Memorandum by Woodland Trust
The Woodland Trust welcomes the opportunity
to respond to this consultation. The Trust is the UK's leading
woodland conservation charity. We have four main aims: no further
loss of ancient woodland, restoring and improving woodland biodiversity,
increasing new native woodland and increasing people's understanding
and enjoyment of woodland. We own over 1,000 sites across the
UK, covering around 20,000 hectares (50,000 acres) and we have
300,000 members and supporters.
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?
5. The Woodland Trust believes that in the
long term the objectives of the CAP need to be significantly reformed
into a single sustainable land management fund. As such the title
of Common Agricultural Policy does not fit our objectives for
the policy and should be altered to reflect a new emphasis on
sustainable land management.
6. The challenges the Woodland Trust believes
the CAP is facing include:
— Maintaining ecosystem services such
as healthy functioning ecosystems, water quality, soil quality
etc.
— Adapting land to the effects of climate
change.
— Protecting and conserving the irreplaceable
habitats such as ancient woodland.
— Conserving and enhancing important
landscapes and their character.
— Reconnecting people with the environment
and understanding what it provides for them.
— Producing food, timber and energy
in more sustainable ways.
7. We believe it is time to begin the process
of developing a new policy framework with adequate funding to
create a single Sustainable Land Management Policy in the EU that
will deliver the environmental public benefits and ecosystem services
that society needs.
8. Indeed, given the proposal in the Treasury
vision for the CAP whereby Pillar 1 is to go before 2020, perhaps
now is the right time to consider terminology for sustainable
land management funding post Pillar 1. The terms Pillar 1 and
2 come with all sorts of weighted views in terms of environmental
damage, market distortion, food mountains, compulsory modulation
etc. If we are to move towards a single support mechanism for
public benefit delivery in the countryside, we should no longer
talk about pillar 2, but simply about a sustainable land management
fund.
9. In this way public money would be delivering
public goods and services.
10. This will continue to require public
intervention to ensure the delivery as the cost of delivering
public goods and services cannot solely be internalised by agricultural
businesses.
11. However, we are concerned that this
call for a new approach may be seen by some as a cost cutting
exercise. Insufficient thought has been given to how much money
will actually be required to deliver the high value countryside,
providing sustainable biodiversity and ecosystem goods and services
on which our quality of life relies.
12. The reality is that the delivery of
public goods and services across Europe may actually cost more
than the current Pillar 1 budget.
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?
13. The Woodland Trust experience of the
reformed CAP so far has been mixed. We strongly support the recent
reforms however we are concerned about some of the detail in the
implementation.
14. 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 (Good Agricultural
and Environmental Condition) in England. We have three examples
to describe:
14.1 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 GAEC 12
prevents the growth of trees and scrub on land not in agricultural
production even where it is beneficial to wildlife and woodland
to do so. A derogation may be applied for to allow for this but
the bureaucracy involved renders this a significant disincentive.
14.2 Ancient trees are not adequately
protected under GAEC. While GAEC 16 and 17 mention the importance
of ancient trees both only reinforce existing legislation. This
existing legislation has significant loopholes which result in
the loss of ancient trees across the countryside.
14.2.1 In terms of the felling licences under
GAEC16, the felling of a single ancient tree will easily come
under the exemptions of a felling licence (the cutoff regarding
the amount of wood that can be felled without requiring a licence)
and so the loss of these historic trees continues un-recorded.
14.2.2 In terms of Tree Preservation Orders
(TPOs) under GAEC 17, we have a number of concerns. Firstly the
system is too slow to place TPOs where ancient trees are threatened;
secondly the are too few resources to protect the trees needing
protection and lastly the "dead, dying and dangerous"
loophole in the TPO legislation is significant as a great proportion
of ancient trees are dead or dying- however this does not reduce
their amenity value and in many cases actually increases their
biodiversity value.
15. As such we believe the lessons that
could be learnt are in the detail of implementation. Firstly the
detail should be checked back against the spirit of the regulation
to ensure they match and secondly the effectiveness of mechanisms
to protect environmental features needs to be assured.
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?
16. The Woodland Trust strongly supports
the recent reforms to the CAP, however we believe reform should
go further.
17. We believe that the new decoupled Single
Payment (even when it eventually becomes tied solely to the area
of land for which it is paid), will not be a good basis for securing
sustainable land management. This is firstly because the Objective
of Pillar 1 is not sustainable land management and secondly because
of the detail of its operation, as we describe in our response
to Q2 above.
18. As such we believe now is the time to
move towards a single Sustainable Land Management policy for Europe,
as described in our response to Q1 above.
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
19. Our main concern in relation to short
term changes to the CAP's market mechanisms is the abolition of
set-aside.
20. Following decoupling there is limited
market rationale for set-aside and therefore it is likely to be
abolished as a result of the forthcoming CAP "Healthcheck"
in 2008.
21. The Woodland Trust has three main views
on the future of set-aside:
21.1 Set-aside is an outdated
production reduction mechanism, it therefore has no place in a
modernised, decoupled CAP. However where set-aside land is currently
delivering high quality wildlife or public benefits, this should
be protected for the future, rather than simply lost as set-aside
goes in 2008.
