Supplementary written evidence from English
National Park Authorities Association
Thank you for your letter requesting further
information following the presentation of oral evidence to the
Select Committee on 10 November 2010. I have set out our response
with each of your questions and have also included some additional
evidence on local needs affordable housing in National Parks as
this was an item that the Select Committee asked about at the
hearings.
1. The press has reported that the Government
is considering selling off National Nature Reserves. Will this
affect land within National Parks, and what impact might this
have on hill farmers?
The first point to make is that not all National
Nature Reserves (NNRs) are owned by Natural England. In the case
of Exmoor National Park, for example, one NNR is owned by the
National Trust and the two others by Exmoor National Park Authority,
while in the North York Moors National Park, one is owned privately
and another by Scarborough Borough Council. None of these will
be affected by any sale.
Of those NNRs that are owned by Natural England,
it is difficult to generalise about the impact of any sale or
disposal as a lot will depend on the current arrangements for
managing these areas and the eventual owner/tenant of the land.
However, the example of Ingleborough NNR in Yorkshire Dales National
Park suggests that in some cases hill farmers might benefit.
Ingleborough NNR covers 1,014 ha and has five
or six graziers. At the current time, some of the graziers on
the NNR have insufficient term of tenancy to enable them to enter
Environmental Stewardship (ES). This is because land owned by
Government departments, executive agencies and NDPBs is ineligible
for ES unless the grazier has sufficient tenure for the term of
the agreement. In addition, the grazier is ineligible if the work
required as part of the ES agreement is already required as part
of the tenancy with the public body. This has become a more significant
issue since the launch of UELS to replace HFA as it means that
graziers on the NNR cannot claim UELS when they used to be able
to claim HFA. Therefore, transfer of the NNR to another owner,
who is not a public body, may have benefits to the graziers, unless
that owner chooses to claim the ES payments themselves, or decides
to farm the land themselves rather than the current graziers.
2. You described a Lake District tourist
tax scheme—could you provide more detail on this and the
other voluntary schemes used in other Parks?
Examples of a number of tourism contribution
schemes that operate in National Parks are set out in Appendix
1. These are all voluntary contribution schemes and not tax schemes.
There are no powers that would allow any "tourism tax"
to be levied and, in effect, visitors to National Parks, other
upland areas and the wider countryside already contribute to the
management of these areas through general taxation.
In the majority of cases the experience of running
visitor contribution programmes is that they do serve to raise
public awareness of conservation objectives but do not provide
substantial financial returns when account is taken of the costs
of running the schemes.
3. Your evidence expressed a preference to
develop a new approach to CAP payments, rather than broadening
income foregone. What specific ideas do you have for this, bearing
in mind the WTO regulations on payments under environmental programmes?
Firstly, we do feel that there will continue
to be the need to include the consideration of income forgone
when asking for some management options. If the payment offered
does not make business sense then farmers will not adopt them
unless the payments recognise that cost. However, in other cases
we believe that greater consideration needs to be given to an
incentive scheme that recognises public benefits or services delivered.
Examples might include payments from water companies
to improve resource protection where there is an economic "driver"
for environmental management. However, that will not apply everywhere
and we do recognise the complexity of placing a financial value
on some of the less tangible benefits.
This need not necessarily be insurmountable.
We understand that the EU regulations already allow for the cost
of delivery to be included in payment calculations and we believe
that more use could be made of this provision. We haven't seen
the Environmental Stewardship (ES) payment calculations but assume
that the approach is already incorporated in some of the ES measures.
For example, if a feature is valued, such as a drystone wall,
it is acknowledged that there is a cost for its maintenance. The
payment reflects that cost and is a positive reward for the farmer's
effort. It also incorporates the concept of reward for results
rather than following prescriptions, which we believe we could
apply in other circumstances. For example, farmers might receive
a reward based on the condition of SSSI habitat that they manage
with a higher payment for more favourable condition.
4. How does the implementation of UELS affect
National Parks Authorities' ability to fulfil their statutory
objective to conserve and enhance the environment?
