Nov 2013

 Consultation on the implementation of CAP Reform in England November 2013 RSPB response Key points The RSPB welcomes the opportunity to respond to Defra’s consultation on the implementation of CAP reform in England from 2015. We have consistently set out a series of priorities for the current round of reform, and its implementation in England. In the most general terms, these are: ‐ A maximum transfer of 15% from Pillar I direct subsidies to Pillar II Rural Development Programmes; ‐ The development of a Rural Development Programme for England that prioritises funding for high quality, outcome focused and advice‐led environmental land management schemes and; ‐ An approach to Pillar I greening that is as effective as possible and thus provides maximum value for money, whilst taking account of the environmental benefits provided by existing agri‐environment schemes. We therefore welcome the Secretary of State’s assertion that Pillar II “unquestionably represents the better use of taxpayers money”, and urge the Government to follow through on their intention to maximise the benefits that Rural Development can deliver. Given the compelling case for a maximum transfer set out in the consultation, and the demonstrable scale of need, we cannot see how anything but a maximum transfer can be justified. We urge the Government to adopt an environmental focus for the next RDPE. The Impact Assessment makes it clear that the benefits provided by such a focus are greater than any other scenario, and the consultation also makes it clear that even with a maximum transfer of funds and environmental focus, the need will still outstrip the available funding. Specifically, we feel that there is a particularly compelling case to focus environmental land management schemes on the conservation of biodiversity. Well funded, high quality environmental land management schemes will be essential if we are to realise the desired outcomes set out in Biodiversity 2020, and the trajectory set for the New Environmental Land Management Scheme (NELMS) is promising. But unless an environment focus is taken for the RDPE, these outcomes may prove impossible to achieve. We are however deeply disappointed that the Government has signalled their intention to implement minimal greening. We strongly feel that the use of a National Certification Scheme (NCS) will enable the most effective approach to greening, whilst allowing Defra to develop measures that provide the best fit to existing and future agri‐environment schemes. We urge Defra to reassess their position with regard to greening. The recent State of Nature report revealed the need for urgent action to address wildlife declines across the UK. The implementation of the CAP in England provides Defra with the opportunity to respond to this call to action. 1 Contents
Direct Payments ........................................................................................................................................... 6 1. The Government has decided that we should not create any new regions nor amend the existing regional boundaries, in order to avoid unnecessary complexity in the transition to the new direct payments system. ..................................................................................................................................... 6 2. Do you support the principle of moving to more equal rates of payment across the three payment regions? ..................................................................................................................................... 6 3. The Government has decided that we will not be introducing payments linked to an ANC designation at the present time. .............................................................................................................. 7 4. Do you support our preferred option that we should apply the minimum level of reduction possible? If not, what level do you think should be applied? ................................................................... 8 5. Do you support our preferred option that we should not implement salary mitigation? ............... 8 6. Do you support our preferred option not to implement redistributive payments as an alternative to reductions? ........................................................................................................................................... 8 7. The Government has decided not to introduce a coupled support scheme in England. ................. 9 8. The Government has decided that in order to achieve the best value for money, the minimum claim size for the new scheme should be fixed at five hectares. ............................................................. 9 9. The Government has decided to roll forward Single Payment Scheme entitlements into the new scheme. ................................................................................................................................................... 10 10. Ministers have decided to adopt a threshold of €5,000 for the purposes of applying the negative list, in order to minimise administrative burdens for farmers and the RPA. ........................... 10 11. Do you support our preferred option not to extend the list of ‘negative activities’ forming part of the active farmer test? ....................................................................................................................... 10 12. The Government has decided that we should not operate a Small Farmers Scheme. .............. 10 13. We must set a limit on the number of entitlements that can be claimed under the Young Farmers Scheme which must be between 25 and 90. What do you think should be the ceiling that can be claimed by an applicant to this scheme? ........................................................................................... 10 14. Our preferred option is not to require those seeking to participate in the Young Farmer Scheme to meet additional eligibility criteria. Do you agree? ................................................................ 11 Greening ..................................................................................................................................................... 11 15. The Government is not minded to take up the option to implement greening through a National Certification Scheme containing additional, equivalent measures. Do you agree with this approach or do you see a case for a National Certification Scheme and, if so, on what grounds? ....... 11 2 16. Do you agree that this approach to the implementation of greening in England strikes the right balance between environmental benefit and administrative cost, in the context of our approach to the CAP Reform package as a whole? ..................................................................................................... 12 17. Making available the full list of proposed Ecological Focus Area (EFA) options would enable the EFA requirement to be met without the need for additional action. However, individual EFA options may realise differing levels of environmental benefit. Which selection of Ecological Focus Area options do you favour? ........................................................................................................................................ 13 18. There is a particular interest to see benefits for pollinators arising from the implementation of greening. Are there any practical Ecological Focus Area options, or enhancements of these options, which could be easily adopted, have a high likelihood of uptake and which would be particularly beneficial for pollinators? ....................................................................................................................... 16 19. Would these options be deliverable within the approach set out in the direct payments Regulation or would they need to be implemented through a National Certification Scheme? ........... 17 Cross compliance ........................................................................................................................................ 17 20. Are there any GAECs that you think should not be carried forward and included from 2015? If so, what are your reasons and evidence for this? .................................................................................. 17 21. Are there elements within any GAEC that you think should or could be changed, implemented better, or excluded? If so why? .............................................................................................................. 18 Rural Development .................................................................................................................................... 20 22. What lessons can be learned from the current Rural Development Programme? How can we build upon its successes? ........................................................................................................................ 20 23. Are there any key areas we have missed in our assessment of need to support the new Rural Development Programme? Are there any further sources of evidence of social, economic and environmental need in rural areas for England that have not been captured? ..................................... 23 Are the areas we outline for support under the new Rural Development Programme set out 24. above the right ones? How we can best target investment under the new Rural Development Programme to help gain the maximum value for money for UK taxpayers? ......................................... 24 25. How might we make the process for applying for Rural Development funding simpler or less bureaucratic? How might this be balanced against the need to ensure clear accountability for public funds? 25 26. What are your views on the structure of the proposed new environmental land management scheme, in particular the new “landscape scale” approach? ................................................................. 26 27. Do you agree that we should not be prescriptive about how groups of farmers or land managers could be brought together to deliver landscape scale agreements under the proposed new environmental land management scheme? ........................................................................................... 27 28. How could we help facilitate landscape‐scale approaches under the proposed new environmental land management scheme? ........................................................................................... 28 3 29. Should we offer a capital only grant as part of the proposed new environmental land management scheme? ............................................................................................................................ 29 30. Do you agree with the principle that five‐year agreements should be the norm under the new environmental land management scheme? ........................................................................................... 30 31. What approach should we take to targeting the new environmental land management scheme? .................................................................................................................................................. 30 32. With the exception of the highest priority sites, is there a case for making advice and guidance available increasingly on line or through third parties under the new environmental land management scheme? .................................................................................................................................................. 31 33. Where should we set the scheme entry requirements (ie above the legal baseline) for the proposed new environmental land management scheme? ................................................................... 