Select Committee on Environment, Food and Rural Affairs Appendices to the Minutes of Evidence


Memorandum submitted by the Environment Agency (A35)


1.1  World Trade Organisation

  There is little doubt that the level of production subsidies and quotas will be reduced after the current round of WTO discussions. The ministerial declaration following the WTO meeting at Doha makes a commitment, without prejudice to the outcome of negotiations, to substantial improvements in market access; reductions of, with a view to phasing out, all forms of domestic subsidies; and substantial reductions in trade-distorting domestic support. The emphasis on reduction of export subsidies will put pressure on CAP reform, while the references to non-trade concerns imply that there is recognition of the environmental agenda.

  The declaration also reaffirms the objective of sustainable development; it states that members are convinced that the aims of the trading system, protection of the environment and the promotion of sustainable development can and must be mutually supportive. No country should be prevented from taking measures for the protection of human, animal or plant life, or health, or of the environment at levels it considers appropriate, subject to the requirement that they are not applied in a manner that would constituted arbitrary or unjustifiable discrimination.

  The declaration provides an opportunity to discuss the role of and funding for agriculture in the UK. The Environment Agency believes that agriculture is and should continue to be multifunctional. We strongly support payments to land-managers for delivery of wider public goods, including the protection and enhancement of the natural resources of water, soil and air.

1.2  The mid-term review and future CAP reform

  Whatever the outcome of the Doha round of talks, CAP reform is inevitable as present levels of agricultural support cannot be maintained in a larger European Union. The current expectation is that the accession states will try to negotiate for the biggest share possible of Pillar one funding. They are unlikely to support a larger Pillar two, or increased modulation.

  This combination of factors suggests that at the EC level, the mid-term review will not result in radical change. However by 2007, substantial reform will be inevitable.

1.3  The Environment Agency position (summarising our submission to the Policy Commission on Food and Farming)

1.3.1  Immediate measures

  Funding for agri-environment schemes should be expanded up to the 20 per cent national discretionary limit under the existing rules of the Common Agricultural Policy (CAP). This funding should support new whole-farm agri-environment measures that emphasise management of soil, water and air (ie resource protection).

  An industry-led whole farm environmental management standard supported by DEFRA should be adopted. Within this, the progressive integration of existing and new regulations in to a single national delivery framework will simplify regulatory processes for farmers.

1.3.2  At mid-term review

  Following the mid-term review there should be greater recognition of resources protection issues in Rural Development Plans.

  The rules governing allocation of funds should be clarified to ensure that:

    —  there is a common understanding of good agricultural practice;

    —  natural resource protection is recognised as a legitimate target of agri-environment funding; and

    —  the option to make capital payments for works in support of natural resource protection is permitted.

1.3.3  At the next round of CAP reform (2007)

  At least half of all CAP funds should to go Rural Development Regulation.


2.1  Why is better stewardship needed?

  The Agency is concerned that agriculture has significant environmental impacts affecting soil, water and air. Our submission to the Policy Commission on Farming and Food describes these impacts, and the cost of these to the UK. The Agency's objective is to see environmental issues placed at the heart of agricultural business thinking. Protection of water, soil and air are fundamental to sustainable agriculture and should not be relegated to an afterthought. They must be addressed as an integral part of business assessment and planning. Many of the principles of good agricultural practice for both the environment and the farm business are encompassed in a recent Agency publication entitled "Best farming practices: Profiting from a good environment".

  To change practice the Agency believes that awareness of the impacts of agriculture, including the external costs paid by society, need to be understood and accepted by the industry. There is a need for higher standards to be adopted across the agriculture industry and land management as a whole.

  More environmental legislation from Europe is inevitable. A list of Directives that will affect agriculture is given in our submission to the Policy Commission. The cost of implementing and complying with these Directives will be substantial. However, new legislation and new regulations do not automatically guarantee better stewardship. It is essential that farmers and other land managers are given assistance and incentives to understand their responsibilities and improve their environmental performance. Regulatory effort and other controls can and should then be targeted at poor performers.

  The Agency sees three principal opportunities to promote better stewardship:

    —  An Environmental Management Standard for farms.

    —  Funding for natural resource management through CAP and/or state aid.

    —  Better knowledge transfer.

2.2  Environmental management standard for farms

  The rationale behind the Agency's proposal for an Environmental Management Standard for farms is provided in our recent submission to the Policy Commission on Farming and Food. In summary, we are proposing a scheme that will integrate environmental objectives and targets into the farm business. It will deliver both statutory environmental requirements (which are set to increase dramatically) and key elements of good practice for protecting the environment. To succeed the standard must be owned by the industry and supported by Government.

  Environmental plans will incorporate both natural resource protection measures covering issues such as nutrients, manures, pesticides, energy and waste management, emissions to the atmosphere and measures to protect wildlife, biodiversity and landscape.

  The farm plan approach will place the responsibility for farm environmental management firmly with the farmer. Farmers can design environmental management plans to suit their enterprise. There will be flexibility to take account of different farming systems, within the environmental capability of the farm.

  Benefits will include better environmental performance from the sector as a whole, better protection of natural resources, cost effective administration and regulation, incentives to adopt good practice, and disincentives for those who choose not to participate.

2.3  Funding for natural resources management

  A financial package to support natural resource management through the Environmental Management Standard is needed. This can be justified because the costs will be offset by reductions in the damage to natural resources currently caused by agriculture. The Environment Agency estimates that remediation, and damage which cannot be remedied, is costing the UK some £1.5 billion per annum.

