Greening the Common Agricultural Policy - Environment, Food and Rural Affairs Committee Contents

3  Improving the Commission's proposals

Crop diversification

46.  The Commission proposes that European farmers must have three different crops on their arable land if that land covers more than three hectares and is not entirely used for grass production, left fallow or entirely cultivated with crops under water. Each of the three crops would have to cover at least 5% of the arable land and none of the crops would be able to cover more than 70% of the arable land. The draft Regulations do not provide a definition of a crop or the period over which the measure will be assessed.[116]

47.  Growing a variety of crops in a particular location over time is a well-understood management practice that can bring about environmental and agronomic benefits. However, while there is good evidence of environmental benefits from crop rotation, there is limited evidence of crop diversity delivering similar benefits.[117] Indeed the Commission had intended to include crop rotation as one of the 'greening' measures but had decided that it could not be delivered under Pillar 1.[118] The IEEP considered that the proposal might bring "modest" environmental benefits "particularly if it encourages greater rotation of crops".[119]

48.  Research by the AHDB found that the crop diversity measure would have a negative impact on "30% to 66.5% of farms depending upon location", with small farms being disproportionately affected.[120] Our farming witnesses pointed out a catalogue of detrimental and perverse impacts of the proposal.[121] Mr Cotterall noted that the proposal would lead to farmers growing for subsidy rather than for the market.[122] Mr Kendall explained that dairy and livestock farmers who grow fodder and cereal crops to supplement grass diets would be discouraged from growing anything other than grass on their arable land—leading to a loss of biodiversity and increased reliance on purchased proteins.[123] He described the measure as a "sledgehammer to crack a nut", which was designed to tackle the "one or two small isolated parts of Europe [where] they have monoculture".[124]

49.  The RSPB and Wildlife Trusts also noted that, while having the potential to deliver some environmental benefits, the Commission's proposal was likely to have unintended or perverse consequences.[125] Geoff Radley, Land Management Head of Profession, Natural England described the Commission's proposal as a "very blunt instrument for something that is really quite a complex problem".[126]

50.  The Commission has the laudable aim of tackling the problem of extensive monocultures found in some areas of the European Union. The proposed crop diversity measure is a compromise and would have little environmental benefit in the UK, which already has a relatively diverse farming system and where most farmers practice crop rotation. The proposal has not been designed to enable local specificity and places process over outcomes.

51.  The Commission's crop diversification measure may have environmental benefits in some areas of some Member States. However, in the UK, the measure will have perverse consequences and will be considerably less environmentally beneficial than crop rotation. The measure will deliver minimal environmental benefits to the UK while placing substantial costs on UK farmers and administrators, as well as risking distorting the market for produce. We recommend that Defra seek to remove this measure from the Regulations.

52.  If the measure remains in the Regulations, we recommend that Defra consult with the industry and other stakeholders to determine the appropriate definitions that give the most flexibility to farmers and communicate the outcome of that consultation to the Commission. It is critical that the Commission provides more details about how the measure will be defined, particularly in relation to the definition of a crop, prior to the Regulations being adopted. We further recommend that, Defra press the Commission to amend the Regulations so that only very large farms will have to meet the crop diversification requirement.

Retention of Permanent Pasture

53.  The Commission propose changing the permanent pasture rules, which currently apply at Member State or Regional level, so that farmers will be prevented from converting land used for permanent pasture "declared as such in the application for direct payments made in the claim year 2014".[127] The Grasslands Trust explained that of the 3.66 million hectares of England's grassland classified as permanent pasture; most is 'improved' grassland of low wildlife value; some 1.45 million ha is 'semi-improved' of greater environmental value; and around 100,000 ha (2% of the total resource) is 'unimproved semi-natural', which has the highest environmental value and is identified as Habitat of Principal Importance in Section 41 of the Natural Environment and Rural Communities Act 2006.[128]

54.  The Commission's permanent pasture proposals have caused widespread concern that, depending on how they are finally defined, they would have unintended and perverse consequences in the UK.[129] The draft Regulations make no distinction between less environmentally-valuable pasture which is cultivated or reseeded and high nature value unimproved semi-natural grasslands, which support biodiversity and generate significant ecosystem services such as carbon storage, flood protection and cultural landscapes.[130] According to Defra the current draft Regulation's failure to differentiate between higher and lower environmental value pasture "undermines, if not negates, many of the [proposal's] potential benefits".[131] Many organisations argued that these environmentally and socially valuable grasslands should be clearly defined and protected within the CAP.[132]

