Greening the Common Agricultural Policy

Written evidence submitted by The Wildlife Trusts (GCAP 25)

The Wildlife Trusts and the Agricultural Landscape: Introduction

There are 47 Wildlife Trusts across the whole of the UK, the Isle of Man and Alderney. We are working for an environment rich in wildlife for everyone. With more than 800,000 members, we are the largest UK voluntary organisation dedicated to conserving the full range of the UK’s habitats and species whether they be in the countryside, in cities or at sea. More than 150,000 of our members belong to our junior branch, Wildlife Watch. We manage 2,300 nature reserves covering more than 90,000 hectares. The Wildlife Trusts have a collective vision to create A Living Landscape and secure Living Seas for the whole UK.

A Living Landscape is a recovery plan for nature championed by The Wildlife Trusts since 2006 to help create a resilient and healthy environment rich in wildlife and to provide ecological security for people. In A Living Landscape habitats are restored and reconnected on a large scale with the local community closely engaged. The vision is a primary objective of The Wildlife Trusts and builds on a groundswell of landscape-scale activity at a county level. Across the UK we now have over 100 Living Landscape schemes covering an area of nearly 1.7 million hectares. The schemes are being delivered in partnership with a huge number of individuals and organisations including farmers and landowners, water companies, land-based industries, local authorities, other NGOs, statutory agencies, local communities and volunteers.

Every year we advise more than 5, 000 landowners and provide more than 2,600 days of land management advice to businesses. We offer support and advice to farmers on both Entry Level and Higher Level Stewardship Schemes, both assisting new applicants to navigate the processes involved and providing continued support to existing agreement holders. As a direct result of this advice, we help to bring millions of pounds to the rural economy every year. We also provide in-depth advice and management plans on habitats from hay meadows to upland wetlands, share expert knowledge for the management of specialist species, deliver workshops to encourage the discussion of ideas, and assist with land management using volunteers. We conduct thousands of advisory visits every year, covering topics such as resource protection, livestock management and agri-environment schemes.

We work with landowners responsible for Local Wildlife Sites (LWS), delivering whole farm advice as well as survey and grant application assistance. There are around 40,000 LWS’s in the UK covering more than 700,000 hectares of land, and two thirds of these important sites are in private ownership. They not only provide refuges for a range of wildlife, but also act as stepping stones to link nationally important areas. Lack of management is the main cause of loss and damage to these critical sites.

Farmers and landowners play a leading role in achieving A Living Landscape by managing their land to protect and enhance wildlife.

Executive Summary

CAP reform is of critical concern to The Wildlife Trusts in our role as land managers, as land management advisors and as active and long standing members of the rural community. It has the potential to significantly facilitate or significantly constrain our ambition to create A Living Landscape across the UK. It will influence delivery of the ambitions for ecological restoration set out in the Lawton Report (Making Space for Nature) [1] and reiterated in the Natural Environment White Paper [2] .

Our written submission to the Committee primarily addresses the environmental benefits of the proposed green direct payments. We think it important that the Committee considers the principles of greening the CAP and views the reform proposals against the background of the current CAP. Hence we have summarised our views on why greening is needed and made reference to some of the lessons learnt from the current payment systems.

We have provided our initial assessment of the environmental benefits of the proposed greening measures and have made some recommendations for improvement. We have provided initial comments on coherence with agri-environment schemes and the consistency of the greening proposals with the CAP simplification agenda. Given the tight timescales for this submission however, we have been unable to develop our response in as much detail as we would have liked. We therefore very much welcome the opportunity that we will have to develop our responses and suggestions for improved measures in the oral evidence session.

We have also submitted evidence on the definition of ‘active farmer’ as outlined in the current proposals. This has major implications for The Wildlife Trusts and the future of the land that we manage.

In summary, The Wildlife Trusts welcome the principle of a ‘greener’ CAP and welcome the move towards making direct payments to farmers and land managers contingent on delivery of a range of public goods and services relating to climate and the environment. Our view is that no payment should support unsustainable practice that undermines ecosystem function or biodiversity (which underpins ecosystem services). We think that at least 30% of direct payments should be conditional on specific 'green' measures that help to address market failure. We have concerns about some of the specific greening measures proposed, but believe we need to grasp the opportunity to improve these; suggesting changes raher than rejecting the measures and the principle of greening direct payments outright.

