BRX0011

 

 

Written evidence submitted by Upper Teesdale Agricultural Support Services

 

EXECUTIVE SUMMARY

 

SUBMISSION

  1. What are the implications for UK biodiversity of leaving the EU, in particular the Common Agricultural Policy? To what extent do initiatives to support biodiversity in the UK depend on CAP-related payments? The UK landscape and the biodiversity it contains is not “natural” yet is bursting with nature. It is a farmed landscape that produces hedges, heather moorland, flower-rich meadows and sites for ground nesting birds. It manages to do all this and produce food. Food production in the hills is not profitable on its own. In the recent past it has depended on payments from the CAP: if those are lost the more marginal areas (LFAs) would risk abandonment or re-wilding by the back door. This would destroy some of the most iconic landscapes in the UK as well as reducing biodiversity. Some of the richest habitats for both flora and fauna depend on management through grazing livestock. Re-wilding would wipe out all ground nesting birds in the hills as they depend on a tightly grazed sward to nest and rear their chicks. In time the landscape would be dominated by scrub devoid of wading birds and many of the more delicate meadow species.

 

  1. What risks and opportunities could developing our own agri-environment policy and funding present? There are opportunities to develop a results based approach to the environment but this would only work if there is a secure and sustainable economic base. It would require environmental goods to be seen as a form of production in addition to food which could be legitimately traded either with the government or with large companies prepared to offer some complimentary environmental benefit to compensate for their less environmentally friendly economic activity (this principle has already been accepted through the UK implementation of the Environmental Liability Directive). Developing a UK agri-environmental policy needs to be done within the context of the EU Rural Development Regulation and WTO guidelines: to develop a scheme outside these parameters that could be seen as “trade distorting” would be a high risk strategy if it prevented the negotiation of trade deals in the future. The EU Commission emerging thinking is moving towards an outcome focussed approach as the current prescriptive one, which by its very nature fits easily with “compensation for income foregone”, does not often deliver the anticipated environmental benefits. There is also a risk that some farmers prefer the prescriptive approach as they get paid for delivering the prescription irrespective of whether the outcomes are achieved or not. It is important that any future policy should not be totally driven by climate change mitigation within the UK: it needs to be cognisance of opportunities to mitigate climate change but not at the cost of producing extra carbon or green-house gases by exporting unfriendly environmental practices and lengthening the food chain.

 

  1. How should future support for UK agriculture be structured in order to ensure there are incentives for environmentally-friendly land management? Any future support needs to pay for the environment as production especially if there is no basic support scheme. There is no realistic prospect that food production will be economically sustainable without support in the future. Environmental sustainability cannot be achieved without an underpinning economic sustainability. Incentive are far more effective if they are not accompanied by an inflexible, disproportionate and draconian penalty system. This has been clearly demonstrated by both HLS and Countryside Stewardship where the penalties incurred for relatively minor irregularities can threaten the economic survival of the farm business. Any future scheme should ensure that the agreement and any payments go directly to the farmer of the land and not to or via the landlord. Shortening the chain is more likely to produce the desired environmental results by engaging and securing the goodwill, experience and commitment of the actual land manager towards achieving them.

 

  1. What are the positives/negatives of current schemes (e.g. Countryside Stewardship) that should be retained/avoided? The current Countryside Stewardship scheme may have some positive attributes in the lowland context but has no positives in relation to all grass farms. There are limited options for these areas with no packages like “pollinators” to make them economically attractive. Few if any farmers in the hills can afford to go into Countryside stewardship as it will cost them to go in. The risk of penalties for non-compliance makes the scheme effectively a non-starter. If an outcome focussed approach is not taken a return to the classic schemes like ESA would make sense as this gives the true expert (the farmer, who really knows the land and has a long term interest in its sustainable management), sufficient latitude to actually be able to farm and produce the environmental benefits. Countryside Stewardship is little more than “a paint by numbers” (do this and it will produce that) approach which does not fit with variable seasons and regional variations. All-grass options are limited, over-prescriptive and inflexible. One prescription cannot be expected to deliver on species rich grassland at sea level in the South West and upland hay meadows at 500m altitude in the North Pennines. Countryside Stewardship because of its limitations has and is destroying more than it conserves. The emerging EU Commission thinking, surprisingly given their usual desire to regulate, supports this view. Countryside Stewardship makes little or no contribution to the economic sustainability of the Less Favoured Areas and thus potentially undermines the environmental sustainability.