55.  Setting 2014 as the baseline for the Permanent Grassland measure provides a powerful incentive for farmers to plough up permanent grassland in the interim, leading to significant ecological damage.[133] Our farming witnesses confirmed that farmers would be concerned about the lack of flexibility in how they manage their land and that that lack of flexibility would reduce the value of the land.[134] The requirement to retain permanent pasture is likely to have unintended and perverse consequences. The Regulations will not target protection at areas that provide the most environmental benefit and are inconsistent with allowing farmers to respond to market signals.

56.  We recommend that Defra press the Commission to adopt a definition of permanent pasture that takes account of the differences in environmental value of improved and semi-improved pasture versus semi-natural grassland. Defra should argue that the Regulations protect semi-natural grassland while providing farmers with flexibility over the management of lower environmental value pastures.

57.  The Grasslands Trust highlighted the lack of protection for valuable semi-natural pasture and recommended the creation of an inventory of England's valuable grasslands. The Trust argued that an inventory would enable conservation, protection and management mechanisms to be applied more effectively.[135] We recommend that Defra urge the Commission to make funding available to Member States to map their semi-natural grasslands, which would inform policies such as monitoring biodiversity, planning decisions and deployment of agri-environment schemes. We further recommend that Defra commission a comprehensive grassland inventory for England.

Ecological Focus Areas

58.  The Commission's Ecological Focus Area (EFA) proposal would require farmers to ensure that at least 7% of their eligible hectares, excluding areas under permanent grassland, is "land left fallow, terraces, landscape features, buffer strips and afforested areas".[136] As with the two other requirements under these proposals the precise definitions are to be left to the Commission to decide under delegated acts.

59.  Of the three proposed mandatory 'greening' proposals, EFA's have the greatest potential to deliver significant environmental benefits, but that potential depends on how the measure is defined and implemented.[137] Defra considered that that the benefits of EFAs would depend on the final percentage requirement, the targeting of areas and features eligible to contribute to the measure.[138] The department argued that Member States should have the discretion to "ensure the measure could be applied in ways appropriate to specific national circumstances and environmental priorities".[139] The IEEP recognised the limitations of the EFA proposals and noted that the benefits would be increased significantly by greater targeting and tailoring of the management practices through tying the measure in to the more sophisticated management options supported by agri-environment schemes.[140]

60.  The Commission has set the percentage of land given over to EFAs set at 7%. Unsurprisingly, environmental bodies considered this figure low while the farming organisations considered it too high.[141] We were told that the figure appeared arbitrary, with Professor Benton commenting that he did not know where 7% came from and that it was "not evidence-based in the way we would like to see".[142] Professor Godfray described a "straight, formulaic 7%" as an "incredibly inefficient way" of approaching the issue, which he thought would deliver poor environmental results.[143]. He told us:

...I would like to see more modularity—more capability for different countries to maximise the environmental benefits that the same amount of funding could produce. I think it would be a shame, just talking about biodiversity as a subset of the environmental goods, if 7% of high-productivity land was taken out of agriculture for some pretty poor biodiversity return, and you then ploughed up whatever in a wonderful, biodiverse, rich, ancient meadow in the Scottish islands just to keep that farm-level percentage.[144]

61.  The Secretary of State told us that Defra was arguing for a wider definition of the features included under the measure and for Member States to have greater flexibility in determining which features should be included in EFAs.[145] Since we concluded taking evidence a number of suggested changes to the EFA measure have been put forward. At the May Agriculture and Fisheries Council most Member States were in favour of a more flexible approach to the measure, the inclusion of a minimum farm size and that areas managed under appropriate agri-environment schemes should be taken into account.[146]

62.  The EU's Committee of the Regions recommended a more regionalised 'greening' approach under which the EFA requirement could be achieved by farms grouping together and collectively reaching the 7% target.[147] It is not clear to us why the EFA measure be imposed at the individual farm-level.[148] If Member States accepted 7% EFA as a national level commitment it would allow areas that are good for food production to be kept for food production, while areas that are good for biodiversity could be kept for biodiversity. Professor Godfray pointed out that the UK's National Ecosystem Assessment (NEA), published on 2 June 2011, provides a starting point for how such an approach might work.[149] The NEA provides a comprehensive overview of the state of the natural environment in the UK and a new way of estimating national wealth taking into account the value of natural capital. The NEA assessed the state of the UK natural environment in 8 broad categories of habitat and looked at the ecosystem services, including 'provisioning services (crops etc) these habitats provide.

