Greening the Common Agricultural Policy

Written evidence submitted by Tom Allen-Stevens, Oxfordshire Farmer (GCAP 02)

CAP Reform

Views on EU proposals to ‘green’ the Common Agricultural Policy

1. Summary


Proposed greening measures will not deliver significant environmental benefits because they are too prescriptive and do not recognise the good environmental work already undertaken by many farmers, such as ourselves. We’ve found recent reforms have simplified the subsidy system and enabled us to increase production and deliver greater environmental benefits. But these proposals threaten to reverse this progress.

Greening should be achieved through expanding Pillar 2 at the expense of Pillar 1. But the overall objective of the EU Commission in this reform is to justify the CAP to the taxpayer. So therefore there should be an exemption from greening measures for those farmers who invite taxpayers on to their farm to show them where public funds are spent. This is work we do, and 100s of farmers like us, through Open Farm Sunday, Educational Access, farm visits and Care Farming. But it gets little recognition, and its value to CAP and to society is underestimated.

2. Will the proposal to green direct payments generate significant environmental benefits?


2.1. I don’t believe it will. This idea has not been thought through with consideration for how it will be put into practice on farm. Generally speaking farmers are not averse to encouraging the environment and wildlife, but are much more willing to do so voluntarily under a range of options that they can pick that will suit their farm.

2.2. On our farm, around 17% of the land is in non-food production, generating benefits for wildlife. We have 5km of hedgerows, 3.5km of ditches, 3km of grass margins – I could go on. We’ve chosen options from ELS that suit the farm. There are areas that were in set aside that fall outside ELS we continue to maintain as wildlife habitats, supporting a growing population of grey partridge, and these areas I count towards our contribution to Campaign for Farmed Environment. We have pond buffer areas, and have positioned grass margins to protect water. We have developed our cultivation and rotational policies to ensure sustainable production, so that this farm can continue to meet the challenges of feeding a growing population from our soils. I think we’re doing our bit, and I think a lot of other farmers will say the same.

2.3. But the current proposals will force us to take extra measures that are too prescriptive and will affect all of our farming area. If ratified in its present form it will purely be seen as a box-ticking exercise to get the subsidy, and sorely resented as a result. That’s not the way to incentivise us to encourage wildlife or preserve the environment, and I’d warrant most other farmers would say the same.

2.4. I also resent the implication from these proposals that we are not farming in a way that is sustainable and ‘green’ and that further measures are therefore required. Those who come here and see the farm will know that is simply not the case.

3. What will be the impact of additional greening requirements on food production and the competitiveness of the agricultural industry?


3.1. They will have a negative impact and this entirely flies in the face of the Commission’s earlier promises that it wanted to increase competitiveness.

3.2. Taking an extra 7% of land out of production is madness. On this farm we have carefully chosen areas that have been taken out of production to maximise their wildlife benefit but minimise impact on food production. I believe we’ve succeeded – we’re producing significantly more than we were pre-1992/MacSharry reforms on less cultivated/grazed land. But we’re not a high production farm. That 17% we’ve taken out reflects the area that can deliver more public good through non-food production than if we were to crop or graze it. Previous CAP reforms have worked extremely well to enable us to identify those areas and deliver on that objective. But we’re there now – take any more land out and it would impact on food production and our ability to compete.

3.3. It’s the same on every other farm in the UK – most farmers should have found the balance of land they can take out of production without having too great an impact on their ability to produce food. This could be 0.5%, it could be 50%. To take 7% of Grade I Lincolnshire silt out of production, for example, would be complete folly. But that doesn’t mean to say that a Lincs high-production unit can’t deliver high environmental benefits.

3.4. Our farm is under a contract-farming arrangement and we restructured the agreement after the single payment (SP) came in so that we can respond more closely to market signals – the contractor gets different per-acre rates that relate to the profitability of individual crops. If market price plummets, he can chose to leave some land fallow, without penalty – this wasn’t possible before SP. Equally it allows for block-cropping if he wants to exercise a rotation that uses this farm as part of the total area he farms, and thereby gain a production and competitive advantage.

