Memorandum by the Campaign to Protect
Rural England
1. CPRE works for a beautiful and productive
countryside which is enjoyable for both present and future generations.
We campaign for the more sustainable use of land and other resources.
We are a leading non-governmental organisation in the field of
planning and the protection of the countryside and the integration
of these with land management policy. We also have considerable
experience in the field of rural service provision and the management
of rural development in order to retain a clear distinction between
urban and rural England and tackle rural poverty.
2. CPRE has led the debate about the purpose and
the future of the countryside since its foundation in 1926. We
have worked with successive governments to ensure that the incomparable
asset of the English countryside is retained and enhanced for
future generations. To a significant extent we enjoy a countryside
which is the product of over 80 years of work and policy influence
by CPRE.
3. We were closely involved in the development
of proposals for Natural England and the Commission for Rural
Communities, which were part of the Government's response to Lord
Haskins" Rural Delivery Review. We played a leading role
amongst the environmental non-governmental organisations during
the passage of the Natural Environment and Rural Communities Act.
We have also been engaged in the development of farming and land
management policy and the future of the funding of land management
and rural development. We gave evidence, both written and oral,
to the House of Commons EFRA Select Committee during their inquiry
into the Government's CAP Vision document.
4. We draw on our insight into the protection
and enhancement of landscape, its associated biodiversity, enjoyment
of it by the public and the viability of rural communities from
the position of a stakeholder unencumbered by the ownership of
land and the particular perspectives and priorities that land
ownership can generate.
5. We are grateful for the extension to the
deadline for evidence that we have been granted.
6. CPRE is one of the signatories to the submission
by Wildlife and Countryside Link to the Inquiry. For the sake
of brevity we restrict our own response to observations additional
to those made in the Wildlife and Countryside Link submission.
CPRE is particularly concerned with the effects of the CAP on
the management, conservation and enhancement of agricultural landscapes
and their very diverse character. We are also concerned with the
effects of agricultural practice on our historic and archaeological
inheritance. Furthermore, we are concerned with the effects of
CAP reform on agricultural communities and those whose livelihoods
are closely dependent upon the future of agriculture and forestry.
CPRE acknowledges the crucial role that food production plays
in the management of the English countryside. We are also strongly
aware of the importance of sustaining a farming community which
has this expertise, together with the associated professions and
businesses: veterinary practices; machinery maintenance, markets,
product processors and trade support, for example.
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?
7. The long term objective of the CAP, or any
policy which supersedes it, should be to maximise the sustainable
management of land for public benefit through encouraging agriculture,
horticulture and forestry to deliver public goods. The title "Common
Agricultural Policy" does not adequately describe these objectives.
However, CPRE is clear that the role of agriculture in any future
approach to land management will be crucial. Essentially, CPRE
is calling for an Agricultural Public Benefits Fund. Developing
the long term objectives of the CAP, (or a fund under any new
name) should be regarded as an opportunity to re-affirm the part
of farming and land management in the quality of all our lives
and to take stock of the huge value of continuity of good farming
practice. It is also an opportunity to make a determined effort
to move away from environmentally damaging farming processes and
look for possible new ways to harness responsible land management
for the public good.
8. There is an urgent need for the CAP to evolve
into a system of support for land management with a range of public
benefits clearly stated as objectives. This could deliver public
goods through farming which would compete in world markets. The
attendant public benefits of competent and responsible agriculture
would be accommodated through the financial support of a land
management fund. CPRE strongly believes that our farming industry
is an immensely valuable national asset, with strategic, technical,
environmental and societal contribution to make far beyond the
short-term calculation of contribution to national prosperity
from food and commodity production. Most of the landscape, access
and habitats that we value require management which is intimately
associated with the productive use of land. Our joint report in
2006 with the National Farmers Union, Living Landscapes: hidden
costs of managing the countryside, illustrates this point
very clearly. The report is submitted to the committee as supplementary
evidence. We identified landscape management activity conservatively
estimated at £412m per year, beyond that directly stimulated
or required through agri-environment schemes. This figure takes
no account of work dedicated to wildlife management by farmers
which will not always overlap with the landscape work we recorded
in our research.
9. The prospect of farmers pursuing world markets
so far as they can while their actual management practices are
partially directed by financial support for environmental objectives
is sometimes characterised disparagingly as "park keeping".
