Memorandum by Wildlife and Countryside
Link
1. Wildlife and Countryside Link (Link)
brings together voluntary organisations concerned with the conservation,
enjoyment and protection of wildlife, countryside and the marine
environment. Our members practice and advocate environmentally
sensitive land management and food production practices and encourage
respect for and enjoyment of natural landscapes and features,
the historic environment and biodiversity. Taken together, our
members have the support of over eight million people in the UK
and manage over 476,000 hectares of land. This submission is supported
by:
— Bat Conservation Trust.
— Buglife—the Invertebrate Conservation
Trust.
— Butterfly Conservation.
— Campaign to Protect Rural England.
— Council for British Archaeology.
— Plantlife International.
— Royal Society for the Prevention
of Cruelty to Animals.
— Royal Society for the Protection
of Birds.
OVERVIEW
Q1. What should be the long term objectives
of the CAP? Does the title "Common Agricultural Policy"
aptly fit your perceived objectives of the policy? What do you
consider to be the main pressures on the CAP as it currently is?
2. Wildlife and Countryside Link (Link)
has led the call for the reform of the Common Agricultural Policy
(CAP) from the 1980s onwards and we welcomed many of the reforms
to the CAP from the Mid Term Review. Since then a debate has begun
on whether the CAP should exist at all and if not how could sustainable
land management be supported. The recent UK Government Vision
for the CAP set out how sustainable land management might
be delivered in a post CAP Europe. However, Link believes the
Government's Vision failed adequately to consider how the delivery
of environmental public goods would be assured as the global agricultural
trading system becomes increasingly liberalised. In addition to
economic pressures creating additional demands on land for food
and bioenergy the demand for provision of environmental public
goods is also increasing.
3. The challenges Link believes the CAP
is facing include:
— Changing land and soil management
practices to tackle the causes of climate change.
— Adapting land to the effects of climate
change.
— Ensuring water quality and quantity
is maintained.
— Creating healthy functioning ecosystems
rich in biodiversity.
— Protecting and conserving the irreplaceable
archaeological resource.
— Conserving and enhancing important
productive landscapes and their character.
— Improving farm animal standards without
leaving European producers at a competitive disadvantage.
— Reconnecting people with the environment
and understanding what it provides for them.
— Producing food, timber and energy
in more sustainable ways.
4. We believe it is time to begin the process
of developing a new policy framework with adequate funding to
create a European Sustainable Land Management Policy in the EU
that will deliver the environmental public benefits and ecosystem
services that society needs. The ending of the CAP will almost
certainly require new terminology. The terms Pillar I and II have
become associated with a variety of preconceptions in terms of
environmental damage, intensive farming, market distortions and
agricultural purpose. We should seek to develop a single funding
and policy instrument that will enable farmers and other land
managers to deliver sustainable land management and high quality
countryside as well as improved animal welfare standards.
5. While policy mechanisms such as the CAP
have encouraged damage to the environment, it should be remembered
that the CAP was originally designed to encourage food production.
A new, fully funded European Sustainable Land Management Policy
that combined funding from both pillars of the CAP could prevent
agricultural practices damaging the environment and instead pay
for a greater range and quality of environmental public goods
over a far wider area while also improving animal welfare standards.
If the CAP were to be abolished we believe the free market is
unlikely to be able to deliver environmental public benefits without
the existence of regulatory mechanisms that are combined with
adequate funded policies to deliver these public benefits through
agriculture and other land management activities. Such a fund
could play a useful secondary role in ensuring a critical mass
of farm businesses continue to exist.
6. We believe that the environmental challenges
facing Europe in the 21st Century means that reform of agricultural
policy will require concerted European intervention. Many of the
detailed solutions to these challenges will need to be developed
at a more local level but must recognise the crucial role of sustainable
farming in managing our wildlife, the character of our landscapes,
our woodlands and our soil and water resources.
7. While it could be argued that the commercial
aspects of agricultural production could be treated like any other
industry and should, therefore, not receive public funding, the
fact remains that the production processes of commercial agriculture
have a direct bearing on the quality of the countryside and its
wildlife habitats. Making production processes more sustainable
in order to maintain high quality countryside and achieve higher
animal welfare standards, will have economic consequences for
farmers. The internalisation of these costs will inevitably have
limits, particularly with a lack of transparency on labelling.
In the opinion of Link, sufficient public money should be made
available to farmers and other land managers to underpin the delivery
of public goods such as landscapes and wildlife habitats that
are dependent on farming systems.
THE REFORMED
CAP
Q2. What has been your experience so far with
the reformed CAP? What has worked well and less well? And where
can lessons be learned?
