Greening the Common Agricultural Policy

Written evidence submitted by the National Trust for England, Wales and Northern Ireland (GCAP 20)

1. Introduction and executive summary

1.1 We welcome the opportunity to respond to the Environment, Food and Rural Affairs Select Committee Inquiry into the ‘greening’ proposals of the Common Agricultural Policy (CAP) for 2014-2020. This comes at a time when there is a clear need to ensure the CAP can adequately respond to the twin challenges of feeding a growing global population whilst safeguarding the natural resources on which agriculture depends.

1.2 The inquiry is well placed to reinforce the inextricable link between food security and environmental security and determine whether the Commission’s proposals adequately recognise and address this fundamental relationship.

1.3 As an organisation with a direct interest in 200,000 ha of farmland across England, Wales and Northern Ireland, the National Trust is concerned that the CAP proposals could fail to integrate food security with environmental security and risk jeopardising funding that directly supports the conservation of wildlife, natural resources and cultural heritage across the farmed landscape.

1.4 We welcome the European Commission’s ambition to ‘green’ the CAP but believe the proposals fall short of achieving this aim, not least because they are not significantly forward thinking, fail to recognise the need to better integrate the environmental objectives of both Pillars 1 and 2 and do not go far enough to make the first Pillar deliver for the wider public good. We were hoping to see proposals that delivered much more for natural resources underpinning the farmed environment, preparing us for an uncertain future of climate and food insecurity.

1.5 We believe the CAP should aim to achieve four key objectives. Firstly, the new CAP must secure a net environmental gain for Europe. In this respect, the proposals should deliver meaningful and demonstrable benefits, with both Pillars working together. Secondly, it must provide the right tools and help Europe meet the EU 2020 strategy objectives and environmental commitments in relation to biodiversity, climate change and water. Thirdly, the new CAP must help put the UK’s and Europe’s food production onto a significantly more environmentally sustainable basis, thus securing long-term food security for European citizens. Food production depends on functioning ecosystems that maintain good quality soils, water availability and stable climates. And fourthly, the new CAP must demonstrate good value for money. For the CAP to be a legitimate use of taxpayers’ money, it must avoid any significant environmental negative impact and deliver efficient and effective mechanisms to reward farmers and land managers for the delivery of environmental public goods.

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

2.1 The proposal clearly states that: "the future CAP will be […] a policy of strategic importance for food security, the environment and territorial balance … Therein lies the EU added value of a truly common policy that makes the most efficient use of limited budgetary resources in maintaining sustainable agriculture throughout the EU, addressing important cross-border issues such as climate change and reinforcing solidarity among Member States, while also allowing flexibility in implementation to cater for local needs" (Explanatory Memorandum, p.3, Direct Payments Regulation). We welcome this statement of intent, but the proposals, as written, appear to significantly over-estimate their ability to generate significant environmental benefits.

2.2 We broadly welcome the principle of mandatory ‘greening’, but the proposed package of measures is unlikely to achieve significant environmental benefits. It is inherently weak due to the Commission’s criteria of simple, annual, non-contractual and generalised design. The proposals also undermine and conflict with agri-environment schemes which are more advanced, contractual, multi-annual and targeted, i.e. better value for money. Both Pillars 1 and 2 need to be much more complementary in their design if future public support is to be maintained, and so if the ‘greening’ measures are to be retained they need to work in practice.

2.3 In the UK, retention of permanent pasture beyond a 2014 baseline will not necessarily deliver any real benefits. There may be a risk of a net loss of grassland as a result of pre-emptive cultivation ahead of the 2014 date to enable farmers to have freedom of cropping and potentially access to valuable cereal markets in future.

2.4 Please refer to Point 5 below for further technical information in relation to individual ‘greening’ measures.

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

3.1 What has been proposed is very basic and is unlikely to impact on food production and farm competitiveness. Many farmers are already employing many of the proposed measures through good agronomic practice or through meeting current cross compliance requirements.

3.2 The suggestion that designating 7% of a farm as ecological focus areas will mean taking land out of production would not, as claimed, be a return to set-aside since many of the features captured as part of this particular measure, such as landscape features and buffer strips, are already covered by cross compliance or agri-environment schemes.

4. Consistency of the greening proposals with the CAP simplification agenda

4.1 We are deeply concerned that whilst intending to ‘green’ direct payments what has been proposed will, in fact, create significant administrative and monitoring burden that will render it unworkable.

4.2 The measures as described would presumably be recorded on the SPS SP5 data sheets and automatically be made available – for example permanent pasture codes PP1 and PP4, along with crop types for each field. However, the way to identify ecological focus areas is less clear and may require increased mapping data to record additional features. This could be problematical if the features change annually, such as the location or size of buffer strips.

4.3 We believe the proposals represent a missed opportunity to develop cross compliance alongside Pillar 1 ‘greening’ measures to serve as an enhanced environmental baseline for Pillar 2 rural development schemes.

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

5.1 Efforts to ‘green’ farmers direct payments must deliver or ‘buy’ genuine outcomes for the environment and not undermine ‘added-value’ agri-environment schemes that encourage farmers to manage their land in environmentally beneficially ways.