CPRE strongly rejects this slur as it misses the crucial point
on two counts. First, because this view shows a failure to understand
the intimate connection between landscape and habitat management
on the one hand and productive farming on the other. Huge differences
to landscape and habitat quality arise from different levels of
intensity of farming, both in terms of margins of land left for
lower productivity and also the level of production from the main
areas dedicated to production. The public benefits of land management
would be much harder to secure without production taking place.
Second, all the activities referred to as "park keeping"
are, and always have been, integral to good farming practice.
It is the destructive mixture of production subsidy in the past,
intense global competition and supermarket dominance which has
suppressed many of these good management practices. CPRE regards
a reformed CAP and a new land management fund as a means to redress
the unhealthy and unwelcome dysfunction of such pressures for
over-intensive farming.
10. A reformed CAP needs to prevent a substantial
and disorderly collapse of farming. The significant contraction
of agriculture in England and the collapse of certain parts of
the industry would have far more destructive consequences than
in many other countries. This is because of the intimate association
over millennia of the productive use of land, wildlife habitat
and the character of the landscape, by comparison with places
in the world where productive agricultural land and wildlife-rich
wilderness are segregated. Examples include Canada, the USA and
the formerly collectivised farmland of some central European countries.
11. The serious decline of farming in England
would do far more than simply reduce inputs and the area under
cultivation or grazing. Networks of semi-natural landscapes (our
farmland), with combinations of management to which the majority
of native species have adapted, would be lost. The variation across
the country, expressed in the style, scale, age and pattern of
field boundaries, woodland, farm buildings, livestock, crops and
soil, would be suppressed or allowed to degenerate. The three
processes most likely to damage locally distinctive landscapes
and habitats on a very wide scale are the abandonment of farming
on less productive land, market-oriented rationalising of farming
techniques to cut costs, and renewed and increased intensity of
farming on better grade land. All three are very likely if farming
comes under significantly greater pressure in England. Some would
argue that the pace of change is already accelerating and that
this is masked for the time being by the inevitable time delay
consequent upon long term investment decisions and existing contracts
and capacity of individual farmers.
12. Just as much of England is dependent on
farming for managing and maintaining its character and wildlife
habitat, so it is dependent on farming for its identity and thus
its marketability for visitors and tourists. The economic interests
of rural settlements and market towns would be very severely affected
if they were surrounded by landscapes increasingly polarising
between dereliction and intensification. The overall proposition
of visiting England could suffer too and with it, the fortunes
of the tourism industry. The views of Visit Britain on the value
of agricultural activity to the tourism industry should be heard.
Accelerating suburban and ex-urban development would also be much
more likely as diversification away from farming became increasingly
attractive to struggling farm businesses.
13. CPRE is clear that successful rural diversification
depends on a wider context of agricultural activity, which keeps
the countryside distinctive and cared for. Ironically, it is likely
that if farming were to decline significantly, the proposition
of rural location could become less marketable. This would not
be surprising: successful urban communities are rarely derelict
or overwhelmingly dominated by commercial interests. Rural communities
and businesses would become less rural and less distinctive and
would suffer as a consequence.
14. Further CAP reform should not be undertaken
until there is a broad consensus on the likely effects of such
reform, agreement on what we value about the countryside and how
we shall retain what we value in the long term. In CPRE's view,
the Government is under an obligation to lead this debate, and
build a new foundation for farming and environmental land management
in the future.
15. A reformed CAP could be a great opportunity.
But ill-judged or hasty change could help destroy the system which
puts to good use the vast majority of the land surface of England
and with it, much of its cultural significance, wildlife and distinctive
character. We might lose the function of much farmland in England,
some of our few remaining links between the wider population and
the land and the ability to manage and use it productively for
the widest possible public benefit.
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 can be learned?
16. CPRE welcomes the decisive break with production
linked payments, despite the considerable difficulties experienced
in the transition to an area-based payments system. We were disappointed
with the concession of some ground to the NFU on the question
of exemptions of small arable fields from cross compliance rules
concerning hedgerow protection and overall, we consider the environmental
benefits from cross compliance to be meagre. Such a weak deal
for the tax payer is unlikely to be defensible for very long.
