The outcome of the independent Farming Regulation Task Force - Environment, Food and Rural Affairs Committee Contents

Written evidence submitted by the Grasslands Trust

1.  The Grasslands Trust[2] welcomes the Environment Food and Rural Affairs Committee's inquiry into the Farming Regulation Task Force's Report "Striking a Balance". We support reducing the bureaucratic burden for farmers, but only where that does not reduce regulatory environmental protection.

2.  The Grasslands Trust is a UK-based charity, working to ensure the future of grasslands that are important and valuable for wildlife, heritage and communities. Our work focuses on protecting the UK's most valuable grasslands, restoring those that have been degraded, and creating new grasslands for wildlife and communities. Grasslands rich in wildlife provide a wide range of ecosystem services[3], compared with agricultural grasslands, where food production is the sole purpose.

3.  Past policies affecting grasslands have focussed mainly on food production, to the detriment of the wide range of other public goods that grasslands provide. Consequently, of five million hectares[4] of grassland in England (over 50% of the total Utilisable Agricultural Area), only an estimated 100,000 hectares[5] (2%) have escaped agricultural intensification, while another 1.45 million hectares[6] (30%) have been modified by agriculture but still retain limited wildlife and heritage value. The remainder is intensively managed productive grassland, devoid of wildlife and heritage value.

4.  Agriculture created and maintained most of England's valuable grasslands: these grasslands rely on sympathetic agricultural management for their future. Intensification and abandonment threaten the future of these grasslands. Education, incentives and regulation are needed, to help landowners recognise the value of these grasslands, support the costs of sympathetic management, and ensure that they are protected from the market failures that value agricultural production above the wide range of other values they embody, including ecosystem services.


5.  The Grasslands Trust submitted written and oral evidence to the Taskforce on Farming Regulation, that evidence focussing on the weaknesses in the Environmental Impact Assessment (Agriculture) Regulations[7] that is supposed to protect "semi-natural" grasslands from "intensive agriculture", derived from the EU's EIA Directive from 1985. The Report (sections 6.92 and 6.93) suggested that there had been "an element of gold plating" when the Regulations were prepared, because the threshold of 2ha was "significantly lower than other member states".

6.  The authors did not recognise the different context in England, compared with other member states. According to research carried out last year [8], other member states still have between 20% and 30% of their agricultural land supporting grasslands rich in wildlife and heritage: England has 2%. Moreover, the size of surviving grassland fragments in England is very small - especially outside areas protected as Sites of Special Scientific Interest. Finally, most other member states' grasslands are less vulnerable to intensification because of their agricultural systems, topography, soils or climate: they are more vulnerable to abandonment. We do however recognise that the Report did not recommend increasing the current 2ha threshold.


7.  Information on the location and status of valuable grasslands is still inadequate, and this is one of the biggest factors contributing to the continuing loss of valuable grasslands to intensification, because some landowners are unwittingly destroying valuable grasslands. We therefore strongly welcome the Report's proposal "to establish a better way to identify these valuable sites…". Natural England's current grassland inventory has been recently updated, but is still not fit for purpose. A concerted effort is needed to identify and characterise all surviving valuable grasslands, and those grasslands that can be restored for their wildlife and heritage value.

8.  The EIA (Agriculture) Regulations also form part of Cross Compliance, as GAEC 5. No farmer has had their Single Payment reduced for failure to comply with this GAEC. Yet we regularly receive information about cases where valuable grasslands are lost to intensification. This is a strong argument for better enforcement. If RPA inspectors already knew where the valuable grasslands occurred on each holding, it would be enable easy compliance checking by reference to the inventory. Landowners would also not need to check with Natural England whether they have a "semi-natural area" or not; and entering them into Agri-Environment Schemes, would automatically achieve "earned recognition", a key principle being promoted in the report.

9.  We do not support the concept that compliance with GAEC 5 or the EIA (agriculture) Regulations can be achieved through the Red Tractor accreditation system. This is a non-statutory system, and Red Tractor Inspectors are likely to be even less aware of the relevance of the Regulations than RPA inspectors, unless they receive adequate training.

10.  Section 7.65 recognises the nonsense of the current CAP Permanent Pasture rules[9]. These rules were introduced to prevent large-scale conversion of pasture to arable land. In England, there are 3.66 Million hectares[10] of "permanent pasture", but most of this is intensive agricultural grassland. In England "permanent pasture" can be annually re-seeded.

11.  We strongly support the Report's recommendation in the report that "Defra investigate whether there is a better method of assessing whether high quality grassland is being eroded." A comprehensive grassland inventory is a prerequisite for assessing trends.

12.  As part of the current CAP reform process, we and the European Forum on Nature Conservation and Pastoralism have also proposed that a Permanent Pasture Premium[11] should be available, as one of the "Greening Pillar 1" options. This premium would be paid to all those eligible for Single Payment, and in return for the payment conditions would include: no re-seeding or overseeding; no cultivation and restrictions on total fertiliser application. This could be a useful incentive to farmers managing valuable grasslands sympathetically, rather than intensifying or abandoning them.

10 June 2011

2   Registered Charity no. 1097893. Back

3   The National Ecosystem Assessment. The True Value of Nature. 2010. Back

4   June Agricultural Census 2010. Back

5   Natural England (2008). State of the Natural Environment. Back

6   Countryside Survey 2007. Back

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9   EC Regulation 796/2004 "Permanent pasture": shall mean land used to grow grasses or other herbaceous forage naturally (self-seeded) or through cultivation (sown) and that has not been included in the crop rotation of the holding for five years or longer. Back

10   Data provided by RPA to The Grasslands Trust February 2011.  Back

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Prepared 23 September 2011