8. Link believes that the recent reforms
have moved the CAP in the right direction. The establishment of
a second "rural development" pillar for the CAP under
Agenda 2000, and the decoupling of most direct commodity supports
from 2005, have begun to rectify the negative effects of the pre-reform
CAP of the past. The introduction of cross compliance measures
means that public funding for agriculture is now linked to basic
environmental and animal welfare standards. However, Pillar I
of the CAP, representing the largest part of the CAP budget (and
a substantial portion of the EU budget as a whole), is now a fund
without a clear policy objective.
THE SINGLE
PAYMENT SCHEME
Q3. Do you consider the Single Payment Scheme
to be a good basis for the future of EU agricultural policy? What
changes might be made at the EU level to the Single Payment Scheme,
including to the rules governing entitlements, in the short and/or
the longer-term?
9. Link believes that the new decoupled
Single Payment even when it eventually becomes tied solely to
the area of land for which it is paid, will be at best an inefficient
policy to secure sustainable land management. Therefore, as we
have set out above Link believes new approaches must be developed
to achieve wider environmental policy objectives. This will continue
to require public intervention to ensure the delivery of a wide
range of public goods from the countryside, alongside the sustainable
production of food and energy, in a way that can be built into
viable farming and rural businesses.
10. The decoupling of farm payments will
also have a profound impact on the profitability of businesses
engaged in farming and land management. Some beneficial land management
activities will become less profitable, and means need to be found
within an international agricultural trading system of providing
sufficient incentives to ensure these continue where they are
necessary. Other environmentally harmful activities should become
less attractive, and the rational move away from these should
be encouraged.
11. The inefficiencies of the current system
in achieving sustainable land management, and the need for a new
approach is exemplified by the case of GAEC 12 in England. The
new reformed CAP aims to be more environmentally aware and through
agri-environment and the England Woodland Grant Scheme provides
for an expansion of the tree and woodland resource in England.
However even where it is beneficial to wildlife and woodland to
do so, GAEC 12 prevents the growth of trees and scrub on land
not in agricultural production. A derogation may be applied to
allow for natural regeneration where appropriate. The bureaucracy
presently involved could render this a significant disincentive.
12. Ongoing provision of public goods should
be secured in different ways around the EU, but to a common framework.
This will involve burden sharing both in setting objectives and
in resourcing the delivery of a new European Sustainable Land
Management Policy that will need to allow flexibility to deliver
the different local approaches that will be needed. Any policy
for sustainable land management must be compatible with the sustainable
provision of high-quality food and renewable energy.
MARKET MECHANISMS
Q4. What short and longer-term changes are
required to the CAP's market mechanisms? Suggestions made by the
Commission have included re-examination of certain quotas, intervention,
set-aside, export refunds and private storage payments
13. Link's main concerns in relation to
short term changes to the CAP's market mechanisms are on the abolition
of set-aside and bioenergy crop measures. We will shortly be publishing
our positions on both set-aside and bioenergy.
14. Link accepts that following decoupling
there is limited market rationale for set-aside and as a result
set-aside is now a redundant concept in the eyes of many and therefore
it is likely to be abolished as a result of the forthcoming CAP
"Healthcheck" in 2008. Link believes that before abolishing
set-aside a comprehensive stock take of both rotational and permanent
set-aside must be undertaken so we know what environmental benefits
it is providing and where it is providing these environmental
benefits. In this way these benefits can be protected for the
future rather than simply lost.
15. Link recognises that there is a need
to maintain the current environmental benefits from set aside
for example through the existence of a permanent network of habitats
in relation to water courses, steep slopes and edge habitats for
key species such as bats and barn owls. Proposals to eliminate
set-aside should therefore be accompanied with mechanisms to retain
the existing environmental benefits either through cross-compliance
or through agri-environment schemes or a combination of both of
these. The benefits of improved set aside rules since its inception
should not be lost in any new regime.
16. A case may be made for short or long
term changes to the CAP to secure other public goods and address
other market failures in agriculture and rural development. We
suggest they might include supporting local food networks, improving
competitiveness, addressing peripherality, securing structural
change, cohesion objectives and income support. A European Sustainable
Land Management Policy could contribute to some of these objectives.
The case for any further intervention in these areas needs to
be clear about the need for EU intervention, respect for the single
market, efficiency of intervention, and avoiding environmental
damage.
17. In particular, it is essential that
any support to secure food, timber and fuel security, or to address
the effects of climate change, does not undermine the objectives
of sustainable land management. We have a particular concern that
there is a danger of this occurring as a result of support through
the CAP for bioenergy crops. Receipt of payment for these crops
should be conditional on production methods meeting the standards
set out in an accreditation system that ensures that real greenhouse
gas savings are provided by crops grown for biofuel or biomass
and which do not damage habitats, landscape, archaeological sites
or historic landscapes, or require unsustainable use of soil and
water resources.