5.2 We believe that the greening measures as proposed need to be revised in order to improve the current measures and make them more consistent with agri-environment schemes. In due course, the overall approach should evolve into a more sophisticated system, not least enshrining the whole of Pillar 1, if the two pillar system is going to be retained.

5.3 It is likely that both higher level agri-environment schemes and organic farms in the UK would already meet the greening measures. However, as currently proposed, only organic farms would be exempt from the greening measures. If that is the case, there is an argument that higher level agri-environment schemes should also automatically qualify for the 30% greening measure.

5.4 Nonetheless, we would argue that all farms at all scales should be expected to comply with the greening measures from the outset so that as and when they become more sophisticated, they are uniformly applied and different farm types are not disadvantaged.

6. Recommendations for improving the greening proposals

6.1 In general, there is an argument that the proportion of land covered by greening measures should be extended well beyond 30%. However, we appreciate that the existing greening measures are unsophisticated and the benefits to increasing the proportion are likely to be felt most beyond the UK where agri environment schemes are less advanced.

6.2 An alternative proposal worth proper consideration might be that instead of the three options, the greening measures could instead require entry into a specified agri-environment scheme. This could be available to all applicants and would make at least part of Pillar 1 funding conditional on Pillar 2 and should avoid dual funding concerns.

6.3 Permanent grassland

6.3.1 We have a number of concerns around this measure. Firstly, the baseline year should not be set in the future, in 2014, but be set based on current or previous agricultural land use designations as of 2011 to discourage pre-emptive cultivation. As proposed, this future date could present a very high risk of soil erosion and consequent loss of nitrogen, carbon and biodiversity across the EU, if farmers are inclined to cultivate land now to avoid it being locked into a permanent pasture post-2014.

6.3.2 Secondly, there is no distinction between permanent pasture of high environmental value and improved grassland that has been established for over 5 years, such as long-term ryegrass leys. If 5% of a farm’s permanent pasture is to be allowed to be cultivated annually, a measure is required to identify and protect high nature value grassland for example by strengthening current environmental impact assessment legislation.

6.3.3 Thirdly, consideration should be given to a derogation permitting cultivation of improved permanent grassland of low nature conservation value to re-establish rotational farming systems that deliver a net environmental gain. This could be achieved by way of a new definition for semi-permanent grassland that can be cultivated, re-seeded or rotated within a holding and which satisfies an environmental impact assessment or which will form part of an appropriate agri-environment scheme.

6.4 Ecological focus areas

6.4.1 This measure, based on an annual management prescription, is unlikely to provide any long term benefit over the period of the CAP term as it lacks continuity and is little more than what agri-environment schemes and cross compliance rules already deliver but over a longer timeframe.

6.4.2 Given the potential overlap with ‘Good Agricultural and Environmental Condition’ (GAEC) standards and agri-environment commitments that extend into the next programming period, clarity is required on duplication of requirements and funding, as well as the impact on the design and uptake of new ‘entry-level’ type agri-environmental schemes. If designed correctly, with the right mix of features and management requirements, this measure would incentivize adoption of higher level agri-environment commitments.

6.4.3 As the proposals stand, there is an implication that the 7% ecological focus areas might need to be above and beyond any existing agri-environment scheme features due to dual funding rules.

6.5 Crop diversification

6.5.1 We foresee difficulties with demanding mixed cropping on very small areas and would recommend raising the minimum area from 3 ha to a more practical threshold, for example 50 ha. There is also a strong case for ensuring that leguminous crops should form part of the crop mix and that consideration be given to specifying a maximum single crop area to avoid a situation where, for example, a large 1,000 ha farm could still employ a large monoculture block of 700 ha.

6.5.2 A three hectare threshold for arable farms to cultivate a minimum of three crops is too low and will discourage those mixed farms which currently employ around 4 ha extensive cropping of spring barley, oats or turnips from carrying on with this practice. This would have a potential negative impact on small-scale arable systems in upland areas, which are usually focused on delivering agri-environment and biodiversity benefits within predominantly grassland areas (see also Permanent grassland).

6.5.3 More broadly, this proposal would impact on the ability of small farms to make financial, market driven decisions and achieve economies of scale and farm efficiencies, create crop store management (the need for segregation of multiple crops in relatively small quantities) and agronomic issues (where continuous wheat is practiced as a way of managing disease take-all) and complicate contracting agreements (one of the ways in which small farms are able to remain viable). Although not an issue for many farmers, it does therefore have the potential to be anti-competitive.

7. Other issues having an impact on the CAP ‘greening’ objectives

7.1 There are other issues that will have a direct impact on the Commission’s objectives to ‘green’ Pillar 1 of the CAP. The active farmer and capping proposals pose real risks for the Trust’s delivery of environmental outcomes on the land we manage directly to conserve wildlife, landscape and provide public access for the benefit of the nation – our statutory purpose. However, we understand these are unintended consequences of the Commission’s proposals and we are working with the UK Government and Commission to resolve these issues.

November 2011