63.  We note the lack of evidence to support the Commission's proposal for 7% of land to be given over as an Ecological Focus Area. We recommend that the Commission set out the basis for, and evidence supporting, the 7% figure. We are far from convinced that applying a formulaic percentage of area at farm-level is the most effective or efficient method of delivering the Commission's environmental objectives.

64.  The proposed Regulation includes some examples of the types of land that could count towards EFAs, but a comprehensive list will be defined only in delegated acts.[150] This lack of clarity has caused concern amongst farming and environmental organisations.[151] The RSPB emphasised that the "landscape features or land types allowed to count towards the EFA requirement will have significant bearing on its ability to deliver for the environment".[152] Both the RSPB and NFU argued that landscape managed under appropriate agri-environment schemes should be counted towards EFAs.[153] Professor Benton told us that whatever the final figure ended up being it should include areas that are currently non-cropped. He said the average English farm already has about 4% non cropped land which it is not profitable or practical for farmers to cultivate.[154] Natural England considered that the current form of the EFA proposals did not make "the most efficient use of available land", or minimise the impact on food production.[155]

65.  There is insufficient detail in the Commission's draft Ecological Focus Area proposal to assess whether it will deliver the desired environmental benefits. We do not believe that the UK Government should agree to these measures in the absence of those details. We recommend that Defra ensure that the Regulations include a definition of the landscape features that will count towards an EFA. We further recommend that such a definition should include landscapes or areas managed under appropriate agri-environment schemes.

66.  Professor Benton told us that the landscape features should be physically connected to derive the most environmental benefit.[156] The Government's Natural Environment White Paper (NEWP) acknowledges and promotes the environmental and ecological benefits of a network of semi-natural areas inter-connected by habitat corridors. The Wildlife Trusts highlighted the value of linked areas of ecological networks, but noted that the EFA proposals contained no mechanism for achieving this.[157] They concluded that "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".[158] Mr Gerrard referred to the conclusions in the NEWP and said that farmers would be instrumental to delivering that network. [159] The Commission's current EFA proposals will not deliver such a network but rather create a fragmented landscape incapable of delivering the potential environmental benefits. We recommend that the Commission consider how Member States might implement EFAs in such a way that would enhance environmental interconnectivity. We recommend that Defra explore how projects and funding streams allocated to the implementation of the Natural Environment White Paper might be integrated with Commission's EFA measures to deliver ecological networks across the country.

67.  Natural England have confirmed that, if the 'greening' measures go ahead, agri-environment schemes may change to take into account the activities that are already being paid for under mandatory 'greening'. The impact of EFAs will be enhanced if agri-environment schemes include management measures that specifically encourage farmers to manage those areas of their farms for environmental benefits.[160] Geoff Radley, Land Management head of Profession at Natural England, told us that some of the activities that "cram the most benefit into the smallest area are those that require the most active management", such as sowing pollen and nectar mixes.[161] We recommend that future agri-environment schemes should include measures to incentivise farmers to manage their EFAs for biodiversity and other environmental benefits, for example through sowing pollen and nectar seed mixes or through locating their EFAs so as to create a coherent network.

68.  The Tenant Farmers Association (TFA) expressed additional concerns about the definition of the land included in EFA. Mr Dunn noted that tenants pay for every acre they rent and that that land will usually be limited to productive land. A tenant subject to the EFA measure might have to take 7% of productive land out of production if they did not have any other landscape features on the farm, and have to pay rent on that 7% of their holding. We see the logic behind the TFA's argument. We recommend that Defra make the argument to the Commission that tenant farmers should only be required to comply with the EFA measure in relation to any non-productive land within their holding.