Making the greening measures of Pillar I coherent and compatible with agri-environment schemes is a major challenge. To achieve this we think that Member States must be given flexibility in the way in which greening measures are implemented.

Over the coming months we want to work with Defra, UK Government, environment NGOs and farming and landowner organisations to ensure that the CAP of the future supports an agricultural landscape that delivers sustainable farming and multiple benefits.

1. Environmental Benefits of the Green Direct Payments

1.1 Key Principles

· Farmers and land managers need to be provided with incentives for managing their land and businesses to deliver the full range of public goods and services associated with the agricultural landscape, including biodiversity, climate regulation and cultural and social benefits for rural communities. The opportunities for delivering multibenefits within this landscape are significant. For example, creating new wetlands in the farmed landscape can reduce diffuse pollution in rivers and streams, thereby protecting drinking water supplies, and can also provide biodiversity benefits and enhance the cultural value of the landscape. Hedgerows provide shelter for livestock, protect soils from wind impacts, provide ‘wild food’, provide shelter and nesting habitats for birds, small mammals and invertebrates and act as highways that link bat roosting sites to their feeding areas.

· The market place rewards farmers and land managers for some goods and services and there may be the potential for further goods and services to be brought into the market place in the future. For example water consumers and water companies subsidising landowners who work to protect drinking water supplies. However development of effective mechanisms for using markets to pay for some goods and services, such as biodiversity, is fraught with difficulties.

· The Wildlife Trusts therefore believe that a payment to farmers and landowners for delivering specific goods and services is an appropriate use of public money. We support the recommendation made in the UK National Ecosystem Assessment that agriculture needs to ‘better provide ecosystem services other than production [3] . An effective mechanism for implementing such payments would prevent money from the public purse being used to support farming practices that damage the natural environment, such as pollution of watercourses, destruction of semi natural grasslands and draining of valuable wetland habitats. Payments to farmers and land managers need to be conditional on delivery of public goods and services such as clean water, biodiversity, carbon storage and sustainably produced food from farming systems that do not damage the environment and do not compromise the future of sustainable farming.

· The CAP reform process is an opportunity to more effectively link the income that comes to farmers and land managers to measures that will protect and restore the health of ecosystems to benefit all, including farmers and farming systems.

· The Wildlife Trusts believe that radical reform of CAP is needed to establish a more effective system that prevents agricultural practices from damaging the environment, and uses incentives and rewards to help landowners implement appropriate measures to protect and restore the environment. A paradigm shift to a more sustainable and environmental subsidy regime is long overdue.

1.2 Learning the Lessons of Current Practice

· We recognise the benefits that good quality ‘higher-level’ agri-environment schemes delivered under Pillar II have provided in recent years. For example, in the Gowy and Mersey Washlands in England, Cheshire Wildlife Trust is working in partnership with local landowners, businesses and communities to restore, recreate and reconnect a network of wetland habitats providing ecosystem services in conjunction with high quality nature conservation resources of benefit to local people, the environment and economy. With assistance from a wide range of agencies and businesses the Trust is undertaking landscape scale wetland creation by working with landowners farming on the rivers’ floodplains. Higher Level Stewardship is an essential component of this scheme. In the Loddon catchment in Hampshire, the Trust has engaged 32 farmers in a project to manage land and undertake river restoration work in order to reverse the damage caused by diffuse pollution from agriculture. Once again, agri-environment schemes and the guidance and support provided to the farmers by the Trust are a real incentive to farmer engagement. It is essential that budgets for effective agri-environment schemes are protected and enhanced, and that where needed, improvements to current schemes are made. For example, there is a need to consider the most effective ways of developing a co-operative approach across several landholdings.

· We recognise that the current Single Payment Scheme (SPS) can help wildlife rich farms to survive and enable them to continue to conserve the natural environment and the goods and services it provides. For example, a report into High Nature Value Farms (HNVF) in the South Devon AONB [4] reported that farm business profitability for many HNVF in the area is relatively low and dependent on SPS income. Important additional benefits are delivered by these farms with the support of agri-environment schemes.