We consider that the UELS is valuable in assisting
with our ability to deliver the conservation purpose of National
Park designation. It usefully extends the ELS options and helps
to protect valuable features and habitats. It is also of value
in supporting the retention of cattle grazing in the hills.
However, there is still a "gap" between
the provisions available in the combined ELS and UELS compared
to those available in Higher Level Stewardship (HLS). Currently,
ELS and UELS do not make provision for capital grants for specific
works or more detailed habitat management where there is existing
environmental value but not sufficient to enable a farmer to enter
into a full Higher Level Stewardship agreement. An example is
provided by those farms on Exmoor that used to participate in
the Environmentally Sensitive Areas (ESA) scheme and who can make
the transition to ELS and UELS but are unlikely to be able to
join HLS. While in the ESA there were capital grants available
for environmental management and landscape management schemes
such as hedge restoration that will not be fundable at the same
scale under ES.
In addition, in many National Parks, National
Park Authority officers are directly involved in delivering advice
to potential UELS applicants (on behalf of Natural England), which
provides the opportunity to raise awareness of the value of environmental
assets that the farm contains and to signpost farmers to other
schemes and opportunities.
5. Do you think there is a case for rationalising
public support to fewer uplands farmers in the most valued areas,
given budgetary constraints?
— What criteria could be used
to define these areas?
We are of the view that there is a case for
rationalising support in other parts of the country so that support
was concentrated on upland farmers rather than seeking to support
fewer upland farmers. Uplands in general, and National Parks in
particular, have the highest value in terms of the combination
of semi-natural habitats; historic environment; landscape and
public access/visitors, so providing maximum value for money for
the taxpayer.
To sustain the public benefits that uplands
provide requires an ability to support the wider farming economy
and community across whole upland areas. For example, the more
productive farmland alongside the semi-natural moor and heathland
habitats together provides the variety and sense of a working
and living landscapes that visitors most appreciate.
The current Higher Level Stewardship schemes
already provide an element of targeting and prioritisation and
already means that some upland farms receive considerably more
financial support than others. All farms in the uplands are subject
to similar constraints on productivity and diversification opportunities
compared to lowland farms, and sustaining farming communities
in upland areas will continue to require financial support that
recognises these constraints.
6. Could you provide further evidence to
support your assertion that headage payments led to overgrazing?
Please see Appendix 2.
Local needs affordable housing
During the oral evidence we received a number
of questions regarding planning in National Parks and particularly
the provision of affordable housing to help meet local need. All
National Park Authorities give a high priority to enabling local
needs housing provision within their planning policies. National
Park Authorities have responded to indicate the numbers of local
needs houses approved in their respective National Parks over
the past four years as follows:
National Park
| Number of affordable/local needs homes receiving planning consent from 2006-10
|
| Exmoor | 62 since 1 January 2006 plus 15 awaiting completion of Section 106 agreements
|
| Lake District | 227 since April 2005 plus 15 awaiting Section 106 agreements
|
| North York Moors | 98 since April 2005
|
| Northumberland | 1 since March 2009 plus 3 awaiting Section 106 agreements
|
| Yorkshire Dales | 11 recent permissions plus 54 completions of homes approved before 2006
|
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Ultimately, planning policy is one of several factors that
affect the provision of housing as reflected in the Commission
for Rural Communities report "High ground, high potential"
page 38, and all National Park Authorities take a proactive approach
to working alongside Housing Authorities and Homes & Communities
Agency to address local housing need.
November 2010
APPENDIX 1
VISITOR CONTRIBUTION SCHEMES IN NATIONAL PARKS
LAKE DISTRICT—NURTURE
LAKELAND
The following information is taken from the Nurture Lakeland
website www.nurturelakeland.org.
"Nurture Lakeland is charitable trust that operates
a `Visitor Payback' scheme that encourages visitors to voluntarily
support conservation by donating a very small amount of money
via their bill or fees.