21.2 We support the principle
of a % of the farm being managed for wildlife and that this be
a condition of payment.
21.3 We would like to see more
imagination in the management of land for wildlife on farms, such
as regeneration of scrub and trees adjacent to woodland, without
the risk of loss of SPS. This would buffer the existing woodland
providing discernible wildlife benefit in terms of resilience
to the existing habitat.
22. In order to protect the benefits currently
accruing from set-aside for the future we believe 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 these are being provided.
23. Mechanisms to retain the existing environmental
benefits include cross-compliance or agri-environment schemes,
as in the Welsh Tir Cynnal example, whereby a percentage of the
farm is managed for wildlife.
24. In this scenario the maintenance of
the biodiversity benefits is a condition of the payment (rather
than an option eligible for further payment). In this way the
benefits of set-aside can be retained for the future without further
squeezing the Pillar 2 budget.
25. In addition we would like to see more
imaginative use of set-aside, in the current scenario in England
scrub and woodland is not allowed to regenerate on set-aside without
the Single Payment being lost. The goes against the new reformed
CAP's aims of greater environmental awareness and provision of
public benefits.
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?
26. The Woodland Trust strongly supports
the introduction of the EAFRD, as it provides for the protection
and enhancement of our countryside.
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)?
27. The Woodland Trust strongly believes
that rural development measures should receive significantly higher
levels of funding because of the need to enhance the countryside
in order to deliver a range of public benefits.
28. We were disappointed with the budget
that was agreed in December 2005 which cut the amount of funding
allocated to the EAFRD.
29. We also believe that the competitive
nature of negotiations for the division of funding between Pillar
I and Pillar II is counter productive to the aim of making agriculture
more sustainable.
30. In addition we do not believe there
has been adequate analysis and evidence of the amount of funding
needed to maintain agricultural landscapes and deliver targets
for biodiversity. As stated in our response to Q1 above it is
possible that the level of funding needed to maintain a high value
countryside, deliverying a wide range of ecosystem services, may
actually be more than the current Pillar 1 budget.
31. 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. Establishing a single fund for Sustainable Land Management
would end this debate.
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?
32. The Woodland Trust believes it is too
soon to determine if cross compliance has resulted in an improved
level of environmental protection.
33. As with other industries, simply complying
with Regulations and Directives should not enable farmers/foresters
to claim public monies. However where these Directives are aimed
at supporting public goods and services there is a need for public
support as the farming industry is unlikely to be able to internalise
all of the costs associated with full compliance.
34. The Woodland Trust does not believe
that cross-compliance is adequately linking to the Water Framework
Directive requirements. Work on these two areas appears to be
in parallel rather than joined.
35. In addition to this, the issues we have
raised regarding GAEC 12, tree felling and TPOs under Q2 are all
relevant here.
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?
36. The CAP could contribute to the adaptation
of climate change through helping to create wildlife friendly
landscape across England. In the short term we believe that this
cannot be achieved without a substantial incease in funding for
Pillar 2. In the longer term further reform of the CAP into a
sustainable land management fund, is required in order to achieve
this.
37. The CAP could also contribute to climate
mitigation measures through carbon storage, for example by using
minimum tillage techniques to prevent carbon loss from soil.
BIOFUELS
38. The Woodland Trust finds that continuing
support for production for biofuel crops is incongruous with decoupling
CAP funding from production of other crops.
39. 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.
40. It is essential that biofuels are properly
certified both for their carbon savings and to avoid damage to
habitats, landscape, and soil and water resources.
BIOENERGY
41. With regard to the wider bioenergy arena
we support mechanisms to develop biomass markets, our comments
in paragraphs 39 and 40 also apply here.
42. In addition we are concerned about a
blanket approach to biomass and the generic assumption that all
biodiversity will benefit and that this is a strong rationale
for developing biomass markets. This is clearly not the case,
as individual species requirements are vastly more complex and
variable than any one form of management in woods might be able
to deliver.
43. Some types of management in some woods
may create conditions that will benefit biodiversity but this
is not true in all woods. Much woodland management, such as the
clearfelling and replanting of ancient woodlands with conifers
in the 1960s, has devastating effects on biodiversity which we
now spend much time and money trying to restore.
44. In semi-natural woods where there has
been no intervention for some time, there is a risk that re-introducing
management for biomass production could have negative effects
on biodiversity, just as it is claimed that it might have positive
benefits.
45. Biomass production, with the proper
checks and balances, is an excellent objective in itself for managing
woods and this should be recognised rather than confused with
a biodiversity rationale.
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?
46. The Woodland Trust believes that the
2005 EU budget deal represented a disappointing outcome for the
environment and sustainable rural development measures—the
current budget is not sufficient.
47. We believe it is imperative that agri-environment
schemes across Europe receive the levels of funding required to
deliver a high value countryside. We believe that the amount of
funding needed is greatly underestimated.
48. The Woodland Trust believes 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.
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?
49. We believe the CAP could be further
simplified through reform into a single sustainable land management
fund. Please see our comments above in relation to this.
June 2007
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