Greening the Common Agricultural Policy

Written evidence submitted by Devon County Council (GCAP 13)

Introduction to Agriculture in Devon

Agriculture is an integral part of the Devon Economy and wider community. Agriculture Forestry and the Farming sector accounts for 3% of Devon’s total GVA and Employs 7% of the workforce. However it is the wider benefit of the public goods that agriculture provide, which has a much more significant impact. Tourism is Devon’s single largest industry; it is reliant upon the natural environment and Devon’s rural communities. A competitive and sustainable Agricultural industry is essential to underpin the Devon Economy and the rural communities.

Rural Research in Devon has highlighted the dependency of Devon’s agricultural industry on CAP payments (notably the Single Farm Payment and agri-environmental funding) it’s estimated that Devon receives in the order of 173 million from CAP funding which equates to approximately a third of agricultural income. Devon farmers are particularly vulnerable to changes in the CAP that could see individual payment levels fall. The dominant agricultural sector is Livestock and the average size of farm is lower than the national average.

We would encourage the continuation of direct payments, as this is vital to the profitability of farms. We would also encourage the recognition of the public benefits that agriculture provides and the continuation of agri environmental payments. However we are aware of the complex nature of the existing scheme and would not encourage a CAP reform to introduce new measures that would be even more complicated and costly to deliver.

Some of the Committee’s specific questions are addressed below:

Whether the proposal to green direct payments will generate significant environmental benefits;

In the wider sense, for example in large areas of monoculture, greening of direct payments should have a significant impact so therefore looking at the EU as a whole it is a positive thing. However for areas such as Devon which are made up of much smaller farms of which many are already in entry or higher level stewardship, the additional benefits could be negligible.

The impact of additional greening requirements on food production and the competitiveness of the agricultural industry.

Unless a farm is totally under permanent grassland, farms which have more than 3 ha of land under crop cultivation has to grow at least 3 different crops, each no less than 5% or more than 70% of the land area. We assume this is aimed primarily at large farms to reduce vast areas of ‘monoculture’ such as those in Eastern Europe, however for much smaller farms in Devon the proposals could act to limit the business flexibility for crop rotation and therefore other diversification options. For example, a small mixed farm might want to grow a bit of barley for extra feed and straw but would have to grow three crops which it may not really want. In addition, any pasture which is permanent in 2014 will have to stay that way throughout the CAP period which further reduces flexibility and ability to respond to market changes. Another dilemma for arable or mixed farmers who are seeing strong grain prices will be whether they are willing to lose land to both HLS and greening?

Recommendations for improving the greening proposals; consistency of the greening proposals with the CAP simplification agenda.

Would a simple improvement be to significantly increase the threshold of ha for crop cultivation from 3 so that the larger farms only are targeted? We would leave suggestion of the exact figure to which it should be increased to partners with more expertise in this area. This might also reduce some of the complexity of administration.

How greening pillar 1 can be made coherent with agri-environment schemes.

Farms also have to devote at least 7% of their eligible land (excluding permanent grassland) to be an ‘ecological focus area’ so where farms already have buffers and other ecological areas under entry or higher level Stewardship schemes do we assume these cannot be counted as part of the 7% because that would create issues with double funding? Therefore increasing quantities of land has to remain ‘unused’ which could dissuade farmers (particularly those with less land) from participation in stewardship.  There is no clear indication in the proposals on how ‘greening’ fits with the agri-environment schemes – is there a real danger that ‘greening’ could make the entry level scheme redundant? This would be very bad news for places like Devon.

From a Devon perspective we want to see proposals managed so that they encourage farmers on all sizes of farm across the EU to undertake environmental practices while enabling smaller farms to retain the flexibility which is essential to a viable business. These businesses are key to maintaining our unique high quality environment in Devon.

In addition, the Committee welcomes interested parties’ views on other elements of the CAP proposals.

We are pleased that the EU has opted for the ‘Integration’ option which we feel is best suited to the agricultural landscape in Devon as described in the introduction above. The six priority themes cover a wide range of support and we are particularly keen to see theme 6 feature in the UK and regional programme ‘Promoting social inclusion, poverty reduction and economic development in rural areas’.

It is hoped that The UK government will actively involve local partners such as ourselves in the development of the new national and regional rural development programmes and we look forward to working together in a timely manner so that the programmes are ready to commence on 1st January 2014. We also want to maximise the opportunities for running joint programmes with the structural funds in what we hope will be a Devon Transition Area. We ask that the UK government will consult local partners on rural development measures will be included in its programmes, and on the creation of a national rural network, for which there must be the potential to build on a number of bodies already in existence.

We are very keen to build on the local delivery partnerships currently in existence, particularly Local Action Group’s to deliver the 5% ring-fenced for Leader as well as potentially joint funding programmes to include EU structural funds as well as RDP funding. The sooner we can start working towards this the better, in order that these partnerships don’t loose their impetus and stakeholder buy-in due to budget reductions in the current RDP, which has meant that some are no longer able to distribute funding.

As the committee is no doubt aware we currently have several Less Favoured Area’s in Devon and it is essential that these continue to receive the support they need through the programme. The NFU are concerned about the effects of the proposed changes to designation of LFA’s and we agree that the proposals should reflect that some LFA’s are disadvantaged because of a combination of several factors covering most of the area, and not the existence of just one factor, covering 66% of the area. We would like to see a finer scale of designation for these areas (i.e. parishes instead of wards) and the threshold changed to 50% of the area, as well as provision for combinations of factors contributing to an areas designation.

November 2011

Prepared 30th November 2011