· We also recognise the significant contribution that voluntary action to improve the farmed environment is making and the personal commitments that many farmers make to the natural environment. For example, we understand that two of the twenty short-listed applications for Natural England’s Nature Improvement Area ‘competition’ [5] are farmer-led. Hampshire and Isle of Wight Wildlife Trust is working in partnership with farmers and the Game and Wildlife Conservation Trust on one of these projects: Hampshire Farmers Linking Landscapes.

· We are concerned that reliance on actions and schemes which are temporary, voluntary and where opting in or out is to a degree dependent on market prices and/or a personal commitment to nature conservation or the environment, introduces a high degree of risk and uncertainty over the longer term. The South Devon AONB study concluded that: ‘ agri-environment schemes are, in some cases, enabling HNVF management only on an artificial, temporary basis which may not be sustainable after the end of an agreement [6] . We believe that longer term appropriate support for such High Nature Value farming systems is essential.

· Without the sustained and focused effort of NGOs such as The Wildlife Trusts and RSPB, who assist farmers in putting together measures and ‘packages’ that maximise the value of subsidies for the environment, the current system would work far less effectively. Reliance on the effort of NGOs, which also depends on funding availability, introduces yet another element of uncertainty and risk that may or may not ensure cost effective delivery of public goods and services into the future.

· Whilst we have seen local scale recovery of species such as farmland birds and mammals when appropriate measures are put in place, scaling up of these achievements to create networks of well-connected habitats and sustainable populations of declining species across the landscape is unlikely to be achieved in the absence of a more strategic and consistent approach. CAP payments should be used to help deliver a targeted and strategic approach; bringing about delivery of specific measures that will significantly extend restoration of the natural environment.

· There is clear evidence that some receiving significant amounts of Single Farm Payment are actually causing damage to the natural environment, whilst other farmers are protecting and enhancing the environment, but currently receive little reward for doing so. This inequitable system is damaging for rural communities and the environment.

· We also believe that the added value that SPS brings to land and the leverage this provides could lead to greater intensification of farming systems.

· It is hard to comprehend that taxpayers money can continue to be used to support farming practices that are damaging to the natural environment and that in the long term may compromise the future of sustainable farming. This situation must be addressed through CAP reform.

· Within the current two-pillar structure of CAP we believe we need a combination of high quality optional agri-environment schemes under Pillar II underpinned by mandatory environmental measures under Pillar I, that together provide a clear roadmap for restoration of the natural environment and sustainable farming and food production.

· However one of the major challenges is to find an effective system of direct payments linked to greening measures that can be applied across the whole of the EU. We believe that further consideration needs to be given to how to build flexibility into mandatory Pillar I greening measures for Member States.

1.3 Assessing the Environmental Benefits of the New Proposals

· Our initial response to the complex CAP reform proposals is one of disappointment and concern.

· The current proposals are unambitious and we also have major concerns about some of the unintended consequences of some of the measures proposed.

· We think that at least at least 30% of direct payments should be contingent on delivery of specific 'green' measures.

· No payment should support unsustainable practice that undermines ecosystem function or biodiversity (which underpins ecosystem services). We do not believe that the current cross compliance system is fit for purpose and think it unable to provide robust protection against damaging activities.

· We believe that the specific greening measures outlined in the proposals for Pillar I do, at least in principle, take reforms in the right direction.

· We feel it is important, at this stage, not to reject the proposals outright because they are not perfect. We believe that a nuanced response that puts forward suggestions for improvement is required at this stage.

· These are complex issues and we would like environmental NGOs to work with farming organisations and Defra to improve the current proposals and ensure that the proposals do not inadvertently cause damage to the natural environment.

1.3.1 Crop Diversification

· This measure requires that where the arable land of the farmer covers more than 3 ha and is not entirely used for grass production (sown or natural), entirely left fallow or entirely cultivated with crops under water for a significant part of the year, cultivation on the arable land shall consist of at least three different crops. None of those three crops shall cover less than 5 % of the arable land and the main one shall not exceed 70 % of the arable land.

· This is a step in the right direction, and increased crop diversity would bring biodiversity benefits, for example providing the potential for farms to provide pollen for insects through most of the year, but we are concerned about a number of unintended consequences.

· Firstly the implication for small mixed farms of the low threshold set for this measure. For example low intensity arable cropping can be an important habitat in High Nature Value Farms in the UK. The crop diversification measure could undermine specific measures for key species that are supported by agri-environment schemes and it may make some who farm small mixed farms give up on arable altogether- which could be seriously damaging for declining bird species and rare plants.

