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


Memorandum submitted by English Nature (A46)


  1.  English Nature is the statutory body, which champions the conservation and enhancement of the wildlife and natural features of England. We work for wildlife in partnership with others by:

    —  advising—government, other agencies, local authorities, interest groups, business communities, individuals on nature conservation in England;

    —  regulating—activities affecting protected species and the special nature conservation sites in England;

    —  enabling—helping others to manage land for nature conservation, through grants, projects and information;

    —  enthusing—and advocating nature conservation for all and biodiversity as a key test of sustainable development.

  2.  We have statutory duties for nationally and internationally important nature conservation sites including Sites of Special Scientific Interest (SSSIs), the most important of which are managed as National Nature Reserves (NNRs); Special Areas of Conservation (SACs); and Special Protection Areas (SPAs).

  3.  Through the Joint Nature Conservation Committee, English Nature works with sister organisations in Scotland, Wales and Northern Ireland to advise Government on UK and international nature conservation issues.


  4.  There has been a sea change in how society, consumers and taxpayers regard agriculture stimulated by a growing concern and awareness that farming is far more than just producing food. BSE and FMD have raised huge issues about food safety and the way in which farming is practised. Citizens increasingly realise that farming is important for providing and sustaining attractive landscapes, wildlife, access and of the links between farming and many aspects of the economy of rural areas.

  5.  Decisions on the future for agriculture and the food chain need to be set in the wider context of the Government's commitments to sustainable development. Agriculture and the food chain need to play their part in attaining the social, economic and environmental elements of sustainable development. A healthy environment is a key feature in achieving quality of life for those who live and work in rural areas and for visitors (DETR, A Better Quality of Life, 1999). Over 90 per cent of people think we have a moral duty to protect the countryside (Countryside Commission 1996). A healthy environment helps to achieve social inclusion both for rural and urban communities.

  6.  English Nature wants to promote sustainable rural development. Farming occurs over 75 per cent of the area of England and as the most important manager of undeveloped land it has a vital and diverse role to play. As a major cultural and natural heritage asset for the nation, the countryside must be safeguarded and enhanced. Our vision for farming that can help achieve sustainable rural development is for it to:

    —  protect and improve the quality of soil, air and water—providing long term sustainability and providing for the range of uses of these resources;

    —  protect and enhance biodiversity and integrate this into farm management decision making;

    —  protect and enhance the character and diversity of landscapes;

    —  support viable rural communities and the economies of rural areas;

    —  provide access to and encourage public enjoyment of the countryside—providing the basis for wider rural businesses based on visitors who enjoy and appreciate "rural amenity" including biodiversity;

    —  protect and enhance the historic environment; and

    —  provide high quality affordable food, fibre and other products produced to defined environmental and animal welfare standards.

  7.  To achieve this vision the subsidies, quotas and other production related support mechanisms of the CAP, which encourage unsustainable farming and environmental damage should be stopped. Standards of agricultural practice should be defined and enforced through a combination of regulation, advice and codes of practice with transitional support available to help farmers invest in the infrastructure that will raise farming's overall environmental performance. Farmers should be encouraged to provide public goods and services, such as a high quality and diverse environment, through incentive schemes that are available to all land managers.


  8.  The CAP has long been criticised for its many negative environmental impacts. In highlighting the problems of the current system, English Nature's role is to focus on the wildlife and natural features of England, highlight the impacts of farming on the environment, to offer suggestions on how these negative impacts can be reduced and how the positive outcomes can be encouraged.

  9.  The policies UK and European policies to "modernise" agriculture after the Second World War aimed to increase and intensify production and make farming more efficient at producing bulk agricultural commodities for a largely state controlled food chain. It was not appreciated at the time that the "intensification" of agriculture (key elements of which are greater mechanisation, labour shedding, greater use of agro-chemicals, winter cropping, enterprise specialisation and increases in farm and field size) would, in addition to increasing productivity, have such a major and damaging impact on the countryside and the wildlife that lived there.

