Greening the Common Agricultural Policy

Written evidence submitted by The Woodland Trust (GCAP 23)

1. The Woodland Trust is the UK's leading woodland conservation charity. We have three aims: to enable the creation of more native woods and places rich in trees; to protect native woods, trees and their wildlife for the future; and to inspire everyone to enjoy and value woods and trees. We own over 1,000 sites, 20,000 ha, of which 20% is farmed. We have 300,000 members and supporters.

Summary

2. Whilst we recognise that the European Commission wants to take steps to achieve better environmental results across the whole of the Common Agricultural Policy the very nature of that aim means using very simple, generic actions which are unlikely to achieve significant environmental benefit.

3. The greening proposals are limited in extent and already have the potential to be better achieved in the UK through a combination of cross compliance and agri-environment schemes.

4. If greening of Pillar 1 is to go forward then Ecological Focus Areas should include trees planted to address farm scale issues however they were funded.

5. The budget currently assigned for greening Pillar 1 would achieve better results added to Pillar 2 to support country specific rural development.

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

6. The CAP remains the largest factor in agricultural land-use in the UK and therefore a key issue for woodland conservation. Increased tree cover is recognised as a means of mitigating climate change, achieving benefits for agriculture and agricultural adaptation to future climate changes and delivering a wide range of benefits to society [1] , [2] .

7. Pillar 1 still represents 75% of the overall CAP budget with only 25% of the budget being used for country specific, rural development which supports dynamic and sustainable rural communities including the environment.

8. Previous experience has suggested that significant environmental benefits are best achieved when schemes are clearly targeted, multi-annual and supported by advice and monitoring. [3]

9. The greening proposals as currently proposed are poorly targeted, not taking account of regional variations in landscape character or farming system. The "one size fits all" nature of the proposals might appear to meet the aims of simplification of the overall CAP but fails to support farmers who will now have to push their farm management into potentially uncomfortable systems to avoid losing money.

10. Ecological Focus Areas provide an opportunity to support positive environmental benefits at a farm scale. From a woodland point of view, however, they only apply to land already planted under pre-existing schemes which seriously limits the land available to take up this option.

11. Ecological Focus Areas specifically mention the potential for buffer strips, but unless the land has already been planted these strips will be grass buffers. Buffer strips with trees have been shown to be more efficient in some situations. [4] Under the current proposals there is no potential for bringing in land specifically planted in response to farmscale issues unless the funding was originally provided by a previous Rural Development Plan scheme, this is surely contradictory to the aims of the greening process.

12. There are no suggestions for the future of greening in the next reform of the CAP such that trees planted within the 2014-2020 period would be considered for any future greening element.

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

13. The last two reforms of CAP have seen a move to countries developing broad and shallow agri-environment schemes which allow an entry point for all farmers, alongside the more targeted and specialized environmental schemes which only some farmers can access.

14. In England the Entry Level Scheme has been very successful in enabling farmers to undertake simple, environmentally beneficial actions which relate to their landscape and farming styles and has also acted as a means of introducing agri-environment mechanisms to a skeptical audience.

15. In order for the proposed greening of Pillar 1 to be operational it will be necessary for some existing conditions to be removed from cross compliance (Good Agricultural and Environmental Conditions) and, in England, some measures to be removed from the Entry Level Scheme. This is confusing and complicates an already complex process of grant and entitlement management.

November 2011