32 34. Have we identified the right areas of support under the new Rural Development Programme to help improve the competitiveness and efficiency of the farming, forestry and other land‐based sectors? Are there any other areas which could be supported? ............................................................ 33 35. What activities to support the farming, forestry and other land‐based sectors under the new Rural Development Programme would provide the best value for money for the UK taxpayer? ......... 33 36. How should we support advice and skills for the farming, forestry and land‐based sectors under the new Rural Development Programme? ................................................................................... 34 37. How can we ensure any advice provided to the farming, forestry and other land based sectors and through the new environmental land management scheme is integrated and linked with advice provided within the industry in the light of the Review of Advice and Partnership Approaches? ........ 34 38. How do we ensure innovation is considered across the breadth of the new Rural Development Programme? How could we develop proposals for an England specific European Innovation Partnership to support this? ................................................................................................................... 35 How can we strengthen LEADER’s contribution to delivering jobs and growth in rural areas? 39. How can we make the LEADER approach more effective and deliver better value for money? ........... 35 40. What role could loans or other financial instruments play in delivering the Rural Development Programme? ............................................................................................................................................ 36 Inter‐pillar transfers ................................................................................................................................... 36 41. Should we transfer funding from Pillar 1 to Pillar 2? If so, should we transfer the maximum 15% or less? ............................................................................................................................................ 36 What priorities should we spend RDP funding on? ................................................................................ 40 43. What proportion of RDP spend should we apply to: .................................................................. 42 Market management ................................................................................................................................. 47 Summary table of main impacts of the new CAP ...................................................................................... 47 4 44. Do respondents agree with the main conclusions of the analysis in the CAP reform evidence paper and in the RDPE Impact Assessment? .......................................................................................... 47 45. Are there any important impacts of the CAP implementation package that have been overlooked? ............................................................................................................................................ 50 46. Are there any key inputs or assumptions where better evidence is available? ......................... 50 Annex 1 – Estimating the percentage of the area of eligible arable land likely to be occupied by features and crop types eligible as Ecological Focus Area under Article 32 of the Direct Payments regulation ...... 52 5 Direct Payments 1. The Government has decided that we should not create any new regions nor amend the existing regional boundaries, in order to avoid unnecessary complexity in the transition to the new direct payments system. The RSPB has no comments on this decision. 2. Do you support the principle of moving to more equal rates of payment across the three payment regions? Option 1: No change in the current regional distribution Option 2: Uplift in upland direct payments (with modest reductions to lowland direct payments), or Another option Please comment further if you wish, or explain what other option you favour. The RSPB is broadly supportive of the intention to increase basic payment rates in the uplands, however we are very concerned about the lack of environmental conditionality attached to these payments. The RSPB is open to changes in CAP Pillar I payments that would see an increase to financial support for upland farmers (Option 2) as many (although not all) are delivering important environmental public goods and services as part of their approach to land management . In the UK, High Nature Value (HNV) farming1is mainly associated with extensive beef and sheep farming reliant on semi‐natural grazing in the uplands. However, maintaining, or indeed even reaching, economic profitability remains a challenge due to a range of factors, including market access barriers, competition from more intensive production systems, poor prices and the failure of the CAP and wider public policy to adequately reward environmental public good delivery. As a result, research has found that farming practices are changing – often with a polarisation between unenclosed areas which have experienced a reduction in grazing, and improved areas are being more intensively managed2. Due to these issues, the Pillar I income support payments that upland farmers receive often represent a significant proportion of their overall income, masking the unprofitable nature of livestock production in the uplands. There is therefore a clear argument for better rewarding HNV upland farmers. For non‐HNV approaches to upland management, particularly moorland management in the context of sporting estates, a very different set of challenges are evident. Across a significant proportion of England’s moorland (a mosaic of upland heath and bog), intensive land management practices are deployed to ensure sufficient numbers of grouse for driven‐shooting, including vegetation burning and cutting, drainage, legal (and illegal) predator control, medication of grouse and the construction of butts and tracks. These management practices can have significant environmental consequences e.g. designated sites in poor condition, absence of priority species, damage to carbon‐rich peat stocks and associated impacts on hydrology, water colour and aquatic invertebrate communities. In contrast to 1
For example, Swales and Moxey (2008) Targeting CAP support at High Nature Value farming and crofting systems Cumulus Consultants (2012) Changing livestock numbers in the UK Less Favoured Areas – an analysis of likely biodiversity implications 2
6 HNV farmers, shooting estates are both less dependent on Pillar I payments as income support or in some cases using them to support less sustainable approaches to land management. The challenge is to make any uplift in financial support sufficiently targeted to deliver the required economic, social and environmental outcomes. For upland HNV farms, we believe a package of support measures from both Pillars is needed, explicitly linked to the exceptional public goods they provide. However, Defra’s proposed uplift in Pillar I payments for SDA and SDA moorland areas will not be linked to environmental public good delivery. Whilst we acknowledge the merits of some of the practices (noted above) in helping to maintain populations of some priority birds, we strongly question any significant uplift in payments (relative to current rates) for the moorland region unless Defra can demonstrate this would be used to secure improvements in land management. Defra’s parallel decision to close the uplands agri‐environment scheme (UELS) must also be considered in this context. The RSPB has long maintained that Pillar II schemes should not include any income support whilst Pillar I exists to provide this function. We are therefore supportive of the decision to remove the income support component of UELS. However, the decision to remove a bespoke scheme entirely, at the same time as boosting Pillar I payments for the uplands, could have very significant consequences for upland famers' perception of where their long term financial interests are best served by the CAP. Despite Defra’s statement that the uplands can “be expected to remain a recipient of targeted agri‐environment funding, both for designated sites and wider landscape scale activity” this may not be evident to many farmers, and the perceived absence of an uplands scheme may have a negative knock on effect on uplands land management. Defra must therefore ensure that upland farmers’ perception of NELMS is that the scheme is as equally ‘for them’ as for lowland farmers, in order that the cultural buy in to agri‐environment schemes, secured through UELS, is not lost from upland farming communities. This could be something as simple as providing a strand to the new mid tier scheme which is uplands specific to make the scheme clearly inclusive to upland farmers, but the application process itself, and crucially the vetting procedure, would be exactly the same for upland and lowland farmers. Defra should therefore, and as a matter of urgency:  work to identify, monitor and develop innovative approaches to improving support for HNV farming systems, clearly linked to their environmental public good delivery;  commission research to fully understand the impacts of the proposed uplift of Pillar I payments on farm management (including economics) and the environment;  explore and identify ways that Pillar I support can be better linked to environmental public good delivery, particularly on upland heath and bog, through for example, better design and enforcement of cross compliance and greening;  Consider how the cultural buy in to agri‐environment schemes, generated through UELS, can be continued and enhanced in NELMS. 3. The Government has decided that we will not be introducing payments linked to an ANC designation at the present time. The RSPB supports Defra’s decision not to introduce ANC payments. The ANC payments that Member States will have the option to make available to farmers (in either Pillar) provide extremely limited scope to attach environmental conditions or require specific management practices. This therefore means the scope to use the ANC measure to target additional 7 support to upland HNV farms is also extremely limited. As a result, the RSPB supports Defra’s decision not to introduce ANC payments at this time, or in the future unless they are clearly linked to environmental delivery. We urge Defra to consider all available opportunities to use CAP payments to reward environmental public good delivery, particularly in areas facing challenging environmental circumstances. 4. Do you support our preferred option that we should apply the minimum level of reduction possible? If not, what level do you think should be applied?  We should apply the minimum level of reduction possible (5% on receipts over €150,000).  We should apply a higher rate of reduction but less than 100% (please explain what reduction you favour).  We should make €150,000 the most any farmer can receive — this is the maximum reduction possible. The RSPB supports Defra’s preferred option. This approach will generate additional funds for Pillar II whilst ensuring a proportionate but not significant impact on large Pillar I beneficiaries, including those who are using Pillar I payments to support more sustainable land management. Due to the funding shortfall for Defra’s environmental objectives, even with maximum transfers from Pillar I to Pillar II (via modulation), it is extremely important that Defra use the funds generated from capping to invest directly in agri‐environment schemes. 5. Do you support our preferred option that we should not implement salary mitigation?  We should not adopt salary mitigation.  We should not adopt salary mitigation, provided that the rate of reductions is applied at the minimum rate of 5%.  Salary mitigation should be allowed. Please comment further if you wish. The RSPB supports Defra’s preferred option. Whilst salary mitigation would reduce the impacts of the cap on larger Pillar I beneficiaries, including those who are using this funding to support more sustainable land management, we do not believe that the level of benefit potentially secured would outweigh the administrative burden on government. In this case, we agree with Defra’s view that the burden placed on the RPA arising from salary mitigation should be avoided, allowing them to concentrate on administering Pillar I payments in good time and providing the highest quality support possible to claimants. We therefore support Defra’s intention not to adopt salary mitigation. 6. Do you support our preferred option not to implement redistributive payments as an alternative to reductions?  We should not implement redistributive payments. 8 
