges, opportunities and suggested adaptations and
mitigations for each farming sector; three video case studies;
over £375,593 advertising value equivalent in key farming
publications; and 11 on-farm workshops for farmers and land managers
reaching over 350 delegates. DEFRA highlights its funding of Farming
Futures as an example of its response to the risk presented by
climate change but the Department has not committed to funding
the project beyond March 2010.
19. There are a range of climate change initiatives
in existence operating at different levels and the NFU wonders
if there are opportunities for greater collaboration and co-ordination
with existing delivery mechanisms. Examples include:
— DEFRA's support of the established Farming
Futures project whilst simultaneously targeting the agriculture
sector with its Act on CO2 campaign.
— New communications activities targeted
at the agriculture sector by regional and county climate change
partnerships and action plans.
20. Recent decades have seen a serious running
down of investment in agricultural science, a shift in focus away
from production, and the undermining of resources and facilities
for knowledge transfer, which would allow farmers to benefit from
research and development on the ground. This at a time when the
world population is expected to exceed nine billion by 2050 and
climate change is expected to impact global food production. The
NFU consequently launched its Why Science Matters for Farming
campaign[54]
to highlight the demands, challenges and opportunities facing
British agriculture in the future.
22. Current projections suggest that, for
example, future sugar beet yields may halve in East Anglia due
to water shortages, demonstrating the importance of the crucial
work scientists are undertaking in producing more drought resistant
varieties for a future under climate change. The NFU would therefore
like to see an increase in public funding of agricultural research
budgets alongside support for the role the Agricultural and Horticultural
Development Board can play in agricultural R&D, and in particular
in promoting translation of agricultural research into practice.
23. We would also like to highlight that
other initiatives in the agriculture sector make a contribution
to climate change adaptation eg the Campaign for the Farmed Environment
will enhance habitat for farmland biodiversity and increase connectivity
in the landscape.
Monitoring and evaluation of work on adaptation,
including thoughts on how progress on adaptation can be quantified
and success measured
24. The NFU agrees with the NAO's observation
that measuring progress on adaptation is difficult. UK farmers
and growers are consciously and sub-consciously already adapting
to climate change. For example, farmers are planting crops earlier
in response to warmer temperatures, improving irrigation efficiency
in preparedness for hotter, drier summers and, as a result of
the flooding events in 2007 and 2008, considering the resilience
of crops over yield. However, this proactive/reactive change in
behaviour is not branded "climate change" adaptation;
it is simply a habitual response to "weather" and circumstance.
Such small-scale, almost imperceptible, changes in farming practice,
whilst important in successfully delivering business resilience
to climate change, will be very difficult to quantify.
15 October 2009
49 http://www.nao.org.uk/publications/0809/adapting_to_climate_change.aspx Back
50
The Climate Change Task Force consists of the NFU, the Country
Land and Business Association (CLA), and the Agricultural Industries
Confederation (AIC) The report is available at http://www.nfuonline.com/x24741.xml Back
51
A collaborative communications project involving the AIC, Agriculture
and Horticulture Research Forum, CLA, Forum for the Future, NFU
and DEFRA: www.farmingfutures.org.uk Back
52
http://www.environment-agency.gov.uk/research/library/publications/40731.aspx Back
53
http://www.defra.gov.uk/corporate/consult/climate-change-adapting/consultation.pdf Back
54
http://www.whyfarmingmatters.co.uk/Documents/Why%20Science%20Matters%20For%20Farming%20Report.pdf Back
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