  10.  The policies used to achieve or encourage this process of agricultural intensification were a system of price support for most of the main agricultural commodities and the provision of advice and dissemination of research findings, which was also focused on increasing production of crops and livestock products. As production increased beyond that required by the internal European market a system of quotas and export subsidies were added to the CAP in order to limit production or dispose of surpluses on external markets. The various commodity regimes of the CAP have been under a process of almost continuous ad hoc reform in order to try and control production and/or manage or create demand for surplus products. The first attempt to strategically reform the CAP was the 1992 MacSharry reforms. This package of measures aimed to decouple some subsidies from production and to introduce compensatory area payments or enhanced livestock payments. The main driver of the 1992 reforms was not environmental concerns; it was the need to control spiralling budget costs and to make the CAP more compatible with moves to bring agriculture into world trade negotiations. The impact of agriculture on the environment was a marginal issue for CAP reform in 1992 and not surprisingly the reforms failed to deliver any significant environmental improvements. The environment had become a more important factor in the latest Agenda 2000 CAP reform package, although the final agreement reached in the Berlin Heads of Government Summit in 1999 again diminished the Commission's proposals to "green" the CAP. Looking forward to the mid-term review of the Agenda 2000 agreement, starting in 2002, the impact of the CAP on the environment is again struggling to be included as part of the review. The focus of political attention is the expansion of the European Union and compatibility of the CAP with a new round of world trade negotiations.


  11.  Three broad types of inter-related factors drive agriculture: economics and markets, adoption of new technology and the governance of the sector through policies, subsidies, advice and publicly funded research and development. The role of governance, however, has been the primary and most important driver of agriculture and has not only had a major influence of farm business decision making, but also on shaping markets and providing an important contextual driver for research and development.

  12.  Over the last 50 years, agriculture, led by the policies and incentives outlined above was focused on increasing food production irrespective of the environmental costs. Farmers have responded by applying new technology and farm management practices that have intensified and specialised farm businesses to maximise production. This also contributed to a massive decline in diversity of wildlife, the loss of natural features and the erosion of distinctive local character. As a general rule biodiversity has been pushed to the margins of modern conventional agriculture, except where physical constraints prohibit this, as in the uplands. On the majority of farms biodiversity now subsists as a residual resource peripheral to most production systems and farm businesses. The net effect of the processes of agricultural intensification and specialisation has been to replace ecological and landscape diversity with uniformity. The CAP has also failed to give farmers the right policy signals to help them adapt to consumer demands and build viable businesses.

  13.  The various ways in which the CAP encourages unsustainable land management and leads to damage to the farmed environment are illustrated in the three specific examples given in the Annex: livestock subsidies and overgrazing; the loss of England's species rich grassland; and the overuse of inputs.


  14.  The recovery of biodiversity on farmland and freshwaters is the main objective for English Nature in the development of new policies for farming and the food chain and is also fundamental to achieving the Government's wildlife PSA targets, fulfilling commitments to the UK Biodiversity Action Plan and other international obligations such as the Water Framework Directive.

  15.  In its recent submission to the Government's Policy Commission on the Future of Farming and Food, English Nature set out the key issues for nature conservation that need to be addressed through active land management, these include:

    —  Reversing habitat fragmentation;

    —  Creating environmentally sustainable grazing regimes, particularly with regard to overgrazing in the uplands and the lack of appropriate grazing in the lowlands;

    —  Allowing managed realignment of coasts where coastal habitats are squeezed between rising sea levels and land defences;

    —  Reversing the decline in farmland species both on arable land and intensive grasslands; and

    —  Reversing the decline in quality of important freshwaters and wetlands, which have been damaged by excess nutrients and sediment.

  16.  Removing production subsidies or quotas alone with not achieve these objectives; what is required is an approach that both removes the damaging subsidies and uses a range of policy instruments including legislation, advice, and incentives to enable farmers and other land managers to manage land in ways that deliver positive environmental objectives. A radical CAP reform agenda, therefore, needs to be about dismantling production subsidies and production quotas while simultaneously greening remaining support regimes and transferring resources into new agri-environment and rural development measures.

  17.  In advocating this process of reforming the CAP it is important that the distinction between a production subsidy and a payment for an environmental public good is both understood and the distinction clearly maintained.


  18.  English Nature advocates a tiered approach for achieving better stewardship of the countryside. The foundations of the approach should be the basic standards that farmers and land managers should meet without publicly funded incentives. This includes meeting requirements of legislation and various codes of good farming practice. Such standards should cover environmental protection, food safety and animal welfare.

  The UK should be in the vanguard of countries setting high standards for agriculture while ensuring that UK competitiveness is not undermined.

  19.  UK competitiveness should be based on producing high quality food based on high standards with clear labelling and marketing to ensure consumers can make an informed choice to buy such produce. It is not acceptable to try and maintain short-term competitive advantage by reducing standards to the lowest level adopted by either other EU countries or those outside EU. Where new agricultural standards are being proposed or have been agreed then the Government should develop a strategy, in partnership with statutory agencies and the industry, to help the industry prepare for the higher requirements before they become a legal obligation. This could include information and advice and where appropriate help with investment and grant aid.

  20.  High standards of land management should also be reinforced through applying environmental conditions to all farm support payments.