We should implement redistributive payments instead of reductions. Please comment further if you wish. The RSPB supports Defra’s intention not to implement the redistributive payment approach as it would not generate any additional funds for Pillar II. 7. The Government has decided not to introduce a coupled support scheme in England. The RSPB supports Defra in its decision not to introduce ‘conventional’ coupled support in England. The RSPB fully supports Defra in its view that coupled payments are a regressive component of the CAP, and that, in the main, such support has a high risk of subsidising, and perpetuating, unsustainable forms of land management. However, article 38 of the Direct Payments Regulation is not only restricted to ‘conventional’ coupled support as it provides Member States with the flexibility to channel additional funds to sectors or regions where specific types of farming are particularly important for economic and/or environmental reasons. The economic challenges facing HNV farming are well documented, as is their environmental and social value. Therefore we urge Defra to research ways in which this measure could be used to support HNV farms in England specifically for environmental delivery. 8. The Government has decided that in order to achieve the best value for money, the minimum claim size for the new scheme should be fixed at five hectares. The RSPB disagrees with Defra’s decision to fix the minimum claim size at 5ha. The RSPB acknowledges that there are issues of transaction costs for very small claimants, however farm size is not relevant to environmental potential and for some very small agricultural holdings, including some HNV farms, Pillar I payments may be the critical factor for continued active management of land and the delivery of public goods. A 5ha threshold would result in over 46,000ha of agricultural land no longer in receipt of Pillar I support and 16,000 claimants affected. Defra’s assertion that the change would have minimal impact on the environment can be challenged: a report commissioned by Defra3 identified that very small farm holdings are considerably more likely to fail GAEC standards, including several measures which are not linked to any specific UK or EU legislation, such as those relating to soil. The same study highlighted that Pillar I payments provide significant leverage to make farmers comply with legislation and other environmental requirements, via the cross compliance inspection regime and the associated risk of payment deductions in cases of breach. Therefore, removing this leverage from the subset of farm businesses that are at most risk of breaching environmental standards seems perverse. This change may save the RPA time and money in terms of processing small claims, but the environmental and wider costs could very well be significantly more costly to address. 3
ADAS, CSL & CCRI (2009) Evaluation of cross compliance 9 We therefore urge Defra to reconsider this decision and to retain the minimum claim size at the current 1ha until thorough research conclusively identifies that a higher claim size will not lead to environmental problems. 9. The Government has decided to roll forward Single Payment Scheme entitlements into the new scheme. The RSPB supports this decision. 10. Ministers have decided to adopt a threshold of €5,000 for the purposes of applying the negative list, in order to minimise administrative burdens for farmers and the RPA. The RSPB has no comments on this decision. 11. Do you support our preferred option not to extend the list of ‘negative activities’ forming part of the active farmer test?  The negative list should not be extended.  The negative list should be extended.  Please comment further if you wish, or explain what types of businesses should be added to the list and why. The RSPB supports Defra’s preferred option not to extend the list of ‘negative activities’. The RSPB shares Defra’s concern that “Given the diversified nature of English agriculture there is a risk of inadvertently capturing under an extended list a large number of farmers who are genuinely farming their land”. Therefore we support Defra’s preferred option not to extend the list of ‘negative activities’. However, the risk that the active farmer test will capture genuine farmers applies equally to the Commission list, which Defra have no flexibility to alter. It is therefore extremely important that Defra ensures that they inform organisations that they might be on the negative list as soon as possible to allow those organisations to consider their options and for those that are conducting genuine agricultural activities on their land holdings but are captured by the negative list, the ability to appeal the decision and become re‐eligible in a simple, quick and efficient manner. 12. The Government has decided that we should not operate a Small Farmers Scheme. The RSPB support this decision as participants in a Small Farmer Scheme would not be subject to greening or cross compliance requirements. 13. We must set a limit on the number of entitlements that can be claimed under the Young Farmers Scheme which must be between 25 and 90. What do you think should be the ceiling that can be claimed by an applicant to this scheme?  A limit of 25 entitlements (the lowest limit possible)  A limit of 54 entitlements (the average farm size in the UK)  A limit of 90 entitlements (the highest limit possible)  Another option 10 The RSPB has no comments in this section. 14. Our preferred option is not to require those seeking to participate in the Young Farmer Scheme to meet additional eligibility criteria. Do you agree?  We should not add additional criteria  We should add additional criteria.  Please comment further if you wish, or explain what additional criteria you prefer. The RSPB does not agree that participants in the Young Farmer Scheme should not have to meet additional criteria. Given the range of environmental challenges facing farmland, and the need for improved understanding of the linkages between farming and the natural environment across the farming sector, the RSPB would like to see public support for new entrants and young farmers explicitly linked to environmental advice and training. Greening In our answers to this section, we seek to make the case for the use of a National Certification Scheme, but also point out where we see value in the Commission’s core proposals. An overriding consideration is that greening (however it is implemented) must complement agri‐environment schemes and not undermine them. We remain of the view that agri‐environment schemes are the single most effective tool available within the CAP to meet biodiversity objectives. Greening requirements, which have to be annual and generic, are not a substitute for agri‐environment measures. Instead the role that we foresee for greening is to raise the baseline, freeing up agri‐environment funding for more ambitious objectives. Therefore it is imperative that double‐funding rules are implemented in a way that reflects this aim, and do not jeopardise gains made to date through existing land management schemes. 15. The Government is not minded to take up the option to implement greening through a National Certification Scheme containing additional, equivalent measures. Do you agree with this approach or do you see a case for a National Certification Scheme and, if so, on what grounds? We do not agree with Defra’s intention not to make use of a National Certification Scheme. The RSPB is disappointed with the current round of reform, which has seen a reduction in the amount of money channelled to environmental improvements through Pillar II and a weakening of cross compliance rules. The RSPB’s aspiration is for the whole CAP budget to be delivered through Pillar II‐
type schemes, but while Pillar I remains we support the aim of increasing the environmental benefit it delivers. Of all the new rules and instruments proposed, we feel that greening has the potential to bring some environmental improvement. Many farmers are already doing good work for wildlife, including through agri‐environment schemes, and these farmers must not be disproportionately affected by any new greening scheme. However greening does have an important role to play in raising the baseline of environmental standards across the farmed landscape. 11 As such, we feel that there is a significant imperative for Defra to maximise the effectiveness of greening. This is reaffirmed by the fact that the payment will be worth over £400m per year in England alone. We are therefore disappointed that Defra is not minded to implement greening through a National Certification Scheme (NCS). This is an approach that the UK negotiated hard to secure, expending a significant amount of political capital in the process, and to not use it now would damage our credibility in future negotiations. More importantly though, not using a NCS will undermine the potential effectiveness of greening, and therefore the value for money that the public should be able to expect from their investment in agriculture. 16. Do you agree that this approach to the implementation of greening in England strikes the right balance between environmental benefit and administrative cost, in the context of our approach to the CAP Reform package as a whole? No, the RSPB does not agree. Environmental effectiveness should be the guiding principle when approaching the implementation of greening in England. Whilst administrative cost should be proportionate to the possible level of benefit, it seems apparent to us that Defra’s approach to greening wilfully prioritises cost efficiency over cost effectiveness. This approach jeopardises the possibility of achieving genuine value for money from the billions of pounds of public money to be spent through Pillar I over the next CAP period. In the case of Pillar I greening, we also do not feel that there is any intrinsic conflict between simplicity and effectiveness. As indicated above, we favour the use of a National Certification Scheme as an implementation mechanism for greening over the Commission’s core proposals. Given the complexity of the latter, with the range of exemptions, varying thresholds and uneven geographical application, we believe that a bespoke Certification Scheme has the potential to both simplify greening and increase its potential to deliver meaningful environmental outcomes. In terms of implementation, we also strongly believe that Defra should not compare the implementation costs associated with the Single Farm Payment to date with the future implementation of the greening payment. The two differ fundamentally given the focus of the latter on improving the overall environmental performance of the CAP. If its implementation is merely thought of in terms of cost efficiency as opposed to cost effectiveness, Defra will miss a crucial opportunity to make good on its long‐term ambition of shifting the CAP to a policy more focused on the provision of public goods. It seems that this opinion is mirrored in the European Council paper on the simplification of the CAP4, to which the UK was a signatory. This clearly states that “Any increased cost or complexity to specific measures can only be justified where the benefits outweigh the costs” and that, “An acceptable justification for increased cost might include better targeting of funding towards the provision of public goods...” We feel that introducing a meaningful and effective approach to Pillar I greening would meet both these criteria. 4