69.  We are conscious that tenant farmers are unique to UK agriculture and the impact of CAP reform on this group should not be overlooked by the Commission or Defra.[162] In our Farming in the Uplands report we concluded that tenants and commoners might be disadvantaged in accessing agri-environment schemes.[163] Defra has committed to a monitoring and evaluation programme to provide evidence of "both the environmental benefits and the impacts for different groups of upland farmers".[164] If Defra identifies difficulties for tenant farmers or commoners in accessing agri-environment schemes we would expect the department to respond positively and identify solutions so that those farming groups are not disadvantaged.

70.  Although this report is focussed on the Commission's 'greening' proposals it is worth noting tenant farmers' concerns about some of the Commission's other reform proposals. The TFA has expressed concerns that tenant farmers would be disadvantaged by the Commission's proposed entitlement system. The Commission proposes that only people who made a valid claim on at least one hectare of land in 2011 under the existing Single Payment Scheme would be eligible for direct payment entitlements under the new regime.[165] The TFA argue that some landlords may "capitalise inappropriately" on the changes by bringing existing tenancies to an end in order to 'bank' land ahead of introduction of the new regime. The CLA has said that it is not aware of any landowners banking entitlements or considering doing so.[166]

71.   The TFA also had concerns about the Commission's 'active farmer' proposals. The Association commended the Commission's desire to ensure that only active farmers would be eligible to receive entitlements and direct payments but were concerned that the current proposals were not, as yet, a workable solution.[167] The 'active farmer' definition was also criticised by the Wildlife Trusts as being unworkable and potentially "catastrophic" for the management of their land.[168] The TFA argued that the Commission should be excluding those individuals who cannot demonstrate that it is they in particular who are carrying out the eligible activities on the land upon which they are basing their claims. In order to qualify for payments an individual would have to be "in practical occupation of the land being used for making the claim, [...] in close management control of the activities on that land and bearing the entrepreneurial risk from those activities".[169] While the CLA agreed that Commission's 'active farmer' proposals would not work, they did not believe that the existing definitions had caused any significant problems or needed to be changed.[170] We recommend that Defra emphasise to the Commission the important role of tenant farmers in UK agriculture and ensure that any negative outcomes from this round of CAP reform do not disproportionately affect them.

Agri-environmental schemes

72.  There is substantial evidence that multiannual, voluntary and targeted agri-environment schemes are the most effective CAP measure for delivering environmental benefits.[171] Although, the European Court of Auditors found that, across the EU, schemes too frequently lacked clear objectives and failed to deliver tangible environmental benefits.[172] The UK is recognised as being at the forefront in developing and delivering these schemes.[173] For example, the Secretary of State told us that:

It is recognised by the Commission that the UK is out there more or less in a league of its own, particularly with higher level stewardship schemes, which make very strong demands on farmers to address very real needs for biodiversity.[174]

73.  Farming organisations were concerned that not only would the requirements of 'greening' overlap with agri-environment schemes but also that farmers' efforts under those schemes would not be recognised as contributing to the 'greening' measures. They emphasised the importance of the schemes remaining voluntary and separate from direct payments.[175]According to the CLA, entry-level stewardship was "overwhelmingly" equivalent to the Commission's mandatory 'greening':

… we have annexed a list of the 67 options in England's Entry Level Stewardship scheme which currently has two-thirds of English farm land enrolled. We asked which of these options a reasonable observer would score as "agricultural practices beneficial to the climate and the environment'. Our suggested scoring is that all 67 actions satisfy this. These actions are all deemed by Defra, and approved by the Commission, to be beyond cross compliance. All farmers accepted into ELS must have accumulated sufficient such 'agricultural practices'.[176]

74.  There was some sympathy for this position among the environmental organisations. Mr Gerrard considered it appropriate for areas of land that qualify for the EFA that were already in agri-environment schemes to overlap with 'greening' payments—he told us "essentially the Pillar 1 payment is paying for the existence of the feature, or possibly the creation of the feature, with agri­environment paying for the proper, appropriate management of those features".[177] Jenna Hegarty, Agricultural Policy Officer at the RSPB did not consider being an agri-environment scheme should be a "free pass for greening" but thought that membership of such schemes should count towards the 'greening' requirement as long as the management practices were appropriate and suitable for EFAs.[178]

75.  Defra has suggested several methods of making 'greening' coherent with agri-environment schemes, including

  • receipt of greening in Pillar 1 could be made conditional on participation in entry-level type agri-environmental schemes (under Pillar 2); or
  • some form of entry-level environment scheme membership in Pillar 2 could be considered sufficient condition for receipt of 'greening' payments effectively providing a derogation from the 'greening' requirements; or
  • Member States could be given significantly greater flexibility to design stringent 'greening' requirements that suit their own conditions and avoid unnecessary burdens of farms.

