Written evidence submitted by the Grasslands
1. The Grasslands Trust
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
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,
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
of grassland in England (over 50% of the total Utilisable Agricultural
Area), only an estimated 100,000 hectares
(2%) have escaped agricultural intensification, while another
1.45 million hectares
(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
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 ,
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.
These rules were introduced to prevent large-scale conversion
of pasture to arable land. In England, there are 3.66 Million
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
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
The National Ecosystem Assessment. The True Value of Nature. 2010.
June Agricultural Census 2010.
Natural England (2008). State of the Natural Environment. http://www.naturalengland.org.uk/publications/sone/sone2008.aspx Back
Countryside Survey 2007. http://www.countrysidesurvey.org.uk/sites/default/files/pdfs/reports2007/england2007/CS-England-Results2007-Chapter04.pdf Back
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
Data provided by RPA to The Grasslands Trust February 2011. Back