Greening the Common Agricultural Policy

3. We are concerned about the implications of these changes: far from providing any environmental benefit, there is a risk they will lead to environmental damage.

4. Landowners who wish to retain the flexibility to convert land from permanent pasture to other land-uses may well feel they have to plough up permanent pasture and sow an arable crop before the reference year of 2014.

5. Grasslands currently in "classic" Agri-environment Schemes such as Countryside Stewardship Scheme and Environmentally Sensitive Areas are especially vulnerable, where agreements end in the next 3 years, but where that land is not eligible (or through lack of funding) to enter the Higher Level Scheme of Environmental Stewardship. These grasslands have received large sums of Government funding and the risk is that this investment will be lost, as these grasslands which have been managed extensively for sometimes over 20 years, will be returned to intensive agricultural production.

6. Around 5 Million Hectares of England’s agricultural area is grassland [4] - this is half of England’s agricultural land. Most of the 3.66 Million hectares of grassland classified as permanent pasture in England [5] is "improved" grassland, that is agriculturally productive, intensively managed and poor for wildlife and ecosystem services.

7. According to Countryside Survey figures, 1.45Million hectares is "semi-improved" [6] , which means that although the value of that grassland for wildlife and ecosystem services has been reduced as a result of agricultural activities, it still retains some value, compared with "improved" grasslands.

8. Around 100,000ha (2% of the total resource) of that grassland resource is "unimproved semi-natural" [7] , and this is the best surviving grassland, identified as Habitat of Principal Importance in Section 41 of the Natural Environment and Rural Communities Act 2006.

9. The risk is that cultivation driven by this proposed change will affect the resource "semi-improved" and unimproved grassland. Unimproved grassland is partially protected by designation as Site of Special Scientific Interest (SSSI), but Natural England figures show that only just over two-thirds of the unimproved resource falls within SSSI [8] . The remaining third (and for some key grassland types under half the resource is protected in SSSIs) is unprotected from agricultural intensification.

10. The only mechanism available to protect unimproved grasslands from cultivation is the EIA (Agriculture) Regulations and these are almost completely ineffective, to the point where we complained [9] to the European Commission and they are now investigating whether the Government is in breach of the EIA Directive on this issue. We have submitted evidence on this issue to this Committee previously [10] , to the McDonald Taskforce on Farming Regulation, and more recently to a Natural England Consultation on the EIA (Agriculture) Regulations [11] highlighting the various weaknesses in the Regulations and their implementation.

11. While semi-improved grasslands do not have the same wildlife value as the very small surviving resource of unimproved grasslands, they can still support important populations of wildlife and archaeology, they provide critical ecosystem services (water quality, carbon storage) and are integral to important landscapes such as National Parks and Areas of Outstanding Natural Beauty [12] .

An Alternative Approach

12. We believe that the Permanent Pasture rules in place since 2003 have done nothing to protect grasslands valuable for reasons other than intensive agricultural production [13] . We have proposed to the Commission an alternative approach which we believe would help those farmers who have these valuable grasslands to maintain them. We have proposed to the Commission an alternative approach of a Permanent Pasture Premium – an annual which would be available to any farmer with grassland, subject to a set of conditions (equivalent to some agri-environment schemes) including no cultivation or re-seeding and limited fertiliser use. We believe this would work well as an "opt-in" scheme which would be attractive to farmers who are already managing their grasslands extensively, while it would be of no interest to farmers who wish to continue to manage their grasslands intensively, so this self-selection process would target the resource where it is needed. One of the reasons for adopting this approach is that we still do not know where the grasslands valuable "for reasons other than intensive agricultural production" occur.

Inventory

13. England does not have a proper inventory of valuable grasslands. Unlike ancient woodland, which is relatively easy to identify from maps, grasslands are not so easy to identify remotely. For this reason, and also because grasslands have historically been neglected by conservation organisations, the picture of where grasslands occur is patchy and incomplete. The McDonald Taskforce recognised this fact and recommended to Defra that this issue be addressed. We and the RSPB are proposing to Defra that such an inventory is urgently required, so that landowners are aware of the valuable grasslands that occur on their land. This will enable mechanisms such as EIA (Agriculture) and Agri-Environment Schemes to be more effectively applied or targeted.

November 2011