The department noted that each of these alternatives have disadvantages and "vary as to the additional environmental benefit they bring to the CAP, the potential legal constraints they face, and the value for money they represent".[179] The CLA also suggested a range of options for making agri-environmental schemes coherent with mandatory 'greening' through Pillar 1. The Association noted that if all farms in the Entry Level Scheme were automatically eligible for mandatory 'greening' then it would be necessary to ensure that agri-environment schemes across all Member States were equally and sufficiently rigorous.[180]

76.  The Commission appear to have listened to the arguments: Commissioner Ciolos told the National Farmers Union annual conference that he "recognised that many farmers in the UK were already meeting some, and in some cases more, of the greening' requirements".[181] He added that:

We will find the appropriate ways to recognise efforts made under your agro-environmental schemes where they genuinely contribute to greening, while not removing the incentives to do more or better in the second pillar.[182]

The Commission subsequently published a paper that would, subject to certain conditions, allow a farmer in an agri-environment scheme or subject to an environmental certification scheme to be considered to have fulfilled at least one of the 'greening' measures.[183]

77.  The United Kingdom's agri-environment schemes are among the best in Europe at delivering meaningful environmental benefits. We are concerned that the Commission's 'greening' proposals will have a chilling effect on the UK's existing, successful, agri-environment schemes. This round of CAP reform should do nothing that would diminish those schemes effectiveness or extent. We conclude that the Commission's initial proposals failed to recognise the benefits accrued by the UK's existing schemes and as a result would disadvantage farmers that participated in such schemes.

78.  We welcome recent moves by the Commission to enable participation in an agri-environmental scheme to be taken into account when assessing a farmer's obligations under the 'greening' proposals. However, those amendments to the Regulations are yet to be agreed. We therefore recommend that Defra continue to make the case in Europe that membership of an approved agri-environment scheme should be included as an alternative measure under 'greening', so that farmers can choose whether to carry out the three 'greening' measures or join an approved agri-environment scheme in order to receive their 'greening' payment.

79.  Entry Level Stewardship (ELS) schemes are legal contracts between the farmer and Natural England. Under the current ELS scheme rules, agreements last five years. Farmers are penalised financially for leaving a scheme early or otherwise breaking the terms of their agreement. The penalties include withholding future payments and recovering payments already made. It is not clear whether as a result of CAP reform farmers would be able to exit agri-environment schemes without facing a penalty. The farming organisations argued that the overlap between the 'greening' proposals and agri-environment schemes would lead to the re-design of current agri-environment schemes and amendment of payment rates.[184] The impact of those changes could lead to farmers deciding to leave schemes. The NFU argued that in such circumstances farmers should not be penalised. [185] The Central Association of Agricultural Valuers (CAAV) said that the lack of clarity around the recognition of agri-environment schemes was already disrupting renewals of agri-environment schemes.[186]

80.  Mr Dondi confirmed that 'greening' was likely to require adjustments to agri-environment schemes so that activities added under Pillar 1 were removed from Pillar 2 schemes.[187] He explained that different measures might be added to agri-environment schemes to balance those measures taken away, or the points threshold for a given scheme could be lowered.[188] Defra has responded to the farming communities concerns and "pledged" that farmers "thinking about entering or renewing agri-environment agreements could choose to opt out without penalty if they had to make changes to their  agreements as a result of CAP 'greening'".[189] We seek assurances from Defra that farmers currently in agri-environment schemes will receive no penalty for leaving schemes should either the design of or payments under those schemes alter as a result of 'greening'. We seek Defra's assurances that farmers who leave their agri-environment scheme contract due to changes resulting from the implementation of 'greening' can do so without penalty or requirement to repay money at any point between now and either the implementation of the post-2013 CAP or the publication of the conditions for the post-2013 agri-environment schemes, whichever is later.