 

  1. How should future UK agri-environment support be administered, and what outcomes should it focus on? Countryside Stewardship has clearly demonstrated through its low uptake that it is not fit for purpose. This is not surprising as it has largely been developed by the RPA under a strict remit that EU disallowance will not be tolerated. As a result every option is measureable and over prescriptive. Future schemes if they genuinely want to produce Public Benefits as perceived by the public should not focus just on bio-diversity but include the overall landscape. They should recognise that there is not a “natural” landscape in England, but a landscape that has been created and shaped by successive generations of farmers. Some of the most precious UK habitats such as upland meadows and rough pastures supporting waders are almost totally the by-product of farming. Natural England is perhaps the best placed organisation to oversee this but it needs to be done in partnership with the industry at a local level using the expertise and experience of farmers themselves. Natural England will need to demonstrate a culture change throughout the organisation to make this possible: it will mean that some of its “experts” (the English Nature “old guard)” will need to be more receptive and show respect for the knowledge, skill, experience and opinions of  farmers. Local solutions for local issues.

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  1. What are the prospects and challenges for future environmental stewardship schemes in the devolved administrations? How much divergence in policy between the nations of the United Kingdom is likely? How can divergence be managed? Politicians need to accept that the landscape and environment cannot be taken for granted: its diversity and quality will alter/deteriorate if there is any significant degree of land abandonment/re-wilding. There needs to be a commitment to pay for public goods especially for those that are the by-product of a farming system which is not in itself economically sustainable. Some divergence is inevitable as the devolved administrations have different policy priorities. Too much divergence may make trade negotiations more difficult and more costly to demonstrate compliance. However, locally designed and focussed schemes delivered in partnership, are more likely to deliver outcomes and thus long term sustainability.

 

  1. What are the future risks and opportunities to innovative land practices, such as managed rewilding? What role can rewilding play in conservation and restoration of habitats and wildlife? “Managed Rewilding” is a contradiction in terms and would only be used by an environmentalist trying to justify a job. “Monitored rewilding” is perhaps what is meant. Rewilding on a small scale as part of catchment management may make some sense but the introduction of species alien to this country needs to be considered with great care. Lynx and wolves would have an impact not just on farm animals but on all species as they would alter the balance of nature. In the future this could impact on urban populations in a similar manner to the migration of foxes seeking easy pickings. In many cases rewilding would not be about habitat conservation but habitat replacement: this should be undertaken with great care and caution. Natural England has simulated some of the outcomes of rewilding through its management of the Widdybank and Moorhouse National Nature Reserve. The removal of sheep grazing in winter has threatened the survival of some of the more delicate and rare species. The work of Dr Margaret Bradshaw has demonstrated that under grazing is more of a threat to bio-diversity. It has also caused a decline in ground nesting birds by allowing the vegetation to become too long for newly hatched chicks to be able to survive. Natural England admits this destocking has wiped out Golden Plover at Moorhouse

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  1. What evidence is there to support the incentivising of such schemes in any new land management policies? Rewilding can occur through land abandonment especially in Less Favoured Areas without offering any incentives if the underlying food production systems are not supported to make them economically sustainable. However, this also happened under the Single Payment Scheme through Set Aside. Farmers over a certain size had to not cultivate a proportion of their land to qualify for the scheme (a perverse incentive). Many of the environmental benefits were lost through the EU cross compliance requirement for annual cutting to prevent scrub encroachment. This also applied to permanent pasture that was “available” (qualified for SPS) but not grazed. The EU Commission had been concerned with reducing production to maintain a higher price for basic commodities (supply management) but wanted to retain the ability to return to full agricultural production if the world supply became tight. Incentivising rewilding (payments to do nothing) on a large scale are not easy to defend in a time of austerity and are highly unlikely to produce the wide range of environmental and social goods that are provided by a carefully and thoughtfully managed farmed landscape. A hectare of wilderness is much like every other hectare of wilderness. Once an area has been rewilded it would not be economically viable to return it back to production: boundaries and drains would need complete reinstallation and the soil, the farmer’s greatest asset, would have been degraded to an extent that would take generations to restore. It would be better value to reward farming that produces or contributes to a panoply of environment goods by paying for those goods. There may be an argument to incentivise the enclosing of relatively small areas for natural regeneration where this may contribute towards other public environmental priorities such as flood control and clean water.

 

  1. Conclusion: This is a once in a lifetime opportunity to create a new outcome focussed approach to conservation which adequately rewards farmers for what they produce in environmental public goods. Local priorities and solutions need to be decided in partnership with farmers and land managers (the experts). For this to take place their needs to be a culture change within the Defra family of agencies and a willingness to adequately pay for what is being produced. A mechanism also needs to be in place to ensure that these payments go to the farmer and not the landowner. The two largest recipients of support under the current CAP regime are the RSPB and the National Trust. In a time of austerity support for the environment should not be going towards the core funding of environmental pressure groups however worthy their objectives.

 

 

August 2016