Council of the European Union (2011) Simplification of the CAP beyond 2013. Brussels. 12 17. Making available the full list of proposed Ecological Focus Area (EFA) options would enable the EFA requirement to be met without the need for additional action. However, individual EFA options may realise differing levels of environmental benefit. Which selection of Ecological Focus Area options do you favour? The core driver and entire rationale behind the ‘greening’ of the CAP was to improve the overall environmental performance of the CAP. Intentionally adopting an approach that allows for the greening requirements to be met without need for additional action is therefore clearly unacceptable. a) Environmental benefit should be the overriding criteria Taking this into account, our starting point with all CAP payments is that they should be directed toward the provision of environmental public goods. The introduction of greening, although imperfect, gives member states and regions the opportunity to move away from a mentality of just ‘getting the money out of the door’ in the cheapest way possible, to an approach that actually secures some return for the significant public spending on Pillar I. Maximising the environmental benefits of greening should therefore be the overriding criteria. This is supported by the fact that the scale of environmental need is demonstrably greater than can be met by Pillar II mechanisms alone. An estimate produced for the Land Use Policy Group (LUPG) in 2009 found that delivering environmental policy objectives in England would cost £1,258m5 per year. The consultation document outlines scenarios with spending on land management schemes ranging from around £300m to £500m per year. Pillar I greening therefore clearly has a major role to play in plugging the gap between environmental need and the resources projected to be available for NELMS. As the projected Utilisable Agricultural Area (UAA) coverage of NELMS is 35‐40%6, it is likely that greening will have a crucial role to play in maintaining the fabric of the wider countryside, and addressing some of the needs of widespread species such as some farmland birds and invertebrates. If greening does not address these objectives, the services that these widespread species provide such as pollination of food crops will be undermined, and it is possible that Defra will be unable to meet its obligations under Article 3 of the Birds Directive7. b) ‘Gold plating’ does not apply Adopting an approach that restricts the availability of measures under the EFA article in order to ensure effectiveness should not be viewed as ‘gold plating’. Implementing an approach to greening that is first and foremost designed to be effective is not controversial, given the scale of public spending associated with the greening payment and direct payments more widely. The RSPB rejects the phrase gold plating when applied to Pillar I greening based on the fact that the greening payment is exactly that, a payment, and not a regulatory requirement. In this instance, Defra’s 5
Cao, Y., Elliott, J., McCracken, D., Rowe, K., Whitehead, J. and Wilson L. (2009) Estimating the Scale of Future Environmental Land Management Requirements for the UK. Report to the Land Use Policy Group. ADAS UK Ltd and Scottish Agricultural College. 6
Defra (2013) NELMS: a first cut. Unpublished. 7
Directive 2009/147/EC of the European Parliament and of the Council of 30 November 2009 on the conservation of wild birds ‐ http://eur‐lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:020:0007:0025:EN:PDF 13 obligation is not to farmers, but to ensuring value for money for the public purse by demonstrating environmental effectiveness. c) Choice of EFA measures should be guided by evidence of effectiveness Given the scale of need and level of spending associated with greening, the overriding criteria used to assess which measures to include should be environmental effectiveness, based on the best available evidence. Another basic principle of our approach to the CAP is that funding should be used to secure the provision of non‐marketable public goods. Applying these two criteria to the range of possible measures outlined under Article 32 would immediately rule out the inclusion of nitrogen fixing crops as a measure that may contribute toward meeting a farmers EFA requirement. As commercially grown crops that receive a return from the market, incentivising the cultivation of these would not only breach the principle of public money for public goods, but would also be questionable under World Trade Organisation (WTO) Green Box rules. Pillar I payments are made under the justification that they are decoupled income support to farmers under the Agreement on Agriculture8. These payments cannot be based on “factors of production employed in any year”. In Annex 1 below we have also attempted to assess the current area covered by the possible interventions listed under the Ecological Focus Area article in England. In 2012, the proportion of croppable land covered by leguminous crops was 2.6%. When this is combined with the area of uncropped land, which was 2.8% in 2012, then the area of the two already exceeds the 5% requirement for EFAs, rendering the potentially most effective greening measure largely redundant in terms of providing additional benefits. The extent to which allowing leguminous crops would undermine greening’s potential effectiveness is highlighted by the fact that as recently as 2010, these crops comprised 4.5% of croppable land in England. Table 2 in Annex 1 looks at the impact of removing short rotation coppice for similar reasons to those posed above, and also afforested areas (the inclusion of which gives rise to questions of double funding). Even with these removed, the area currently covered by uncropped land and landscape features is still between 3.6 to 5% of croppable land. Given this, we would suggest that any measures included as eligible for the EFA measure should be limited to these two rough categories, with further refinement needed to ensure effectiveness. On the basis of this and the following analysis, we would not wish to see the following options included within EFAs:  Areas with nitrogen fixing crops. Such crops provide limited biodiversity benefit. Mass flowering crops grown in monoculture provide pollen and nectar in a short, synchronous pulse which is unlikely to provide sufficient nutrition for pollinator species active throughout the growing season9. Whilst not a nitrogen fixing crop, one study identified that mass‐flowering oilseed rape had a beneficial effect on bumblebee colony growth, but this did not translate into a greater likelihood of 8
Paragraph 6, Annex 2, WTO Agreement on Agriculture Carvell, C., et al., Comparing the efficacy of agri‐environment schemes to enhance bumble bee abundance and diversity on arable field margins. Journal Of Applied Ecology, 2007. 44(1): p. 29‐40. Memmott, J., et al., The potential impact of global warming on the efficacy of field margins sown for the conservation of bumble‐bees. Philosophical Transactions of the Royal Society B‐Biological Sciences, 2010. 365(1549): p. 2071‐2079 9
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colonies producing sexual offspring. The authors propose that this may be due to food scarcity later in the colony cycle10. Any given crop grown in monoculture can only provide pollen and nectar resource for a small number of pollinator species. For example field beans have flowers that only pollinators with long and strong mouthparts can access11. Harvested crops can generally only provide foraging for pollinators, whereas areas managed specifically for wildlife can also potentially provide nesting and overwintering sites12. Furthermore there is not a clear case for public spending to incentivise planting these crops, since they are sold on the market and also bring agronomic benefits (nitrogen fixation). Areas with catch crops or green cover. These features only provide biodiversity benefit for a small portion of the year, so should not attract the same greening payment as features like fallow that are present all year round. Where needed for soil protection, these features should be a part of cross compliance. We would have concerns about the inclusion of afforested areas established under rural development schemes. This could incentivise poorly sited, small scale afforestation that falls beneath the forestry EIA threshold (and so onto good quality open habitat – see also the GAEC section of this consultation), which is likely to have little biodiversity benefit. In addition, small isolated woodlands are likely to become under‐managed woods of the future due to lack of viable size. Including these afforested areas in EFAs brings no clear added benefit to those already secured via Pillar II schemes, for example meeting the UK Forestry Standard. Including this measure in greening could possibly increase the rate of planting, but we feel that the focus must be on quality, not quantity, of planting. We cover those EFA measures that we feel hold potential in our answer to question 18. d) Permanent pasture and scope for flexibility The scope for flexibility to get the most from the Commission’s core proposals does not just apply to EFAs; there is also significant potential to improve the performance and value for money associated with the permanent pasture measure. The final text of Article 31 requires member states to identify “permanent grasslands which are environmentally sensitive” inside Natura 2000 sites, a requirement which we welcome. However, the article also states that – “The Member States may, in order to ensure protection of environmentally valuable permanent grasslands, decide to designate further sensitive areas situated outside areas covered by Directives 92/43/EEC or 2009/147/EC, including permanent grasslands on carbon rich soils.” We urge Defra to use this opportunity to afford protection to the large areas of undesignated but ecologically valuable permanent grassland that have for a long time received inadequate levels of protection. 10
Westphal, C. et al. (2009). Mass flowering oilseed rape improves early colony growth but not sexual reproduction of bumblebees. Journal of Applied Ecology 46:184‐193 11
Carré et al. (2009). Landscape context and habitat type as drivers of bee diversity in European annual crops. Agriculture, Ecosystems and Environment 133: 40‐47 12