Defra's points system and recent developments

81.  The department has proposed to the Commission an alternative to 'greening' that would give Member States greater flexibility of approach and that would recognise the variation in environmental and agricultural circumstances across Europe. The Secretary of State explained that the department's 'points' system would enable some level of equivalence to be determined between environmental measures in different Member States:

Instead of a rigid one-size-fits-all approach, where everybody is forced to do the same thing with some terrible unintended consequences as a result, a good way forward would be to look at some sort of a menu that had flexibility and equivalence to guarantee to the taxpayer that they were providing the money and it was providing good value for that money, but also scientifically we were genuinely making a difference for the environment.[190]

82.  Mr Arik Dondi, Deputy Director, Environmental land Management at Defra, described how "one might create a menu of broadly equivalent measures from which member states could then pick and mix, more or less".[191] Martin Nesbit Director, EU, International and Evidence Base at Defra told us that:

...flexibility is something that is increasingly becoming of interest to member states. There will be some member states who see flexibility as an opportunity to remove the environmental substance from the proposals, and others who are genuinely interested in achieving progress. We will need to ensure that we get as much equivalence as possible in the negotiations.[192]

He thought it was unlikely that there would be time for the UK to involve Member States' Chief Scientists in drawing up the points system. He considered the Commission would be the only institution with the "convening power" to enable that to happen. Mr Nesbit added that the European Parliament might wish to look at the proposal, saying "Interestingly, flexibility for member states was a subject that was unusually something that MEPs seemed to be willing to contemplate and to see as a potential solution to these negotiations".[193]

83.  The Government may find that there is an appetite in the European Parliament to significantly amend the draft Regulations. Paolo de Castro, chairman of the European Parliament's agriculture committee told the NFU annual conference that changes to the proposals were needed and he suggested a more flexible approach under which farmers could select from a menu of environmental options in return for direct payments.[194]

84.  There is also support for greater flexibility among Member States. The UK is part of the 'Stockholm Group', which includes Germany, the Netherlands and Scandinavian Member States.[195] A paper by the group proposed a menu of options that would enable farmers to deliver 'greening' through measures tailored to the local environmental circumstances and farming systems. 'Greening by definition' was included in the proposals, under which farmers in Entry Level Stewardship schemes would be exempt from elements of 'greening'.[196] There is evidence of a growing desire among Member States to inject flexibility with the one-size-fits-all approach causing particular concern.[197] The Commissioner has made some concessions on his proposals, but he insists that 'greening' in Pillar 1 is 'not negotiable'.[198] He is yet to be persuaded to adopt the more flexible approach advocated by the UK and its allies.[199]

85.  We are surprised that Defra decided to introduce its idea for a points system at too late a stage in the process to enable the critical scientific assessment of the proposal across the European Union to be conducted. We consider it unlikely that the UK's points system will be embraced by Member States or the European Parliament. On the other hand we welcome the apparent openness of several Member States and some in the European Parliament to a more flexible approach to 'greening'. We urge Defra to redouble its efforts to explain to all parties to the negotiations the diverse benefits greater flexibility and local tailoring would provide.

116   Ev w11ff; Q 189 Back

117   Ev 96, 82; Qq 92, 127 Back

118   Qq 91, 188 [Mr Nesbit], Ev 82, 99-100 Back

119   Ev w53 Back

120   Ev 71 Back

121   Qq 15-16; See Ev 71ff, Ev w11ff Back

122   Q 15 [Mr Cotterall] Back

123   Ev 71 Back

124   Q 15 Back

125   Ev 82, 87; Q 106 Back

126   Q 92 Back

127   Proposal for a Regulation of the European Parliament and of the Council on establishing rules for direct payments to farmers under support schemes within the framework of the common agricultural policy, COM(2011) 625 final/2, Article 31(1)  Back

128   Ev w49ff Back

129   Q 46, Ev 81, 82, 100; See Q 90 [Mr Radley], Qq 185-186 [Ms Spelman] Back

130   Ev w15-16; see UK National Ecosystem Assessment (2011) The UK National Ecosystem Assessment: Technical Report. UNEP-WCMC, Cambridge. Chapter 6: Seminatural Grasslands; Article 4 (h), COM(2011) 625/3 Back

131   Ev 100 Back

132   Ev 82, 88, 96, Evw49-50; Ev w15-16 Back

133   Q 30 [Mr Kendall], Ev w6, w11, w49, w53 Back

134   Q 29 [Mr Kendall] Back

135   Ev w50; See "Defra urges farmers not to plough up grassland" Farmers Guardian, 13 May 2012 Back

136   Proposal for a Regulation of the European Parliament and of the Council on establishing rules for direct payments to farmers under support schemes within the framework of the common agricultural policy, COM(2011) 625 final/2 Back