However, the value of the Single Payment in helping continuity
of farming in very uncertain times is considerable and, we believe,
sometimes underestimated.
17. The chaos and uncertainty surrounding payments
of the Single Payment, Entry Level Environmental Stewardship and
Higher Level Stewardship needs no further exposition, but there
are important lessons to learn from the experience. For CPRE,
one of the most important is the urgent need not to let farmers
down if they rise to the challenge to calls to farm responsibly
and imaginatively for landscape, access and habitat improvement.
Farming and its associated land management practices require long
term investment decisions and making changes can be onerous. It
is profoundly damaging to the public interest if Governments,
acting on behalf of society, disenchant the only group of people
competent and numerous enough to achieve agri-environmental goals.
18. The Government's record in negotiating an
agreement for agri-environment funding until 2013 over the last
eighteen months has been only partly salvaged by the achievement
of 14% modulation. This is still far below the 20% target which
the Government itself established. The funds available, though
substantial, are not enough to deliver the scale of land management
improvements which are now regarded as necessary for biodiversity
targets. The character and diversity of farmed landscape, which
does not benefit at present from a PSA target, is more vulnerable
still to this shortfall. Higher Level Stewardship is an immensely
valuable scheme and remains, in our view, under-funded.
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?
19. CPRE does not anticipate a long term future
for the Single Payment as its benefits to the wider public are
not direct enough, or good enough value. As an interim measure,
it serves a useful purpose. But the challenge is to make a transition
to a new funding regime for land management without losing most
of the resources which are presently devoted to the Single Payment.
20. The ending of the Single Payment is likely
to have a profound impact on the profitability of some businesses,
communities and families engaged in farming and land management.
Some beneficial land management activities will become less easy
to accommodate within farm businesses calculations. Means need
to be found within an international agricultural trading system
of providing sufficient incentives to ensure these continue where
they are necessary. Where competitive farming is likely to bring
pressure for environmentally harmful activities, resistance to
these should be encouraged. Otherwise, the indirect costs to society
in terms of soil and water quality and condition, as well as landscape
and wildlife damage, will escalate in the long term.
21. In terms of social equity and in recognition
of the advantages of economies of scale, a case can be made for
refining the system through tapered payments beyond a certain
threshold of income received. It would be wrong in our view to
have an absolute cut off, as a large scale of farming can be beneficial
and competitive; a reduction in payment per acre for very large
holdings, might, however, be more equitable and might make more
resources available for smaller, more hard pressed enterprises.
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.
22. One significant risk which is very likely
to arise as the result of the move towards ending the Single Payment
is the loss of the environmental benefits of Set Aside, both rotational
and permanent. Set Aside is the Prodigal Son of agricultural policy,
which has yielded significant public benefits after a very shaky
start and a conception which had little environmental inspiration.
But over the last 15 years, Set Aside rules have been altered
to the extent that where rotational cropping has been retained
when otherwise it might have been abandoned; there have been good
effects on soil quality and wildlife habitat as well as the texture
of arable landscapes. Permanent Set Aside has provided an attractively
funded route for some farmers to re-establish important linear
habitats and hunting grounds for bat and owl species and their
prey. Permanent Set Aside has also allowed the protection of water
courses and wetlands in intensive arable landscapes. In an unexpected
way, Set Aside policy has come of age just when it is likely to
be abolished. There is an urgent need to retain its benefits and
its effectiveness through another mechanism which is as attractive
to farmers in the longer term. The requirements of the Water Framework
Directive would be more likely to be met with a management agreement
available which offers returns that are competitive with intensive
cropping in sensitive or vulnerable places within river catchments.
23. CPRE is seriously concerned that moves to
incentivise bio-energy production could replicate the damaging
mechanism of production-led subsidies for food, from which we
are only now emerging. Damage to eco-systems and landscapes and
possibly local food production is as potent, whether the commodity
is food or energy.
24. Another significant risk lurks in the dedication
of significant acreage to bio-energy production. By definition,
the commitment of land for fuel must be long term. There will
be far less flexibility in land use in an era when large areas
of productive land are contracted to power generating companies
and when society is, in turn, dependent on this land for core
energy generation. The pressure on less intensively farmed land
will grow, to the likely detriment of soil and water quality as
well as habitats and landscape character. Expansion of bio-energy
cropping should not be artificially boosted without regard for
our long term food and other commodity production needs.