Ibid. 15 18. There is a particular interest to see benefits for pollinators arising from the implementation of greening. Are there any practical Ecological Focus Area options, or enhancements of these options, which could be easily adopted, have a high likelihood of uptake and which would be particularly beneficial for pollinators? Our assessment of the evidence suggests that the benefits for pollinators arising from the measures listed under the Ecological Focus Area measure would be limited without additional management.  Land lying fallow: the value of fallows to pollinators depends on their age and how they are managed13. Pollinator numbers (bees and butterflies/moths) are greater on two‐year old fallows, compared to one‐year old fallows. Pollinator densities are highest where flower densities remain high, which may be achieved by sowing seed mixtures containing non‐competitive grasses or by limited, mid‐summer mowing (for bees but not butterflies/moths) to prevent competitive grasses taking over. If Government chooses to implement Commission’s basic three options, fallow should be included within EFA and its management enhanced through voluntary measures (promoted by the CFE) and agri‐environment payments.  Buffer strips: grass buffer strips support higher numbers of bumblebees than the crops they replace, but their utility is greatly enhanced by the presence of flowers or sources of pollen and nectar14. Buffer strips quickly become grass‐dominated in the absence of management (cutting, grazing), reducing flower production to levels that cannot support foraging bumblebees. Margins planted or managed specifically to maximise flower production support significantly greater densities of foraging bees15. Unmanaged grass buffer strips can also provide valuable breeding habitats for bees as well as grass‐feeding butterflies and moths16. The Merckx study also showed that wider buffer strips (6 m rather than 1m) are more effective for increasing moth diversity. Narrow, grass dominated field margins will therefore provide some additional resources for pollinators, but more substantial benefits for pollinating insects requires the sowing of flower‐rich, or pollen and nectar rich, margins managed by regular cutting or grazing. Again, we feel the inclusion of this measure within EFA would be beneficial, but its value could be greatly enhanced through more specific management requirements.  Landscape features: hedgerows can enhance numbers and diversity of bees, especially if allowed to flower17. Reduced trimming may increase flower production and support more bees, but its effectiveness has not been measured18. Moths/butterflies that breed in hedgerows are negatively impacted by trimming, though infrequent trimming (>1 year intervals) or avoiding sensitive times of year (e.g. late winter) can ameliorate losses19. Retaining hedgerow trees increases diversity of moths20. Therefore the inclusion of hedgerows within eligible EFA features, potentially with a requirement to trim no more than a third or half of hedgerows in any one year, would be beneficial. This brief assessment of the benefits provided by buffer strips, fallows and hedgerows suggests that they will provide a level of benefit, but the benefits provided for pollinators would be significantly 13
Gathmann (1994) Oecologia 98, 8‐14. Steffan‐Dewenter (2001) Ecography 24, 83‐93. Kuusari (2011) AGEE 143, 28‐36. Pywell et al (2012), Wildlife‐friendly farming benefits rare birds, bees and plants, Biology Letters, published online. 15
Carvell (2007) J Appl Ecol 44, 29–40. Potts (2009) J Appl Ecol 46, 369–379 16
Lye (2009) Biol Cons 142, 2023‐2032, 101–107. Potts (2009) J Appl Ecol 46, 369–379. Merckx (2012) J Appl Ecol 49, 1396–
1404 17
Hannon (2009) Biol Cons 142, 2140–2154 18
Dicks et al (2012) Bee Conservation: evidence for the effects of interventions. www.conservationevidence.com 19
Defra project BD2012 20
Merckx (2012) J Appl Ecol 49, 1396–1404 14
16 increased if a certain level of management were undertaken to enhance their effectiveness. This would be best achieved through the adoption of a National Certification Scheme. To be meaningful, any pollinator‐focused measures within greening must be part of coherent action to reverse pollinator declines, which Defra is currently developing through the National Pollinator Strategy. This strategy must include the continued prohibition of neonicotinoid use on crops that attract pollinators, pending further research to understand and mitigate the risks. 19. Would these options be deliverable within the approach set out in the direct payments Regulation or would they need to be implemented through a National Certification Scheme? As stated above, we believe that the use of a bespoke National Certification Scheme has the potential to both simplify greening and increase its potential with regard to the delivery of meaningful environmental outcomes. We have described in the previous question how some of the basic measures could deliver some limited value for pollinators, and how enhancing them could deliver much greater benefits. If Government decides to take the approach set out by Commission, these enhancements could only be delivered through voluntary approaches (exhortation of farmers through the Campaign for the Farmed Environment) or agri‐environment options designed to build on the basic greening options. The former has no guarantee of delivering results, while the latter uses agri‐environment funding that could be better spent on more ambitious schemes. A National Certification Scheme offers the opportunity to design these enhancements in from the start, so that the greening scheme would consist of a set of evidence‐based measures that can deliver real benefits for pollinators and other wildlife. The Environmental Land Management packages of measures for arable and lowland livestock farmers21, developed by the Voluntary Initiative, could readily be adapted to form the basis of a National Certification Scheme. These packages were developed by the farming industry with technical input from conservation organisations, and are thus already supported by a wide range of stakeholders. Further to this, it is possible, albeit with Delegated and Implementing Acts still under development, that a National Certification Scheme could be developed to provide a better ‘fit’ with current and future Pillar II land management schemes. Achieving the best fit possible between Pillar I greening and agri‐
environment schemes should be an absolute priority for Defra. Getting this interaction wrong risks undermining the advances made to date, and could jeopardise the viability of many existing schemes, thus eroding the confidence of the farming community in future schemes. Cross compliance 20. Are there any GAECs that you think should not be carried forward and included from 2015? If so, what are your reasons and evidence for this? GAECs provide a basic standard of environmental protection in return for large payments of public money. The RSPB is strongly opposed to any watering down of the level of protection provided. First, we note that in the EU‐level negotiations cross compliance has already been watered down significantly. In addition to the removal of SMRs as noted in the consultation paper, articles from the 21
See www.farmwildlife.info 17 Birds and Habitats Directives have been removed from cross compliance. These relate to deliberate killing or disturbance of wild birds and protected species of plants; to the requirement for national authorities to assess plans and projects not directly connected to the management of a Natura 2000 site but likely to have a significant effect, and to mitigate for any damage to the Natura 2000 site if the work is authorised. Although Defra is not able to alter the SMRs as set out by Commission, this changed baseline must be taken into consideration as part of the overall implementation of the CAP. GAECs provide a basic standard of environmental protection in return for large payments of public money. The RSPB is strongly opposed in principle to any watering down of the level of protection provided. In particular, a low breach rate on any current cross compliance rule is not a valid reason to remove that rule. A low breach rate could be due solely to a low level of detection, or it could be that the rule is acting as an effective deterrent and removing the rule would lead to environmental damage. Furthermore, cross compliance represents the baseline above which agri‐environment payments can be made. Lowering this baseline, so that measures which were previously a requirement become eligible for payment, would represent an extremely poor use of public money. 21. Are there elements within any GAEC that you think should or could be changed, implemented better, or excluded? If so why? Cross‐compliance generally, and GAECs in particular, require better implementation, enforcement and monitoring given the scale of public funding that will continue to be dedicated to the Basic Payment Scheme. We welcome Defra’s intention to consult on the detailed content of GAECs in 2014 (consultation document page 34) and will input further at that stage. We suggest that this review must include implementation, enforcement and monitoring of cross compliance as well as content. This is particularly important in the context of Government’s interest in using ‘earned recognition’ to reduce inspection rates for some farmers. We note that the new framework for GAECs, as in the current programming period, allows considerable scope for interpretation, potentially allowing Government to tailor GAECs to suit the English situation and deliver an increased level of environmental public goods. For example, the new GAEC 6 specifies ‘maintenance of soil organic matter level through appropriate practices...’ The Impact Assessment (page 24) highlights the current costs of soil degradation in England and highlights the need for improved soil management practices. The new English GAEC on soil organic matter, if appropriately designed could make a significant contribution to meeting this need. As a general point, GAECs need to be reviewed in light of other changes proposed across the CAP. For example, we have highlighted elsewhere in this response our concerns about increasing payment rates to SDA farms without any additional environmental conditionality. The new GAECs should provide a level of protection for upland habitats otherwise at risk of intensification. Similarly, we note that ‘protection of permanent pasture’, formerly a compulsory GAEC, has been converted to a greening measure. This makes it all the more important that the most environmentally valuable pastures are adequately protected through greening and the Environmental Impact Assessment regulations. We would like to make the following specific comments on existing GAECs: 18 