RURAL DEVELOPMENT
Q5. What is your view on the introduction
of the European Agricultural Fund for Rural Development (EAFRD)?
Do you consider that it is meeting its objectives thus far? Is
it suitably "strategic" in nature, meeting the needs
of rural society as a whole rather than being restricted to aiding
the agricultural industry? How well is it being co-ordinated with
other EU and national policies on regional and rural development?
18. Link's key principles for the EAFRD
are that it should deliver public benefits through integrating
environmental, economic and social measures for sustainable outcomes
and that the agri-environment measures of the EAFRD should be
adequately funded. We supported the UK's Government view that
allocation of EU Rural Development funds should move away from
the basis of historical spend and instead be based on evidence
of need.
19. We were concerned that although the
EAFRD regulations allowed member states a degree of flexibility
in developing rural development measures an opportunity to provide
greater integration between measures has been lost through the
creation of separate axes. The Mid Term Evaluation of the Rural
Development Regulation made a recommendation that greater integration
between measures was needed. We continue to seek greater guidance
on strategic co-ordination of measures across the three axes of
the EAFRD provided by the Commission and the UK Government.
20. We are aware of only two member states
who have so far had their programmes approved by the European
Commission so it is difficult to comment on whether the EAFRD
is meeting its objectives across Europe. However, Link has carefully
monitored the development of the Rural Development Programme for
England and provided input to the process where requested. We
support the decision to allocate the majority of funding to agri-environment
measures. We were relieved that the UK Government was partially
successful in negotiating for the levels of voluntary modulation
it needed to meet the commitment it had made to the Environmental
Stewardship Scheme. We are concerned that Higher Level Stewardship
will require greater levels of funding if it is to achieve its
aims.
21. We also have some concerns over the
extent to which Structural Funds and EAFRD funds will be integrated.
Link believes it is crucial that both sets of funding reinforce
each others objectives. EAFRD social and economic funding allocations
will be limited in the UK and is therefore likely to support small
scale enterprises. The sums available through the Structural Funds
are proportionately much greater than EAFRD funding for economic
and social measures. Structural Fund support should not undermine
the smaller scale economic and social activities being supported
by EAFRD measures.
Q6. Is there a case for a higher level of
EU financing of rural development? Do you have a view on the extension
of compulsory modulation from Pillar 1 (Direct Payments) to Pillar
2 (Rural Development)?
22. Link strongly believes that rural development
measures should receive significantly higher levels of funding.
We were disappointed with the EAFRD budget that was agreed in
December 2005 which cut the amount of funding allocated to the
EAFRD. We also believe that the competitive nature of negotiations
for the division of funding between Pillar I and Pillar II from
the overall EU budget is counter productive to the aim of making
agriculture more sustainable. Link takes the view that funding
negotiations take place without the existence of adequate analysis
and evidence on the amount of funding needed to maintain agricultural
landscapes, deliver targets for biodiversity and conservation
of the historic environment, and improve animal welfare. There
is an urgent need to examine the cost and range of policy tools
for delivering the wide range of environmental and animal welfare
benefits that arise through the management activities provided
by various farming sectors which are supported through a combination
of Pillar I funding and by the sustainable land management measures
that are derived from Pillar II.
23. We also believe further research is
needed into more sustainable systems of paying for public goods
that is not reliant on the "income forgone" from often
uneconomic farming systems and enterprises. Traditional farming
systems themselves are responsible for many of the landscapes
in marginal areas which are most valued by the public (and, paradoxically,
most designated as areas of great "natural" beauty).
24. The recent disagreement between the
European Commission and the European Parliament over the percentage
of voluntary modulation the UK would be allowed to introduce also
demonstrated the difficulty of trying to fund two sets of policy
objectives that essentially both now claim to deliver sustainable
land management. Establishing a single fund for a new European
Sustainable Land Management Policy would end debate over re-nationalisation
of agricultural policy providing that the need to maintain flexibility
over the different measures required for sustainable land management
delivery in each member state was recognised.
WORLD TRADE
Q7. What benefits can the EU's World Trade
Organisation obligations create for EU agriculture and, consequently,
for the EU economy as a whole?
25. Link does not hold a view on the extent
of the benefits of the EU's WTO obligations to EU agriculture
or subsequently the EU economy as a whole. However, global sustainability
must lie at the heart of agricultural policies across the globe.
The export of environmental and animal welfare problems as result
of WTO obligations or EU measures would be both counter-productive
and unethical. One area that could prove beneficial to the continuance
of traditional farming practices is the securing of regional food
identity exemption under WTO rules; Link would strongly support
UK Government efforts to secure this.
ENVIRONMENTAL PROTECTION
AND CLIMATE
CHANGE
Q8. To what extent has the system of cross-compliance
contributed to an improved level of environmental protection?