· In addition, rather than reducing the area of main crop, farmers may be tempted to bring other land into production as an additional crop, for example to comprise 5% of their arable land. This could lead to areas of valuable semi natural habitat being lost.

1.3.2 Permanent Grassland

· This greening measure requires farmers to maintain as permanent grassland the areas of their holdings declared as such in claim year 2014. Farmers will be allowed to convert a maximum of 5 % of their reference areas under permanent grassland.

· We appreciate the intention behind this measure, but in practice it is far from fit for purpose and it has the potential to lead to the destruction of valuable semi-natural grasslands.

· A serious issue has arisen in relation to the proposed baseline figure (2014). This must be amended so that the baseline is historic. We have already heard of cases where farmers intend to plough up temporary grassland after four years rather than six or more and we have evidence of grassland on coastal grazing marshes in Lincolnshire being lost in the last few months- potentially these losses could be linked to early action being taken to avoid this measure. Unfortunately the Environmental Impact Assessment Regulations are not effective, but their very existence constrains any other actions to prevent such destruction. We would urge Defra and statutory nature conservation organisations to urgently consider what action can be taken to prevent ploughing of valuable grasslands.

· There is no requirement within this measure to bring areas into better management or to protect semi natural grasslands.

· This measure must be enhanced to specifically protect grasslands that are important for wildlife and it must be revised to avoid inadvertently preventing damage to valuable grassland habitats.

1.3.3 Ecological Focus Areas

· This measure requires that farmers shall ensure that at least 7 % of their eligible ha, excluding areas under permanent grassland, is an ecological focus area such as land left fallow, terraces, landscape features, buffer strips and afforested areas.

· We welcome the concept of Ecological Focus Areas (EFA) and believe that if done well the ‘sparing’ of 7% of a land holding for ecological benefit could be effective. However, this measure must be applied to permanent pasture areas as well as arable farms. The latter could address some of our concerns in 1.3.2.

· The success of the measure would rely on the location of the EFA and the management of the land. If management requirements to deliver specific benefits were introduced to EFAs and if the measure were extended to permanent grassland areas, this could protect and increase habitats such as wildlife-rich grasslands.

· There is huge potential for using this kind of ‘land sparing’ to protect, expand and link areas of value for nature to create ecological networks and restore healthy and fully functioning ecosystems. There is no mechanism within the proposed reforms for achieving this and the risk is that we end up with a scattering of disconnected fragments of land for nature, scattered across the landscape. We would like to see a strategic approach to EFAs across the landscape.

· We would like to see consideration of a greater range of options for creating EFAs, which would also link to current agri-environment schemes.

2. Coherence with Agri-environment Schemes

· Coherence of Pillar I greening measures with agri-environment schemes is essential. Though this has not been made explicit we believe that the land in agri-environment schemes will able to be included in EFAs. Further clarity is required but if a farmer has say 6.5% of land in agri-environment schemes, we believe it is unreasonable to require a further 7% of land to be taken out of production.

· If a farmer already in agri- environment schemes was required to take 7% of ‘new’ land out of production this could lead to cultivation of land that is already being managed in an environmentally friendly way

· We do not believe that the allocation of 25% of the rural development budget for land management and the fight against climate change is anything like enough to deliver both environmental and climate objectives, or to deliver a key priority of the Rural Development Regulation: ‘Restoring, preserving and enhancing ecosystems’ . In this respect a scenario where effective greening measures attached to the direct payments of Pillar I, supplemented by rural development measures that enable ‘deeper’ greening (i.e. agri-environment schemes delivering significant benefits), could kick start the kind of more extensive restoration of the natural environment on which the long term future of farming and wildlife depends. But the uncertainties attached to the relationship between the greening measures and agri-environment schemes, to the future of agri-environment schemes and their final funding levels; as well as the apparent flaws of the proposed greening measures, introduce a huge element of doubt as to just how effective the combined measures of the two Pillars are going to be.

· We are concerned that, as discussions proceed on the compatibility of greening measures and agri-environment schemes, plans to exercise the facility to move money from Pillar II to Pillar I (reverse modulation) could be developed by Member States and could lead to a reduction of budgets for Rural Development.