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GAEC 1, soil protection review. It is not clear why maize stubble is excluded from the ‘post harvest management of land’ requirements. Maize is one of the most susceptible stubbles to soil erosion. Maize stubble management options are currently provided through Environmental Stewardship, which appears to be a poor use of public money and not in line with the polluter pays principle. As a separate point, anecdotally soil protection reviews are being carried out to a very low standard, if at all, suggesting that implementation of this option need to be revisited. GAEC 5, Environmental Impact Assessment. There is clear evidence that the Environmental Impact Assessment (Agriculture) (England) Regulations are failing to protect the remaining resource of semi‐natural grasslands – rectifying this failure should be a priority for Government as these habitats support many priority species and provide essential services for society such as carbon storage and water quality benefits. The 2 hectare threshold for the regulations should be reduced as it excludes a significant proportion of England’s semi‐natural habitats. Grasslands and other habitats that do not qualify on grounds of habitat quality should be regarded as ‘semi‐natural areas’ if they support populations of, or provide conditions for, priority species. There is an urgent need for an inventory mapping the extent and quality of semi‐natural grassland in England. GAEC 10, heather and grass burning. The content of this GAEC is fine, in line with the Heather & Grass Burning Code. However there does appear to be a problem with enforcement, as burning of sensitive habitats (as defined in the code) on designated sites is routinely consented to across the Northern English uplands. Given the proposal to uplift Pillar I payments in the uplands, it is even more important this public money is used to drive and support more sustainable and sensitive land management. GAEC 12, agricultural land which is not in agricultural production. The objective of this GAEC is to prevent the encroachment of scrub onto agricultural land not currently used for production. However, there are situations when this can drive the destruction of valuable habitat. Numerous rare and threatened species are associated with scrub22. Scrub provides essential complexity in otherwise highly managed landscapes and can provide opportunities for species to shift habitats in response to changing climate23. Currently, scrub areas can be eligible for Entry Level Stewardship points (e.g. EC4) but scrub disqualifies land from the Single Farm Payment. This contradiction should be removed, with a derogation from GAEC 12 granted for all scrub which is managed for environmental objectives. Furthermore, this GAEC translates badly into the uplands with perverse environmental outcomes including scrub/gorse clearance. This issue must be addressed in the review of GAEC. GAEC 15, hedgerows. We strongly welcome the change in wording which now clearly stipulates that hedges and trees must not be cut during the bird breeding and rearing season. The current ‘no cut’ window in England is too short, covering 1 March to 31 July. This should be extended to the end of August to ensure the main breading and rearing season is adequately covered. 22
Mortimer et al (2000) The nature conservation value of scrub in Britain. JNCC report 308, Ausden and Fuller (2009). Birds and Habitat change in Britain Part 2: past and future conservation responses. British Birds 102: 52‐71 23
19 Rural Development 22. What lessons can be learned from the current Rural Development Programme? How can we build upon its successes? Whilst there are countless lessons to be learned from the current RDPE, the following cover some of the key points that we feel should be taken into account in the design of the next programme. a) There is a need for a robust intervention logic The demands on the RDPE budget are such that it will never be able to deliver all that is expected of it. This problem will only increase in the future. It is therefore critical that a robust intervention logic is adopted to ensure that the available funding is put to the best possible use. Our long‐term position is that RDPE funding should be used to secure the non‐marketable public goods that agriculture can provide to society, but which the market does not adequately deliver, and often actively works against. The Treasury Green Book24 makes clear that such market failure should be one of the key reasons behind Government intervention. Lessons from the current RDPE make it clear that of all the priorities that the programme has addressed, the environment is subject to the highest degree of market failure. We cover this issue in more detail in our answer to Question 41 in the inter‐pillar transfers section. b) Spending on the environment can create added‐value Although environmental public goods are non‐marketable, and the payments to secure them are based on income‐foregone and cost‐incurred, there are clearly defined and significant economic benefits to be derived from spending on the environment through the RDPE. This is made clear by the analysis in Defra’s Impact Assessment that accompanies the CAP consultation. However, public spending through agri‐environment schemes can also directly draw down funding from other areas, providing significant levels of added‐value. For instance, the Sustainable Catchment Management Project (SCaMP)25, a partnership between the RSPB and United Utilities (UU), has used agri‐environment schemes to effectively match‐fund £10.6m in funding from UU, securing beneficial action for biodiversity whilst improving water quality and thus reducing bills for customers down stream. Without agri‐environment and woodland grant scheme funding, the project would have been much reduced in scope, and it would have been much harder to continue farming whilst securing improved environmental outcomes. RDPE funding, and specifically land management schemes, is often utilised in this way to secure funding from other sources, providing genuine added value to the public’s investment. c) Importance of robust monitoring and evaluation We know that SCaMP has had a beneficial impact because the project was subject to intense monitoring and evaluation. This is a key lesson to take from the current RDPE – that monitoring is essential if we are to build on the strengths of the programme whilst addressing its deficiencies. For example, Defra have, 24
Available at https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/220541/green_book_complete.pdf 25
More information available at http://corporate.unitedutilities.com/scamp‐index.aspx 20 to their credit and in contrast to other UK and EU countries, invested significant amounts into the outcomes associated with agri‐environment schemes. As a consequence, we have good data on the environmental effectiveness of schemes such as HLS, and know what solutions are required to address flaws in aspects of scheme design. The investment in monitoring and evaluation should therefore allow for improvements to made to scheme design, extracting better value for money from the overall scheme spend. However, as the varying levels of confidence in Table 14 of the Impact Assessment show, this level of monitoring and evaluation has not been replicated across the programme. A key lesson for the next programme is therefore the requirement to build in from the outset a robust and comprehensive system of monitoring and evaluation to feed into future programmes, and allow for iterative improvements to be made. d) Importance of continuity The next RDPE will clearly not be starting with a clean slate. Specifically, we have 25 years of experience with agri‐environment schemes, and many current scheme agreements will run right through the next programme to 2020 and beyond. Many farmers and land managers will have had multiple agreements under previous schemes such as Countryside Stewardship (CSS), the Environmentally Sensitive Area Scheme (ESA) and HLS, and retaining their confidence in any future schemes will be critical to their success. A key lesson to take forward to the next programme therefore is the importance of continuity and where it has to occur, well managed change. This will be of particular importance with regard to NELMS, where the necessary move to a more targeted and outcome focused scheme will be step change, especially for those entering the scheme from ELS. It is critical that where high quality outcomes are already being achieved that these are continued, and that where there is a willingness to engage with the scheme, the change from an open to all scheme to one that is more competitive is managed so as not to erode the faith that the farming and land management community have shown in the schemes to date. e) The need for evidence based interventions Building on the point about monitoring and evaluation, it is critical that all interventions in the next RDPE are evidence‐based. Evaluation studies of Environmental Stewardship show clear and large benefits for wildlife (plants, bees and birds; common and rare species) where evidence‐based options were implemented by landowners on ordinary farmland26. Evidence‐based options brought about a 10‐
100 fold increase in the species‐richness of rarer taxa. Another study has found that the deployment of evidence‐based options as part of HLS agreements has resulted in large and rapid increases in the abundance of five priority farmland bird species (grey partridge, house sparrow, tree sparrow, yellowhammer, reed bunting); in‐field species were not impacted due to a low uptake of evidence‐based in‐field options27. However, more general options had much less of an impact than evidence‐based options. Although ELS management has had positive impacts on the population growth rates of target farmland bird species, this only occurred in the minority of localities where uptake of key options providing winter seed 26
Pywell et al (2012), Wildlife‐friendly farming benefits rare birds, bees and plants, Biology Letters, published online. Bright et al., RSPB/NE unpublished report 27
21 resources was at a sufficient scale. Uptake of these key options has been inadequate in most areas and consequently ELS has not had any demonstrable impact on farmland bird populations at the country scale28. This evidence suggests that in order to recover depleted wildlife populations on farmland, the next RDPE needs to ensure adequate uptake and funding of key evidence‐based options known to provide resources and habitats for priority species and taxa. This suggests that NELMS should prioritise targeted interventions akin to HLS. Although the evidence suggests the need for wide scale action, and therefore a tiered approach in terms of scheme design, the middle, area‐specific element of NELMS should ensure the right balance of interventions to deliver the environmental outcomes needed. NELMS needs to incentivise change, rather than rewarding the continuation of Business as Usual where that continuation does not provide genuine public goods. For instance, whilst payments to maintain irreplaceable priority habitats such as upland hay meadows are clearly justifiable, low input grass options have been widely recognised as ‘deadweight’29. f) Advice and aftercare – delivery is as important as design Another key lesson from the current RDPE is that advice is critical to the success of many RDPE schemes, and particularly environmental land management schemes. Targeting to ensure good value for money is often only possible where skilled and knowledgeable advisers are able to assist in the interpretation of that targeting framework, and in the development of an agreement that will match it, and therefore deliver against the scheme objectives. The consultation makes it clear that Defra are alert to this fact, highlighting that both pre and post application advice and support are important to “...help ensure the environmental outcomes we want are delivered”. The evidence also suggests that for advice to be effective, it has to be provided by a trusted source, indicating the need for continuity of advice. This supports the continued provision of advice by permanent Natural England advisers, who are known and recognised by the farmers and land managers delivering the scheme outcomes. It is no surprise that all the evidence suggests that farmers welcome high quality consistent advice to improve the quality of the outcomes associated with their agreement. g) There is a creative tension between effectiveness and simplicity – cost effective, not least cost delivery Leading on from the previous point, it is apparent that there is a tension in Defra’s proposals between effectiveness and simplicity. For instance, the recognition that advice is of critical importance, but the apparent reluctance to then provide sufficient funding, or the desire to pursue a ‘simple’ approach to greening at the expense of maximum effectiveness. We feel that Defra should adopt an approach that is driven by cost‐effective, as opposed to least‐cost, delivery. When we compare the experience of HLS in England to that of similar ‘narrow and deep’ schemes in other part of the UK and EU, the relative effectiveness of HLS can be attributed in large part to the advice that was used to support and drive forward its implementation, which was generally lacking elsewhere. This points to the fact that cost effective delivery will require a certain level of up 28
