Greening the Common Agricultural Policy

Written evidence submitted by Smiths Gore (GCAP 32)

Response from Smiths Gore. We are one of the UK’s largest firms of rural land managers, managing over 2 million acres of land in England, Scotland and Wales, including responsibility for the direct management of over 120,000 acres of farmland.

Committee questions

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

· We are not convinced that the proposals will generate significant environmental benefits; the PBL Netherlands Environmental Assessment Agency report [1] on the proposals (2011) suggests that the proposals might result in 3% increase in species richness on EU farmland by 2020 compared with no greening of the CAP; this does not mean a gain in biodiversity, more a slowing down of loss but this could be achieved more effectively using other measures.

· The measures are passive – they do not require active management, which is generally more beneficial for wildlife – and may, if land under Environmental Stewardship schemes does not count towards the 7% ecological focus area, have unexpected effects in terms of putting farmers off applying for and renewing agri-environment scheme agreements, which contains the more active management measures

· The crop diversification proposals are unlikely to affect many traditional arable farmers, other than those practising continuous wheat systems or 50:50 wheat: oilseed rape rotations. Livestock farmers growing maize or single arable crops for fodder may be impacted and question whether this was intended.

· The permanent grassland proposal will probably be the most environmentally beneficial [2] . We know that it is already leading to some farmers ploughing up this type of grassland and not intending to establish any more permanent grass. Any benefits from this type of measure are probably already delivered in the UK through the Environmental Impact Regulations that protect permanent grassland

T he impact of additional greening requirements on food production and the competitivene ss of the agricultural industry

· The requirements are likely to reduce it as they will require productive land to be taken out of production [3] . There should be an assessment, at national level, of the benefits of requiring the land to be removed from production if, as is likely, it will not deliver significant biodiversity benefits – so it is a lose – lose scenario.

· A more sensible approach, particularly considering Defra’s policy objectives of sustainable intensification, would be to encourage land to be taken out of production where it can generate environmental benefits, and reward those farmers appropriately. Where land will not generate environmental benefits, the farmers should continue to be expected to comply with agreed standards of good agricultural and environmental management.

· The risk of the proposed approach, which as Dacian Ciolos states is to get a pan-Europe approach to environmental protection, is that farmers will not see any environmental benefits being produced and it will make them less likely to enter into more effective schemes, such as Environmental Stewardship, as they will be less convinced that it can produce benefits. The psychology / messages of the proposals are very important and should not be under estimated

Consistency of the greening proposals with the CAP simplification agenda

· If adopted, the proposals seem simple and could be, in our view, accommodated in the existing IACS

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

· As stated above, this could be a significant issue as the greening proposals could results in farmers not renewing or applying for agri-environment scheme agreements as (i) they will feel that they have taken enough land out of production and (ii) they will not consider that it generates significant environmental benefits

· The simple way of making them coherent is to allow land under Environmental Stewardship to count towards the ecological focus area

Recommendations for improving the greening proposals

· As they stand, the proposals are "green wash". They are very unlikely to generate the environmental benefits wanted and may dissuade farmers from entering into Environmental Stewardship schemes.

· A more effective approach to reducing agriculture’s negative effects on the environment and encouraging more environmentally beneficial behaviour would be:

o To allow Member States to design their own greening proposals so that they can be tailored to the requirements of individual countries

o Use the 30% of direct payments proposed for greening to the Rural Development pillar to increase budgets for agri-environment

24 November 2011

[1] Greening the Common Agricultural Policy: impacts on farmland biodiversity on an EU scale. 2011. ISBN 978-90-78645-70-2

[2] This is supported by the PBL analysis

[3] Again, this statement is supported by the PBL analysis

Prepared 21st December 2011