  21.  Above this foundation should be a "broad and shallow" agri-environment scheme, such as English Nature's proposed Basic Stewardship Scheme, which would be available to the majority of farmers and land managers and be applicable to achieving environmental objectives across the great proportion of the farmed countryside. Such a scheme would help address the protection of the quality of land, air and water, protect and enhance the landscape and historic environment and help deliver the Government's commitments to UK Biodiversity Action plan targets and meet the Government's PSA targets on reversing the decline of farmland birds by 2020. A Basic Stewardship Scheme should also be administratively simple and have lower transaction costs than the current range of schemes.

  22.  Above the Basic Stewardship Scheme should be an agri-environment scheme, or schemes, which reward land managers for more ambitious protection, enhancement and restoration of the farmed environment. Specific areas of farms or areas of the countryside that have particular environmental quality, such as Areas of Outstanding Natural Beauty, scheduled ancient monuments and Sites of Special Scientific Interest may need more detailed environmental management requirements to maintain, enhance or restore them. This kind of scheme would be available on top of the Basic Stewardship Scheme and would complement rather than duplicate. Such scheme can, again, help meet various Government targets including the PSA target of getting 95 per cent of SSIs into favourable condition by 2010.

  23.  Markets have a complementary role in ensuring food production meets food safety, animal welfare and environmental standards, although markets alone are currently unable to deliver a diverse, attractive and wildlife rich countryside. Industry led assurance schemes can help build consumer confidence and make the link from "farm to fork". Current farm assurance schemes, however, offer little in terms of guaranteeing food was produced to high environmental standards. There are also marketing opportunities that capitalise on meeting higher production standards, built on a range of attributes such as health, convenience and locality. There are also opportunities for greater added value, direct marketing and more direct selling to consumers, such as through farmers' markets. This would also help farmers achieve a higher farm gate price for their produce.


  24.  The prospects for production subsidies and quotas can be considered in relation to opportunities in the short, medium and long term.

  25.  Short term opportunities—the Agenda 2000 agreement still provides scope for further movement away from production led subsidies:

    —  Modulation provides a way that member States can re-deploy funds from farm subsidies and into incentives for providing environmental public goods through agri-environment schemes. English Nature welcomes the Government's decision to modulate direct farm subsidies at 2.5 per cent rising to 4.5 per cent by 2006, but recommends that the Government should use the discretion given to it under the Rural Development Regulation to modulate to the 20 per cent allowed.

    —  Under the beef (and possibly the sheep regime by 2002), member States can use a proportion of the direct subsidies to support particular elements of the Industry through so called National Envelopes. English Nature urges the Government to use whatever discretion it has open to it to change the nature of funding away from headage payments to area based payments to encourage environmentally sustainable production systems.

  26.  Medium term opportunities:

    —  The mid-term review of the Agenda 2000 CAP reform agreement provides an opportunity to revisit the need for further reforms, particularly with regard to the livestock and dairy regimes which are at various stages of being decoupled from production. The beef regime is very complex and comprises a confusing range of headage and extensification payments for breeding cows and some finished stock with limited additional price support. The sheep regime is based on a premium on the breeding ewe controlled by quotas, and as shown in the Annex, encourages production at the expense of environmentally sustainable land management. The dairy sector is largely unreformed and remains a price support system with production controlled by milk quotas. In terms of land and farm management the beef, sheep and dairy sectors are inextricably linked and future support needs to be considered as a package and not looked at separately. The key reform should be the move away from headage payments and quotas towards an integrated area based payment linked to environmental land quality and the protection and production of environmental goods. The mid term review is an opportunity to put forward proposals, start a debate on the future of the dairy and livestock support and begin a clear progressive process of reform.

  27.  Long term opportunities:

    —  In the long term the only justification for paying public money should be for the provision of public goods. This should be the aim of the 2006 CAP reform process. This should include all the major regimes; particularly from a UK perspective, the livestock regimes and the arable regimes. This would allow the EU to reform the CAP in line with the position adopted as part of the Doha WTO agreement, which put a significant emphasis on the removal of export subsidies for surplus agricultural products.


  28.  For entrepreneurial farmers and land managers there are major opportunities from the move away from production subsidies to a more market orientated approach. Future production, however, must respect the environment, animal welfare and food safety standards. Public money should be redirected away from production subsidies and made available for the production of public goods, such as wildlife and the maintenance, enhancement and restoration of habitats.

  29.  Current production subsidies, however, represent a significant proportion of farm incomes and adjustment to a new basis for the public support for farming will be difficult for many. There needs to be a phased transition of measures to help the industry readjust to the different expectations on them. Farmers need to embrace the concept that as land managers they fulfil a variety of valuable roles for society and are not only food producers.

English Nature

19 December 2001

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