3. Consistency of Greening Proposals with CAP Simplification Agenda

· We find it difficult to comment fully on this matter at this stage as we understand that the detail of the greening proposals will be set out in the implementation regulations. However, the fact that unintended consequences could arise from the measures and the current uncertainties that surround some of the measures, suggests there is much work to be done to enhance the clarity and refine the practicalities of the greening measures.

4. The ‘Active Farmer’ Definition

· The ruling states that no direct payments will be granted to natural or legal persons, or to groups of natural or legal persons, where one of the following applies:

o the annual amount of direct payments is less than 5 % of the total receipts they obtained from non-agricultural activities in the most recent fiscal year; or

o their agricultural areas are mainly areas naturally kept in a state suitable for grazing or cultivation and they do not carry out on those areas the minimum activity established by Member States in accordance with Article 4(1)(c)

· When considering the impact of this rule it is important to remember that CAP payments are not directly linked to food production and that there is increasing recognition that taxpayers’ money distributed via the CAP should be used to deliver land management that protects and enhances a range of goods and services in a cost effective way.

· Taken together, The Wildlife Trusts manage 2,300 nature reserves covering more than 90,000 hectares of land. We manage this land in ways that provide a range of public goods and services relating for example to biodiversity, recreation, social and cultural values, water quality, food production and carbon storage. The land that we own and manage is a key part of the agricultural landscape and our land is often well integrated with neighbouring farms and landholdings in Living Landscape Schemes. We use livestock to manage our land and ‘conservation grazing’ with rare breeds is an important management tool for many Trusts.

· Some of our nature reserves are working farms. For example Radnorshire Wildlife Trust own and manage Gilfach, a 410 acre hill farm nature reserve north of Rhayader. The farm is a mosaic of habitats including traditional hay meadows, rhos pasture, wet flushes, hill-side scrub and oak woodland. It supports a nature discovery centre visitor centre and Radnorshire Wildlife Trust organises public events at Gilfach every year. This traditional Radnorshire hill farm has remained unimproved since the 1960's. The Trust purchased the farm in 1988 and with support from volunteers, renovated the longhouse and barn; restored ancient field boundaries and developed a management plan that put wildlife at its heart.  The farm is registered as an organic holding and has been entered in the Tir Gofal agri-environment scheme and the Better Woodlands for Wales scheme. A local farmer works in partnership with the Trust to manage the land for conservation, grazing it using traditional breeds like Welsh black cows and local Welsh mountain-cross sheep. The reserve is an SSSI and falls within a Special Protection Area (SPA) for birds. It is a particularly important site for ancient grassland species, waxcap fungi and lichen species.

· Each Wildlife Trust operates as a separate organisation and registered charity, but our preliminary investigations suggest that the active farmer definition will significantly impact on the way in which The Wildlife Trusts are able to manage land in the future. We expect that the majority of individual Trusts will not meet the criteria for ‘active farmer’. One Trust has commented: ‘This would have a severe, if not catastrophic, impact on the management of our land’.

· We are not clear whether the intention would be to restrict access to agri-environment schemes to ‘active farmers’ only. If that was the case the implications for our land management would be even worse.

· We believe that this rule will be totally unworkable. For organisations like The Wildlife Trusts, income naturally fluctuates year by year. For example a Trust could qualify as an active farmer one year and then in the next year receive a significant legacy that would boost receipts, meaning they would not then qualify.

· We believe that many farmers and land managers who are delivering valuable and multi benefits, whilst at the same time diversifying to increase farm incomes, will fall foul of this rule. It is absolutely paramount that this ill thought out rule does not get taken forward in the final regulations.


November 2011

[1] Lawton, J.H. et al (2010) Making Space for Nature: a review of England’s wildlife sites and ecological network .  

[2] HM Government (2011), The Natural Choice: securing the value of nature

[3] UK National Ecosystem Assessment (2011), The UK National Ecosystem Assessment p199

[4] Cumulus Consultants (2011) High Nature Value Farmland in Rural Development Policy . South Devon Case Study. Report for the European Forum on Nature Conservation and Pastoralism . Issue 2.00. Report CC-P-504.2


[6] Cumulus Consultants (2011) High Nature Value Farmland in Rural Development Policy . South Devon Case Study. Report for the European Forum on Nature Conservation and Pastoralism . Issue 2.00. Report CC-P-504.2

Prepared 30th November 2011