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?
25. CPRE welcomes the continued commitment by
the Government to the EAFRD. However, we consider that closer
integration between the three axes of the Fund would be welcome.
Closer integration of funding for improving competitiveness, the
better integration of farming as a way of life into communities
and the measures which encourage the delivery of substantial public
goods though farming would probably improve the overall effectiveness
of the EAFRD. As different authorities are responsible for different
axes, such integration requires particular commitment, for example
by Natural England and the Regional Development Agencies.
26. In CPRE's experience, rural development
which is supportive of traditional and land based industries,
is vulnerable to displacement by footloose commercial activities
which can generate higher returns. But such footloose businesses
often have unwelcome effects such as attracting out-commuting
from towns and cities, generating longer journeys to work on average
and failing to offer employment to local people. The EAFRD could
help redress the economic pressure in rural economies to abandon
land-based businesses which in turn can make a more effective
contribution to local economic and social fabric. Our research
report The Real Choice, How local foods can survive the supermarket
onslaught published in 2006, showed conclusively how valuable
local land based businesses can be both for social and economic
success at a community level as well as supporting good land management
practice and local landscapes and habitats. A copy of this report
has been sent to the committee.
27. CPRE is well aware that farming is intimately
and inextricably linked with other aspects of rural economies
and community. We regard axes one and three of the EAFRD as playing
important support roles in farming communities, especially where,
as in uplands outside national parks, pressures on communities
are very great.
28. We look for more substantial funding for
the EAFRD, and in particular for the Higher Level Scheme within
Environmental Stewardship. We should also welcome the expansion
of the EAFRD to initiate and incentivise local food networks where
these are weak or non-existent. Connections between local producers
and processors on the one hand and local schools, prisons and
hospitals, for example on the other, could be encouraged by expansion
of EAFRD funding.
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 I (Direct Payments) to Pillar
II (Rural Development)?
29. CPRE considers that there is a very important
case to be made for increased funding for rural development measures
in the UK. Specifically, a more extensive distribution of Higher
Level Stewardship schemes is needed, particularly outside the
currently targeted Sites of Special Scientific Interest and nationally
designated landscapes. CPRE supports the present priorities but
we are aware of the demand for funding outside these targeted
areas.
30. The extension of compulsory modulation would
be welcome in order to present a more equitable face of agri-environment
funding to English farmers than the present system of voluntary
modulation allows. English farmers are put under additional competitive
pressure from the present arrangements. Whether or not this is
fair is less important than whether or not it is damaging to our
national interests. It should not be achieved, however, at the
expense of the overall level of funds available for Pillar II
payments. In the longer run, should the Single Payment come to
an end, we anticipate that a new land management fund might be
founded in expanded resources for Pillar II.
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?
31. For CPRE, the reciprocal and synchronised
removal of trade distorting measures both within the EU and with
the rest of the world is a sine qua non.
32. The case is made by some for the removal
of support payments for English farmers based on the moral argument
that such expenditure directly harms the livelihoods of farming
communities in developing countries. CPRE would welcome the decoupling
of land management in England from damage to the local rural economies
of developing countries as was implied in paragraph 1.11 of the
CAP Vision paper which the Government published in December 2005.
Should radical reform of the CAP take place, it would be possible
to establish a support system for farming in England which rewarded
farmers for the successful "export" of our native landscape
in terms of both domestic and international tourism. This is something
which is unlikely to be regarded as a priority for those intent
on removing trade distortions.
33. The EU is already ensuring substantial support
for developing countries through the Generalised Scheme of Preferences
and the "Everything but Arms" agreement. Expenditure
on export refunds is now much reduced. It would seem to be unnecessary
and unwise to make further concessions in WTO talks which might
damage our agricultural industry to little benefit.
34. We should not ignore the serious consequences
of merely exporting environmental damage to other parts of the
world, many of which have far greater biodiversity to lose than
England, or the consequences of increased carbon emissions from
the expansion of long distance food export. Both modes of transport
and the methods of agriculture need to be carefully appraised
for their carbon performance. Furthermore, the urbanisation of
the developing world is proceeding very rapidly in many of the
countries most able to compete in agricultural trade. It is unclear
whether the decoupling of agricultural support from the damage
to developing rural economies will be a lasting or effective legacy.