The project operates by recruiting tourism related businesses
to become members of Nurture Lakeland. The membership is made
up of a large number of hotels and guest houses of all sizes,
caravan parks, holiday cottage companies and a broad spread of
tourism related businesses, such as design companies, transport
companies and retailers. Once businesses are members of Nurture,
they pledge to raise money for a chosen conservation project.
A number of fundraising techniques are used including:
Opt Out: Businesses, typically hotels, add a
small amount, usually just £1 to the customer's bill. The
customer then has the option to "opt out of this payment,
by crossing it off or un-ticking the box. The English Lakes Hotels
group has to date raised a total of £81,000 as a result of
a £1 opt out on customers' bills.
Match Funding: Some member businesses are also
prepared to `match fund' the monies raised by opt out, and some
even double this.
Donations: Collection boxes are still used although
they don't bring in large amounts. More successfully, Nurture
Lakeland has recently started giving hotels donation envelopes
which they put in guests rooms with their welcome pack.
Sponsored products: Some organisations have identified
a product they can sell where either all or part of the revenue
is passed on to Nurture Lakeland.
Benefits both ways: A small 10p levy on the price
of the Ullswater Steamer's ticket has to date brought in £20,000
for conservation work around the Ullswater Lake. This has been
used to fund path repair work on the popular Howtown to Glenridding
trail. There is benefit both ways from this work; benefit to walkers,
who have a well maintained path to walk on, benefit to Ullswater
Steamers who receive good publicity for their support, and a great
benefit to the conservation of the lakeshore of Ullswater itself."
The website indicates that more than £1.5 million has
been raised for conservation projects in the Lake District over
the past ten years and that the scheme is the largest Visitor
Payback scheme in Europe. However, we do not have information
on the proportion of income that is received from visitor donations
compared to grants and other sources, or how the income from visitors
compares to the costs of running this element of the scheme.
EXMOOR NATIONAL
PARK—CAREMOOR
FOR EXMOOR
In Exmoor National Park voluntary contributions are sought
from visitors to contribute a range of conservation and access
projects. Sources of funding include:
— Proceeds from events: eg from participants at Exmoor
National Park Authority guided walks and activities.
— Percentage of ticket/entry fees such as Exmoor Challenge
(organised by Rotary Club for Exmoor ); Lynmouth Harbour Boat
Trips; Exmoor Explorer Mountain Bike Event (Team Zoyland); North
Devon and Exmoor Walking festival.
— Royalties from some publications.
Typical annual income from the scheme is currently around
£5,000.
NORTHUMBERLAND NATIONAL
PARK—GOOD
NATURE FUND
The Good Nature Fund is currently managed through a semi-autonomous
group called the Northumberland National Park Environment Association,
see:
http://www.northumberlandnationalpark.org.uk/grantsandsupportgoodnaturefund.
Contributions are gathered from a number of sources notably:
— Donations from businesses.
— Donations from % of profits from sales of publications,
photographs, etc linked to NPA supported projects.
— Donations made by visitors at our Centres.
— Donations made by visitors using re-usable trail guides
from village centres, eg Elsdon Village Trails.
The Environment Association is responsible for allocating
the funds, either to add value to other grant funded projects
or for stand-alone projects. The mechanism for this allocation
process is currently being reviewed by the Association. Once this
is clarified and agreed, we will promote the scheme more widely.
The value of donations currently held in the Environment Association
account is around £4,500.
As with other similar schemes, the benefit of this scheme
is more about awareness and education, than generating income.
YORKSHIRE DALES—THREE
PEAKS PROJECT
The Three Peaks Project was launched in April 2009 and aims
to ensure that the three Peaks (Ingleborough; Pen-y-ghent; Whernside)
area, which is one of the most heavily-used rights of way networks
in the country, is maintained and improved in the long term by:
— generating a sustainable income to help pay for its
management;
— creating new opportunities for businesses, groups
and visitors;
— promoting understanding of the area's special qualities;
and
— encouraging people to help look after the area.
The project gives users of the network the chance to support
the area and the work of the Authority by raising money for it.
This can be by:
— asking participants in sponsored events like charity
walks to donate part of their entry fee to the project;
— providing merchandise to celebrate walking one, two
or all of the peaks (whether in one go or over an extended period);
— joining the Friends of the Three Peaks; and
— building business and community interest in the area
that will help support it.