Baker et al 2012, J Appl Ecol. 49, 871‐882 GHK, (2012) Dynamic Deadweight in Environmental Stewardship ‐ Towards a better understanding of the added benefits of the scheme. Report to Defra. 29
22 front investment to ensure overall value for money, whereas pursuing least cost delivery will inevitably jeopardise scheme effectiveness, perhaps saving a few tens of millions but risking the waste of hundreds. h) The need for targeting and an outcome focus A final and overarching lesson for the RDPE is the need to target investment, and focus primarily on priority outcomes. In terms of land management schemes, this means ensuring that funding is targeted to the areas where it can be most effective, adopting a framework for targeting that is transparent and coherent at both a national and local level. Reflecting on ELS, the lack of targeting was one of the key flaws in the scheme’s design. The targeting of HLS however was found to be on the whole fit for purpose30, albeit with the need for improvements in how the application of the scheme was prioritised within the overall targeting framework. The mix of target themes as well as target outcomes proved to be a flexible and pragmatic approach that we feel should be developed for NELMS going forward. A well targeted scheme however is of little use if it is not implemented with an outcome focus. One of the strengths of HLS was that it managed to navigate the tightrope between being too prescriptive or too flexible, allowing for individual options and agreements to be tailored, but within certain bounds to ensure a certain level of standardisation. It is important that this flexibility, supported by advice, is taken forward into NELMS to ensure that this outcome focus can be retained. The requirement in the next programme for individual options to be signed off as verifiable by the Paying Agency could potentially restrict this, and therefore restrict innovation. Defra will need to make sure that the right balance is struck to so that the outcome focus of NELMS is not undermined. 23. Are there any key areas we have missed in our assessment of need to support the new Rural Development Programme? Are there any further sources of evidence of social, economic and environmental need in rural areas for England that have not been captured? Defra’s preliminary analysis of need has identified ‘restoring, preserving and enhancing the natural environment’ as one of the three main priorities for support under the new Rural Development Programme. We fully support this conclusion, but are disappointed that the assessment of need has not also identified High Nature Value farming. Defra’s analysis has not explicitly identified High Nature Farming (HNV) as an important issue, despite this being an area where urgent action within the Rural Development Programme is needed. This is a major omission and should be rectified when Defra completes its revised needs assessment as part of the final programme document. Firstly, and as a priority, Defra must complete the HNV impact indicator, a requirement of the Common Monitoring and Evaluation Framework. If Defra does not identify the HNV resource in England, then protecting it will be extremely difficult, and render the monitoring of support measures’ impact impossible. The Scottish Government has already made considerable progress in developing a HNV farming indicator; England must now follow suit. 30
Mountford J O, and Cooke A I. (editors), Amy S R, Baker A, Carey P D, Dean H J, Kirby V G, Nisbet A, Peyton J M, Pywell R F, Redhead J W, Smart S M. 2013. Higher Level Stewardship: Monitoring, Ecosystem Services and Landscape. Natural England Research Reports, in press. 23 In England, HNV farming is mainly associated with low‐intensity livestock systems, largely (though not exclusively) in the uplands and includes priority habitats such as hay meadow, upland heath, blanket bog, woodland and mountain habitats, and support a host of our most special wildlife including black grouse, curlew, twite. Areas of HNV farming in the lowlands support nationally important species such as the cirl bunting and chough. However, due to the market failure to reward environmental public good delivery, and the tendency for Pillar I CAP payments to be directed to more productive and profitable systems, many HNV farmers struggle to make ends meet. Although agri‐environment schemes have played a very important role, they are usually insufficient to make HNV farming economically viable and as such, many HNV farmers face a choice between agricultural intensification and abandoning parts of their farms and in some cases ceasing to farm altogether, which would have disastrous consequences for biodiversity and wider environmental quality. Domestic implementation of the new CAP is a key opportunity to develop innovative ways to better support HNV land managers to modernise whilst retaining their exceptional environmental characteristics. An urgent package of support is needed, one which recognises and rewards HNV land management and seeks to improve its long term economic environmental and sustainability, through for example, support for extensive grazing , better market access, shorter supply chains and tourism. By creating and developing better markets for HNV farms to tap into, and by providing clear rewards for environmental public goods via CAP payments, the prospects of retaining their exceptional environmental value will be significantly improved. The continuation of HNV farming is also relevant to other legal requirements– for example, 20% of habitats on Annex 1 of the Habitats Directive are pastures and meadows dependent to some extent on low intensity livestock farming It is important to note that steps to improve the economic performance of England’s HNV farms would also contribute to Defra’s other priority areas for Rural Development support, particularly improving competiveness and delivering rural economic growth. We urge Defra to consider new ways to address the challenges faced by HNV farming systems, particularly the ‘European Innovation Partnership for agricultural productivity and sustainability’ (EIP) approach – see Question 38. 24. Are the areas we outline for support under the new Rural Development Programme set out above the right ones? How we can best target investment under the new Rural Development Programme to help gain the maximum value for money for UK taxpayers? We broadly agree with the areas of support, but feel that there are compelling reasons to make the environment the overarching priority for the next programme. We have expanded on these in answer to Questions 42 and 43 below in the inter‐pillar transfers section. In terms of the environmental priorities identified, we generally agree that the right ones have been identified, but feel that the need to use RDPE funding is highly variable. Specifically, we do not accept the premise that the RDPE should be the only mechanism used to address diffuse pollution from agriculture, as suggested by the scale of need estimate outlined in paragraph 6.17 of the consultation document. Again, we have expanded on the reasoning behind this in answer to question 42 below. 24 25. How might we make the process for applying for Rural Development funding simpler or less bureaucratic? How might this be balanced against the need to ensure clear accountability for public funds? Whilst it is perfectly legitimate to try and simplify the application process, the accountability of public funds must be the paramount concern when it comes to implementation of schemes within the next RDPE. The best way to ensure accountability is take steps to guarantee that the schemes are effective in achieving the outcomes required. Such an outcome focus may at times require innovation and even complexity, given that complex problems sometimes require complex solutions. In terms of streamlining the application process, there are several possible steps that may be taken, relative to existing schemes. ‐ The move to a single list of options should help to iron out the duplication that exists between ELS, HLS and HLS ‘more of the same’ options. This create complexity and confusion, and is a function of the fact that one tier is based on a tariff system, whilst the other provides a payment per option. Such a move should simplify NELMS relative to Environmental Stewardship. ‐ Environmental Stewardship currently produces one map for ELS options, and another for HLS options. A simplification for NELMS would be to ensure that all options are mapped together, simplifying and reducing the paperwork whilst aiding the applicant’s understanding of their agreement. ‐ As covered in our answer to the cross‐compliance questions, many environmental features are currently rendered ineligible for the Single Farm Payment, effectively incentivising their removal to maximise the eligible area. However, agri‐environment schemes may pay farmers to maintain and enhance the very same areas of habitat. This inconsistency is clearly nonsensical, and can erode the faith of many farmers in schemes, if for instance a feature they have retained as an agri‐environment option is subsequently identified as ineligible, thus reducing their eligible area. Such an erosion of faith can be compounded by the fact that the ineligibility is often identified following analysis of satellite imagery, which will frequently lead to features being identified as ineligible when in fact they are not. Defra should take steps to remove this perverse inconsistency through its development of cross‐compliance and greening measures in the next CAP period. This would be a significant simplification. Whilst these are administrative simplicities that could be made without any real adverse effects, we would be deeply concerned if steps were taken under the guise of reducing bureaucracy that actually led to a reduction in accountability. For instance, a shift to earned recognition for compliance monitoring could lead to a reduction in the accountability of public spend when there is little evidence to suggest that the approach being suggested is fit for purpose. One important step that could be taken is to increase the knowledge of those inspecting agreements so that they are able to adopt an outcome focus, as opposed to the current approach whereby a minor unintentional breach of an agreement based on a misunderstanding can lead to significant penalties. One common theme from farmers is that participation in agri‐environment schemes conveys a high risk of compliance failure – with significant consequences for their farm payments and future inspection rate. Scheme compliance inspections should be focused on outcomes rather than process. This requires 25 compliance inspections to be delivered by a competent authority, backed up by appropriate levels of training and development. Another clear step that can and should be taken to improve transparency and accountability is to make sure that details are made public of all CAP payments, in a way that is easily understandable and accessible. 