We should not, therefore, contemplate the abandonment of much
traditional English farming in the unsubstantiated hope that traditional
sustainable agriculture in poorer countries will benefit. For
this argument to carry conviction, there would have to be targeting
of support for small-scale farmers in developing countries, which
is contrary to the likely outcome of opening up global markets.
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?
35. CPRE considers the system of cross compliance
has played a limited role in improving environmental protection.
We describe this as meagre. Anecdotal evidence suggests some improvement
in the management of hedge and ditch margins in arable fields.
The imminent end of Set Aside is more likely to threaten successful
achievement of the standards required by the Water Framework Directive.
It is also apparent from our discussions at a local level that
there is considerable frustration amongst some farmers at the
inconsistent and sometimes inflexible approach of Defra to minor
infringements of cross compliance rules. We are unable to draw
any generalised conclusion from the limited evidence available
to us. It would appear wise, however, to allow as much discretion
as possible for local officials to encourage confidence in the
system.
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. While there is no need to achieve maximum
production from farmland in the foreseeable future, there is a
need, in the view of CPRE, to keep indigenous farming systems
in England viable and stable. Continued support for the farming
sector to prevent a precipitous decline in the national capacity
to use land effectively is vital. Such support should come in
terms of Pillar II incentives rather than the Single Payment in
the medium term.
37. The unpredictable effects of climate change
add to the importance of protecting productive agricultural land
in our relatively temperate country. The protection of productive
land from development is an essential part of this process. The
existing planning mechanism protecting Best and Most Versatile
Land (BMV) is now weaker, since the publication of Planning Policy
Statement 7, Sustainable Development in Rural Areas in 2004. The
Agricultural Land Classification System on which BMV is based
and which dates back to 1966, also took no account of climate
change. CPRE considers that there is an urgent need for a new
system which protects land from development and which includes
the calculation of the potential of land to produce food, fuel
and other commodities in changing climatic conditions. Such recognition
of mapping and valuing the versatility of land to climate change
must underpin any serious strategic discussion of how farming
can play a part in both adaptation and mitigation policies.
38. CPRE is not convinced of the value of biofuels
grown in the UK to the mitigation of climate change. Clearly,
biofuel crops, including those presently grown on Set Aside land,
are strongly attractive to farmers and to some extent this is
welcome. But the environmental footprint, both in terms of carbon
and landscape, water and soil impact as well as associated built
plant and traffic movement, will sometimes be considerable. The
development of local biomass capacity appears to be more promising
and less likely to contribute to unforeseen environmental damage
than, for example from the increasing of demand for unsustainably
produced biofuels from former tropical forests.
39. CPRE welcomes efforts made by the farming
industry and individual enterprising businesses to address the
carbon footprint of agriculture through on-farm biogas schemes.
This has obvious secondary benefits for local, decentralised power
generation.
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?
40. CPRE considers that the UK and English shares
of the budget devoted to Pillar II funding (for example, our share
of the Rural Development Regulation) has not been adequate in
the past and this remains the case. In the circumstances co-financing
is likely to be necessary. We are clear that the domestic benefits
which would derive from adequate land management funding from
the Exchequer would justify such a course of action. In the longer
run, there is also a need for successive governments to maintain
a commitment to financial support for land management as the benefits
are so long term and securing them is so vulnerable to other economic
and social trends.
41. If substantial co-financing were to be contemplated
in the long term, the Treasury would be acquiring a crucial role
which it has not had hitherto. It would no longer be possible
for the Treasury to display a lack of regard for the effects of
world trade on domestic agriculture and land management quality.
The relatively high standards we maintain in England would need
positive support. It is possible that the Treasury might prefer
to leave this responsibility with the EU.
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?
42. CPRE considers that the UK Government should
be prepared to make a strong case for continued funding for rural
development in the face of demands for a substantial reduction
in the share of funds allocated to the western European states.
It is likely that the land management practices we value in this
country will be more vulnerable to economic displacement than
in some less prosperous nations.
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?
43. The evolution of Pillar II funding into
a new land management fund would be a welcome medium to long term
simplification of a further reformed CAP.
June 2007
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