3.5. This flexibility and ability to respond to market signals would be threatened by proposed CAP reforms, in particular the requirement to plant at least three crops. Over his entire area the contractor grows at least five or six different crops, rotating them carefully to ensure the system is sustainable and builds inherent fertility. But in any one year there may be only two crops on this farm – he currently has the flexibility to plant just one. Yet soil fertility has improved under this system, while wildlife has benefited from other measures we’ve adopted.

4. How consistent are the greening proposals with the CAP simplification agenda?


4.1. The proposals don’t seem to fit very well within the simplification agenda. They will inevitably add extra tiers of checks. You wonder whether actually they’re making it more complicated. This would persuade farmers it’s not worth the bother, thereby reducing the number of farmers who actually want to claim subsidy.

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


5.1. I can’t understand why the EU appears to be abandoning Pillar2. The whole point of introducing Pillar 2 was that this was the green pillar – it would start off small and grow. ELS and HLS are very good schemes. Considering the complexity of what they’re managing, NE deliver a really good service, both to farmers and the public. They offer farmers choice and reasonable rewards for a good job done. The obvious no-brainer solution is to expand these schemes to occupy say 30-40% of the budget, modulating funds accordingly, and to leave pillar 1 well alone.

5.2. There are a great many good schemes that should be brought within ERDP as part of an expanded Pillar 2. Easier access into HLS should be among these, and in particular recognition for Educational Access and Care Farming.

6. Recommendations for improving the greening proposals


6.1. The requirement for greening has come from Cioloş’ agenda to make the CAP more agreeable to the taxpayer. So rather than get reluctant farmers to green up their offering, would it not be a better idea for farmers to invite taxpayers on to their farm to see where the money is spent?

6.2. This is something we do each year on Open Farm Sunday – we receive about 200 visitors and include a tour of the farm, showing them the environmental work we do and what it’s delivering, as well as how we produce food sustainably. We find visitors are not only grateful and find it worthwhile, they enthusiastically support us.

6.3. There are around 350-400 farmers who open each year for Open Farm Sunday and survey results from them and their visitors suggest this type of direct involvement with the general public is a very effective route to increase understanding of how public funds are spent and the countryside cared for. There are now over 1000 farmers who have taken part in OFS since it started 5 years ago, and over 1 million visitors have attended an OFS event.

6.4. In addition there are 1000 Educational Access agreement holders in HLS who host farm visits, mainly schoolchildren, to give them a greater appreciation of how the countryside is farmed.

6.5. Farmers who do this work should be given an exemption from the greening proposals, similar to organic farmers. While there is still scope for many farmers to increase the environmental value of their farm, it is as important that the taxpayer is shown the good environmental work that is currently carried out with public funds.

6.6. Cioloş himself is in favour of this idea. In a recent interview with NFU British Farmer and Grower magazine, in which NFU members were invited to submit questions, he chose the question reproduced below as the ‘star question’ and gave the answer indicated:

Q Rather than justifying the CAP to taxpayers through greening, why not reward every farmer who brings the public onto their farm and shows them how the CAP funds are spent?

A Farmers look after roughly two-thirds of the land in the EU. As a result, if we get all farmers to do just a little bit more, then greening can really make a difference. I agree with your idea of getting the non-farming public to better understand what CAP funds do – and maybe member states can look at encouraging farm visits under a rural development scheme.

6.7. Educational Access currently gets a pitiful share of ERDP funds because none of the money comes from the European pot – it all comes from UK Treasury funds, despite the fact it clearly delivers a European objective of showing the taxpayer where CAP funds are spent. OFS is currently 80% funded by commercial sponsors (20% public funds). But it is the farmers themselves who put in the most resource, most of which goes unrewarded, so it is unsurprising there are so few who carry out this good work.

6.8. If Defra was to push for this exemption, and push for farm visits to be funded from modulated EU funds, these are clearly both moves that would be supported by the EU Commission – they would be pushing at an open door.

We have a 170ha arable farm near Faringdon in Oxfordshire. I am also training coordinator for Linking Environment and Farming (LEAF) that organises Open Farm Sunday. I managed the event for LEAF in 2010. I am also director of Farming in the Park, that plans to bring a major food and farming festival to Hyde Park in September 2013. I am also editor of Crop Production Magazine (CPM). The views expressed are my own, and not those of the organisations I represent.


11 November 2011

Prepared 30th November 2011