How is it linking with other EU policy requirements such as the
Water Framework Directive?
26. There is a view that following the 2003
CAP reforms and the introduction of cross compliance measures
for receipt of the Single Payment, the CAP has become a "green
payment". However, others consider the basic standards required
for compliance as being too low for this label to be truly justified.
There is a need for public support to ensure that a baseline of
environmental measures are established and maintained. This should
be based on maintaining land in Good Agricultural and Environmental
Condition. Complying with Regulations and Directives should not
in itself qualify for receipt of public support as is the case
with other industries. However, as we have stated previously farming
is unlikely to be able to internalise all of the costs associated
with full compliance. Given that the purpose of many of these
Regulations and Directives is to deliver environmental public
goods is could be argued that funding is justified to help with
the transition and adaptation of farming businesses to meet these
requirements. Equally, it is important that measures proposed
for resource protection should be adequately assessed for possible
negative impacts on other areas of environmental protection (for
example, the impact on buried archaeological deposits of subsoiling
to reduce runoff).
27. The UK Government, in their 2005 Vision
for the CAP, gave a great deal of consideration to the impacts
of agriculture on Diffuse Water Pollution from Agriculture (DWPA).
Link believes that the pressure for profit driven production derived
from the liberalised trading system set out in the Government's
Vision could result in very different land management pressures
than under the current CAP. If these were to require different
regulatory measures to be developed to maintain the benefits of
the WFD than intervention through publicly funded measures could
be required to ensure that the aims of the WFD were secured.
Q9. How can the CAP contribute to mitigation
of, and adaptation to, climate change? What do you consider the
role of biofuels to be in this regard?
28. Link believes that further reform of
the CAP is needed to ensure land management practices can be adapted
so that the sustainable production of food and energy alongside
the conservation of biodiversity, the historic environment, landscape
character, and soil and water resources can be secured. Link believes
that the CAP even with its 2003 reforms will face difficulties
in meeting this requirement.
29. Link finds that continuing direct support
for production for biofuel crops is incongruous with decoupling
CAP funding from production of other crops. We are also concerned
that such support could result in intensification of production
and could feasibly add to green house gas emissions, for example
through increased use of artificial fertilisers. Biofuel production
is already putting additional pressure on the historic environment,
since the cultivation needed for many biofuel crops is more damaging
than that for conventional cereals and grass. It is essential
that biofuels are properly certified both for their carbon savings
and to avoid damage to habitats, landscape, the historic environment
and soil and water resources.
FINANCING
Q10. The Commissioner has expressed her dissatisfaction
at the financing agreement reached by the Member States at the
December 2005 Council. Do you consider the current budget to be
sufficient? Do you consider co-financing to be a possible way
forward in financing the Common Agricultural Policy?
30. Link believes that the 2005 EU budget
deal represented a disappointing outcome for the environment and
for sustainable rural development measures and the current budget
is therefore not sufficient. We believe it is imperative that
agri-environment schemes across Europe receive the levels of funding
required. This is essential to achieve UK Government stated objectives
for landscape, public access and biodiversity. We believe that
the amount of funding needed to deliver biodiversity targets,
maintain the character of our landscapes, protect our historic
environment and secure our soil and water resources for the future
is greatly underestimated.
31. Link believes that it is right that
the cost of protecting and enhancing our environment should be
shared by the EU and national governments but allocations to member
states must be made using an equitable, needs based approach.
ENLARGEMENT
Q11. What has been the impact on the CAP of
the 2004 and 2007 enlargements and what is the likely impact of
future enlargements of the EU on the post-2013 CAP?
32. Link is concerned that the CAP should
not encourage damaging agricultural practices in member states
that have recently joined the EU These member states often retain
non intensive farming practices that create diverse landscapes,
conserve the historic environment and provide important habitats
for wildlife. Evidence from WWF engagement in the Carpathian mountains[36]
also indicates the damage to traditional farming practices of
ill informed standards in food production and processing. Unless
addressed such food standard's rules could single handedly destroy
many valuable traditional farming practices.
SIMPLIFICATION OF
THE CAP AND
OTHER ISSUES
Q12. How could the CAP be further simplified
and in what other ways would you like to see the Common Agricultural
Policy changed in the short and/or the long term?
33. Link believes that the time has come
to assess whether efforts to further adapt and reform the CAP
to meet the challenges we have outlined above would be more fruitful
if they were to be focused on establishing a new European Sustainable
Land Management Policy. If such a decision was taken and such
a policy created it is essential that there is a carefully planned
transition from the CAP to the new policy. It is vital that during
the transition period agriculture in Europe is supported in its
land management functions that maintain and enhance the environmental
public goods it delivers.
15 June 2007
36 See http://ec.europa.eu/agriculture/events/youngfarmers/kazakova_en.pdf Back
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