137   Ev 80, 88, 92, 100 Back

138   Ev100 Back

139   Ev 100 Back

140   Ev w51ff Back

141   Ev 80, 71, Q 107, Q 10 [Mr Cotterell, Mr Kendall] Back

142   Q 58 Back

143   Q 121 Back

144   Q 121 Back

145   Qq 224-225 Back

146   Press Release, 3165th Council Meeting Agriculture and Fisheries, 14-15 May, Presse 194, PR CO27 Back

147   "Regions committee calls for greater CAP redistribution and regionalised 'greening'" Agra Europe, 15 May 2012 Back

148   See Q 41 Back

149   Q 136 Back

150   Ev w52 Back

151   Q 22 [Mr Cotterell] Back

152   Ev 80 Back

153   Ev71, 80 Back

154   Q 44 Back

155   Ev 95 Back

156   Ev 92; Q 41 Back

157   Ev 88 Back

158   Ev 88 Back

159   Q 97 [Mr Gerrard] Back

160   Q 57 Back

161   Q 71 Back

162   See Qq 34-36 Back

163   Environment, Food and Rural Affairs Committee, Third Report of Session 2010-11, Farming in the Uplands HC 556, para 55; Q 73 Back

164   Environment, Food and Rural Affairs Committee, Fourth Special Report of Session 20-12, Farming in the Uplands: Government response to the Committee's Third Report of Session 2010-11, HC 953, page 8 Back

165   "TFA voices entitlement fears linked to CAP" Farmers Guardian 6 April 2012 Back

166   Ibid. Back

167   Q 32, Ev 51, "UK tenant farmers seek CAP changes" Agra Europe, 24 April 2012 Back

168   Ev 89 Back

169   Ev 51 Back

170   Q 33 Back

171   Ev w50; Q 10 [Mr Cotterell]; Qq 68-71, 74 Back

172   European Court of Auditors, Is agri-environment support well designed and managed?, Special Report No 7 2011 Back

173   Ev 95, 99, Q 74; See European Court of Auditors, Is agri-environment support well designed and managed?, Special Report No 7 2011. Some 68% of English farmland is already in stewardship, with a further 192,231 ha in voluntary environmental management. Back

174   Q 196 Back

175   Q10 [Mr Cotterell], Q 25 [Mr Kendell], Q27 [Mr Kendell] Back

176   Ev 59, Q 24 Back

177   Q 102 [Mr Gerrard] Back

178   Q 102 [Ms Hegarty] Back

179   Ev 101 Back

180   Ev 59 Back

181   "Accountability and the consumer must drive CAP", Agra Europe, 16 January 2012 Back

182   Ibid. Back

183   "Commission gives ground on CAP greening plans" Farmers Guardian, 14 May 2012; "Stewardship to exempt farmers from 'greening'?" Farmers Weekly, 15 May 2012; "Regions committee calls for greater CAP redistribution and regionalised 'greening'" Agra Europe, 15 May 2012 Back

184   Ev 100-101; Ev w11, w54 Back

185   Ev 68 Back

186   Ev w11 Back

187   Q 77 [Mr Dondi] Back

188   Ibid. Back

189   "Views sought on CAP reform" Defra press release, 12 December 2011 Back

190   Q 170 Back

191   Q 175 Back

192   Q 172 [Mr Nesbit] Back

193   Q 172 [Mr Nesbit] Back

194   "Changes ahead for CAP reform proposals" Farmers Weekly, 24 February 2012 Back

195   "Alternative to EU's greening measures" Farmers Guardian, 4 May 2012 Back

196   "Paice urges Ciolos to go further on CAP greening concessions" Farmers Guardian ,15 May 2012 Back

197   Press Release, 3165th Council Meeting Agriculture and Fisheries, 14-15 May, Presse 194, PR CO27 Back

198   "Regions committee calls for greater CAP redistribution and regionalised 'greening'" Agra Europe, 15 May 2012 Back

199   "Concessions from Ciolos but he needs to go further" Farmers Guardian, 18 May 2012; "More flexible 'greening' measures with menu options gain support" Agra Europe, 1 May 2012 Back

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