A number of major charities like the NSPCC and Heart Research
UK are using the Three Peaks area to raise money for their causes
this year and have already pledged their support for the project.
They will be donating cash to be used directly in the upkeep of
the Three Peaks path network.
Three Peaks has raised £19,000 since summer 2009.
Also worth noting is the visitor contribution scheme being
operated by the Yorkshire Dales Millennium Trust. Further details
are at: Yorkshire Dales Millennium Trust. The money raised goes
to support environmental, economic and social projects in the
Dales. "Donate to the Dales" generally raises £20,000-£30,000
per year from a combination of individual donations and corporate
donations.
APPENDIX 2
FURTHER EVIDENCE REGARDING HEADAGE PAYMENTS AND OVERGRAZING
BACKGROUND
The two headage support measures which significantly influenced
livestock farming in the uplands between the mid 1970s and 2003
were the Hill Livestock Compensatory Allowance (HLCA) and the
Sheep Annual Premium (SAP).
The HLCA was introduced in 1976 with 25% of the funding from
the European Agricultural Guidance and Guarantee Fund. The HLCA
was not conceived as a production subsidy. Its purpose was to
provide compensation for the additional costs of production in
the hills, to keep farmers in the less favoured areas and to support
the conservation of the countryside.1 However its method of delivery
was as a payment per ewe. The HLCA did limit the number of stock
for which support could be claimed, in the case of ewes this was
to a maximum of six per hectare but this limit is clearly beyond
the normally accepted environmental limit for moorland of two
ewes per hectare.
The SAP was introduced in 1981 as a payment per ewe. A limit
on the number of sheep for which support could be claimed was
introduced in 1989 and quotas introduced in 1993, using 1990 as
the reference year.2 However the support had already significantly
increased the trend towards higher stocking which was started
by the introduction of the HLCA. Quotas effectively stabilised
the overall ewe numbers but at a much higher level than in 1976
(see graph).
The value of the combined HLCA and SAP payments increased
significantly over time. For example, from £12.30 per ewe
in 1989-90 to £43.50 in 1999-2000. This corresponded with
a drop in value of the produce (breeding ewes, lambs and wool).
By 1999-2000 the average gross margin (income after variable costs)
per ewe on hill farms in Yorkshire was £23.70 compared with
£31.90 in 1989-90.3 The economic viability of hill flocks
had therefore largely become a factor of the numbers kept.
IMPACTS ON
LIVESTOCK NUMBERS
The importance of headage support to the overall economy
of hill farming encouraged higher stocking rates and the rise
in stock numbers is well documented. Indeed farmers accepted the
need to "play the numbers game".4 The number of breeding
ewes in Less Favoured Areas in England increased by around 35%
between 1980 and 2000.5 Some areas saw significantly larger increases,
such as a 55% increase in sheep numbers in the North Pennines
between 1975 and 1994.6 This increase inevitably affected moorland
rough grazing with the area of English and Welsh moorland rough
grazing stocked at over two ewes to the hectare (the nominal sustainable
limit) increasing from 27% in 1977 to 71% in 1989.7
The link between economic viability and headage also led
to changes in farming practice, such as an increase in out-wintering
on hill areas which increased problems of overgrazing and localised
poaching of the ground.8
GRAPH SHOWING CHANGE IN LIVESTOCK NUMBER
Source: Agricultural Census data taken from Table 18.2
"A hundred years of British Food & Farming" until
1983, and from each UK agriculture department from 1984 onwards
THE LINK
TO OVERGRAZING
Numerous reports and research documents draw a direct link
between the economic pressure on farmers to keep more stock and
overgrazing in the uplands. For example, see 5, 6, 8, 9, 10, and
14. MAFF developed a definition of overgrazing as:
"the result of environmentally unsustainable livestock
practice brought about through overstocking so that the growth,
quality and species composition of vegetation is adversely affected".