2.4  Knowledge transfer

  Farming in England and Wales is supported by high quality research and development, conducted by the Government, its Agencies and by the agricultural supply trade. However, there is substantial evidence to suggest that new technologies and best practice are not being adopted by the industry. Recent research and policy development by DEFRA—supported by the Environment Agency—has led to a proposal for a knowledge transfer strategy. Outline proposals for this support a national facilitation service supporting local networks. The Environment Agency believes that a properly funded knowledge transfer strategy will be vital to the future success of the agriculture industry. The Strategy should build as far as possible on existing effective local networks (eg the South-West Agriculture and Rural Development Project (SWARD).


3.1  Natural resource protection

  It is important to recognise that land produces a range of benefits. In some places food and fibre may be the primary output or benefit to society, and other benefits such as biodiversity, amenity/recreation, water supply and energy may be secondary. Elsewhere, the reverse may be true, even where agricultural outputs are currently the primary source of income. In practice all land could and should produce a range of benefits. To ensure that these benefits are maximised, expertise in land management, not just agriculture, is required. Sustainable land management must ensure that land use matches, but does not exceed, land capability.

3.2  Funding for agriculture

  The UK has an opportunity to prepare for the transition away from production support and into environmental measures by taking immediate advantage of the full level of discretionary modulation and by taking all necessary steps to achieve an extension of discretionary modulation in the next round of CAP reform.

  Transition away from production subsidies will allow agriculture and wider land management greater flexibility to diversify, and to receive payment for the provision of public goods.

3.3  Land-use change and management

  Changes in the level of and basis for public support of agriculture may lead over the next decade or so, to some land, particularly marginal land, becoming economically non-viable for food production. This will open up opportunities for alternative land uses. Non-food crops such as biofuels may become more attractive, as may commercial afforestation. Prospects of land acquisition by conservation and amenity interests for management may also arise, on a minimal intervention basis, to allow reversion to more natural habitats, with recreation, biodiversity and natural resource benefits. In urban fringe areas, there may be opportunities to provide such benefits where they are more accessible to large numbers of the population, and deprived groups and those reliant on public transport.

  Even if land management costs are minimal, other associated costs, for example fencing and footpath maintenance, countering flytipping etc, may be significant. To ensure that the benefits of land-use change are fully realised it will be important to ensure that suitable funding is available. Where payments, including those from the CAP, are available to agriculture for provision of biodiversity, amenity, natural resource and other public benefits, they should also be available to other land managers undertaking similar works for the provision of such benefits.

3.4  "Green proofing"

  Where land remains in agriculture, and farmers continue to produce commodity crops, the Agency is concerned that increased competition and cost reduction will lead to "cutting corners" and that management for the environment will be prejudiced. There may also be rapid changes in land use and/or techniques. Many of these are likely to be outside the scope of current planning and Environmental Impact Assessment regulations, and so their environmental consequences will not come under scrutiny.

  The Agency and its predecessors have expended considerable effort and public money on correcting adverse environmental impacts arising from the adoption of new technology. In the 1970s new silage and slurry systems were introduced and adopted without a proper understanding of the environmental consequences. This led to pollution problems that have taken decades to correct. Another example is where the widespread adoption of maize caused significant environmental damage. Swift action by the Agency, in collaboration with the industry, ensured that guidance was produced to address the adverse impacts. However the problem is not wholly under control. An earlier understanding of the environmental impacts of maize production could have avoided considerable environmental damage, and significant difficulties for individual producers.

  The Agency believes that a system for "green proofing" of new practices and technologies is needed, to ensure that the environmental consequences are understood and environmental good practice can be developed and promoted at an early stage. We emphasis that only in extreme cases would change be prevented. However, change must be managed to ensure that new techniques do not compromise the environment.

3.5  Adding value

  UK producers could focus on adding value by processing food close to source, so that domestic primary food production has a closely linked market and the impacts of transport (carbon and other emissions) are minimised. The Agency would welcome such a development, and public support to encourage its realisation. The environmental as well as social and economic benefits of maintaining profitable UK agriculture are considerable.

3.6  Flood management

  We are also living at a time of increasing flood risk due to climate change. Planning scenarios from the UK Climate Impacts Programme currently suggest that peak flows for a given return period could increase by up to 20 per cent within 50 years. The Agency, along with its partners in Flood Defence, are introducing Catchment Flood Management Plans (CFMPs) to take a strategic view of managing flood risk in a sustainable manner throughout the whole catchment. This will involve—in some catchments—the development of significant volumes of flood storage on agricultural land to reduce peak flows in the river and flood plain downstream.

  The introduction of CFMPs and the new planning guidance on Development and Flood Risk (PPG 25) provides the opportunity to consider strategic changes in land use, including the realignment of defences to designate new flood storage zones on structure plans. Such changes would "enable flood plains to flood naturally or more extensively, thus providing the necessary storage and subsequent gradual release of flood water" (PPG 25). There has been considerable interest in the use of agricultural land to provide flood storage, particularly with additional benefits for wetland creation. With the technical and statutory frameworks in place, there is an excellent opportunity to formalise this important future category of rural land use.

  Flood storage is not synonymous with wetland creation. Development of effective storage will require some engineering works to "pond" water. Simply creating wetland is unlikely to generate sufficient flood depth to deliver an adequate volume of storage to reduce the impact of flooding downstream. For example, work on the pilot Catchment Flood Management Plan for the River Severn has established that to fully protect Shrewsbury, 60 million cubic metres of storage space will be required, in addition to the 20 million cubic metres already available in the Welsh borders. (One million cubic metres equates to flooding one square kilometre of land to a depth of one metre).

  Depending on the design and management of each zone of flood storage, the land flooded could revert to either agricultural use (eg grazing; water meadow) or wetland after flood storage. The inundation of zones would be graded so that some zones flood regularly (eg annually) whilst others flood only in extreme events (eg once in 20 years or more).

14 December 2001

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