Controls were introduced between 1992 and 1994 as a result
of concern about the effect of the schemes on grazing levels.
15 Subsidy payments became conditional on not contravening the
overgrazing "rules" and contravention could lead to
withholding subsidies. It is true that subsidies were withheld
or reduced in only a limited number of cases, although the total
number of cases investigated was much higher. By the end of 2005,
151 (92,400 ha) cases had been investigated with 64 (13,000 ha)
still open. Sixty-three closed cases (45,000 ha) had gone into
either the Countryside Stewardship Scheme or Environmentally Sensitive
Area agreements, with additional ones in the Wildlife Enhancement
Scheme. 16
In 1993 the then Minister of Agriculture, John Gummer, launched
proposals for a series of new environmental schemes. These included
the Moorland Scheme which recognised:
"a priority environmental concern for the livestock sector
and for the uplands in particular is the need to extend the steps
already taken to reduce overgrazing of important habitats, particularly
moorland".11
The levels of stocking in the uplands, driven by support
based on headage, had led to the need for a national scheme aimed
at reducing stock numbers.
TRENDS POST
DECOUPLING
The decoupling of support from livestock headage to area
payment has resulted in a national decline in ewe numbers. In
some areas this had led to a virtual de-stocking of some uplands
and this is of concern. However, the availability of the Environmental
Stewardship Schemes has meant that hill flocks and cattle have
been retained in many areas and there is evidence that farmers
consider that these schemes have been successful in addressing
overgrazing and that heather is recovering. 12 This view is supported
by more recent assessments of both upland SSSIs and the LFA generally.
13
For the future it is important that the right mix and level
of grazing is supported so as to deliver the range of goods and
services for which the uplands are so important. Ultimately, the
required stocking type and density to achieve ideal management
will depend on the place. Local knowledge and flexibility are
therefore important. Food production will continue to be important
but so is water, carbon, wildlife, landscape etc. The challenge
is to find ways that help to keep farmers on the hill, managing
the land positively so that their management is both economically
viable and environmentally sustainable.
REFERENCES 1 Council Directive
EEC 75/268 28 April 1975.
2 Defra Observatory Monitoring Framework. Indicator Date
Sheet B12.
3 Farming in Yorkshire 1989-90 and 1999-2000. Askham
Bryan College of Agriculture.
4 North West Upland Farming: A Brief History. www.cumbriahillfarming.org.uk,
2008.
5 State of Nature: The Upland Challenge. p 52
Agriculture. English Nature, 2001.
6 Andrew Moxey, David Parsisson, Paul Evans. Modelling
the Effects of Agenda 2000 on the Farm Business. Centre for
Rural Economy Research Report, 1999.
7 D B A Thompson, A J MacDonald, J H Marsden, C A Galbraith.
Upland Heather Moorland in Great Britain. Centre for Rural
Economy Research Report, 1995.
8 Environmental Impact of Land Management. Natural
England Research Report NERR030. Chapter 8 Grazing Livestock in
the Uplands.
9 Sustainable Grazing in the English Uplands. English
Nature 2004.
10 Determining Environmentally Sustainable and Economically
Viable Grazing Systems for the Restoration and Maintenance of
Heather Moorland in England and Wales. Defra Research Project
Final Report BD1228, 31 March 2007.
11 Agriculture and England's Environment. MAFF, March 1993.
12 Economic and Environmental Impacts of Changes in Support
Measures for the English Uplands. Final Report to Defra by
Countryside and Community Research Institute and the Food and
Environment Research Agency, October 2010.
13 Mapping Values: The Vital Nature of our Uplands.
p 6 Food, Wood and Energy. Defra, 2007.
14 Developing Revised Methods to Assess Overgrazing on
Moorland. The Moorland Appraisal Pilot Project (MAPP), Defra
Rural Development Service, December 2003.
15 A Review of Overgrazing and Unsuitable Supplementary
Feeding Cross-Compliance Controls in England. Public Consultation
Paper, Defra, January 2003.
16 Grazing Management Annual Report January 2004 to December
2005. National Land and Grazing Management Team, January 2006.
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