26. What are your views on the structure of the proposed new environmental land management scheme, in particular the new “landscape scale” approach? We have been supportive of Defra’s approach to developing a New Environmental Land Management Scheme (NELMS), and believe that the proposed structure goes some way to addressing the flaws associated with Environmental Stewardship. a) Site specific agreements We strongly support the retention of a targeted upper‐tier, and urge Defra to retain the best of Higher Level Stewardship (HLS), including the outcome focus, flexibility and advice that have been so important to its success. In terms of the priorities for this site specific element of NELMS, we also believe that whilst SSSIs will clearly be a key priority, certain priority habitats and species should also be targeted by this tier. For instance, priority habitats subject to low levels of designation, such as woodland, wet grassland and newly created reedbed, may require the tailored management and intensive advice that the middle tier of NELMS may not be able to provide. Similarly, many priority species will require complex management not necessarily limited to designated sites, such as complicated water level management associated with management for breeding waders. The criteria guiding the priorities for this site‐specific element of NELMS should be guided by environmental need before any other consideration. b) Area specific agreements In terms of the more novel area‐specific element, we have to date been strongly supportive, and see the intention to adopt “selection criteria which favour the right choice of options” as an important remedy to overcome one of the most significant flaws of Entry Level Stewardship (ELS). A landscape‐scale approach should not however be limited to this element of the scheme, but should be applied to NELMS in its entirety. This will require a single and coherent overview if we are to avoid the ‘siloeing’ that occurred with ELS and HLS. We strongly support a continued and central role for Natural England in the delivery of NELMS, and they should be provided with the resources necessary to make sure that applications for the middle tier are coherent with those that are being developed for the more site‐specific upper tier. If this is achieved, then the Lawton vision of a more resilient and coherent ecological network may be one step closer to being realised. If not, we are likely to see a disparate implementation of NELMS, which does not make the most of the ecological connections between holdings. 26 The targeting and selection criteria used for this element of NELMS will be of paramount importance to its success (or otherwise), and we look forward to working closely with Defra to develop these aspects of the scheme. 27. Do you agree that we should not be prescriptive about how groups of farmers or land managers could be brought together to deliver landscape scale agreements under the proposed new environmental land management scheme? We agree that there should be no set template or preferred model for how groups of farmers could come together, but would encourage Defra to provide a set of minimum standards for those applications requiring funding for facilitation. Our experience has shown that in some areas, a collaborative project may be fairly small in scale, with personal as well as ecological connections developing between the holdings. Alternatively, farmers may be collaborating toward the same outcome but never meet, and be dispersed across a wide area. What is important is that the scale of delivery proposed by a group of farmers or land managers is sufficient to deliver the stated outcome, or at least has the potential to reach this point. Two examples of group working are outlined in Boxes 1 and 2. Box 1 – Thorney Farmland Bird Friendly Zone The Thorney Farmland Bird Friendly Zone (TFBFZ) is a farmer‐led project in the Cambridgeshire Fens, just north east of Peterborough, supported by advice from the RSPB. The project involves 16 farmers across over 3800ha of farmland using HLS and ELS agreements to support nationally ] important populations of range restricted species such as the corn bunting, tree sparrow and yellow wagtail. Each of the farmers in the project delivers the farmland bird package, dedicating between 3% and 10% of their farm to options that provide the ‘Big 3’ for farmland birds. In order to maintain and foster a sense of collaboration and share best practice management and common experiences, the farmers involved in the project meet together once a quarter. This provides the opportunity to reflect on the progress made, make plans for the future and also the chance for RSPB and Natural England advisers to provide advice and support in one ‘hit’. The aims of the project are to provide the needs of priority species alongside profitable and productive farming, whilst making sure that the farmers are very much in the driving seat. It is important to note that we are not talking about a blank canvas. Many areas will have HLS agreements running right through the next programme, and it is important that any mechanism to implement NELMS and assess the integrity of a group proposal takes account of existing activity. For instance, the project outlined in Box 1 is based around a number of existing HLS agreements opened between 2009 and 2013. However, there is still scope for growth within this project, and it is feasible that individual applicants to NELMS could effectively join the group, but as separate agreements started at a later date, as opposed to applying in direct conjunction with others. The development of this project raises a final point about group working, in that in many cases, projects need to be given time to grow and evolve. Any assessment of group application should therefore take into account the scope for growth. Whilst we recognise that this may be difficult in practice, especially if 27 the application process for the middle tier is largely IT driven, it is essential if this approach is to work in the ‘real world’. Box 2 – Forest of Bowland breeding wader project The Forest of Bowland breeding wader project aims to safeguard one of the most important upland wader populations in the country. Working with Natural England and others, the RSPB has provided targeted advice to farmers and land managers to deliver habitat for waders using three key HLS options – HL7 (yellow dot), HL8 (red dot) and HK11 (orange dot). Whilst the farmers in the project area are not necessarily working together in person, they are all collaborating to deliver a shared objective. Monitoring for lapwing breeding success between 2006 and 2010 revealed that productivity was highest on farms in HLS that received follow up advice and aftercare, revealing the importance of advice to achieving high quality outcomes. 28. How could we help facilitate landscape‐scale approaches under the proposed new environmental land management scheme? We welcome the focus on landscape‐scale outcomes, and feel that this is critical if the recommendations of the Independent Panel on Forestry31 and Making Space for Nature32 report are to be realised. 31
Independent Panel on Forestry (2012) Recommendation 9 – “One of the key recommendations by the Independent Panel on Forestry was that, “Government should ensure that land use creates a coherent and resilient ecological network at a landscape‐
scale, by integrating policy and delivery mechanisms for woods, trees and forests in line with the principles set in the “Making Space for Nature” report.” https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/183095/Independent‐Panel‐on‐Forestry‐
Final‐Report1.pdf 28 The practicalities of facilitation represent a real challenge to the successful implementation of NELMS. Inevitably, there will be many existing projects and groupings that will be able to facilitate entry into the scheme for a large number of farmers, but incentivising this in areas where this is lacking will demand ingenuity and may take time. We initially suggested a slimmed down version of the Nature Improvement Area (NIA) approach, providing a fund within the RDPE that projects could bid into to secure funding for facilitation. An alternative approach would be to provide a small payment to individual agreement holders to ‘buy‐
in’ facilitation to assist with the application process and coordination between agreements. This would be more likely to secure the support of the farming community, but would require farmers to communicate with one another, something that may depend on existing relationships and linkages. In reality, what may be required is a combination of the two, with local Natural England teams providing a small amount of funding to a farmer or third party who has secured the buy‐in of a group of farmers to work to expand the project. A proposal could then be presented to Natural England at an initial expression of interest phase, and then payments made to the individual farmers within the grouping to provide to the facilitator (or other party) to draw up the applications in line with a pre‐agreed set of priorities for the group. This approach could be of particular use on large Commons, which have historically presented some the most challenging areas to enter into schemes, but often have well organised federations and associations that may provide an existing body with which to work. Care would need to be taken to ensure that the expense of this approach was balanced against the potential benefits, recognising that a payment may not always be required to realise coordination, or that below a certain group size or complexity threshold, a payment may not be warranted. 29. Should we offer a capital only grant as part of the proposed new environmental land management scheme? We remain sceptical of the benefits of a stand‐alone capital grant scheme, and believe that the available budget would be better deployed as part of multi‐annual agreements. We have always felt that capital items are only suitable when supported by direct advice, as without it, the scope for misapplication of capital items and perverse effects may potentially outweigh the benefits (e.g. inappropriate woodland/hedgerow planting). As the consultation makes clear that this direct advice will not be provided, we feel unable to support the inclusion of a stand‐alone capital grant scheme in NELMS. We would also question the utility of such a scheme, given the lack of targeting associated with it (it will be first come first served), and the potential opportunity cost it could have with regard to the scheme as a whole, which will inevitably operate within a finite budget. 32
Lawton, J.H., Brotherton, P.N.M., Brown, V.K., Elphick, C., Fitter, A.H., Forshaw, J., Haddow, R.W., Hilborne, S., Leafe, R.N., Mace, G.M., Southgate, M.P., Sutherland, W.J., Tew, T.E., Varley, J., & Wynne, G.R. (2010) Making Space for Nature: a review of England’s wildlife sites and ecological network. Report to Defra. 29 30. Do you agree with the principle that five‐year agreements should be the norm under the new environmental land management scheme? We disagree with the presumption in favour of five‐year agreements, and feel that the duration of agreements should be dictated by its target outcomes. In some cases, a five‐year agreement may well be sufficient, and in the case of tenant farmers on short duration tenancies, all that can be achieved. However, in others the agreement will need to be longer. For instance, any agreements which have significant levels of habitat creation are likely to need at least 10 years to be effective, for example in the case of the creation of woodland, restoration of blanket bog and restoration or creation of species rich grassland.33 This is echoed by the recommendations of Making Space for Nature34, which suggested that the length of HLS agreements at ten years was still insufficient. Recommendation 15 stated that “...Consideration should be given to improving the quality of advice and putting longer term agreements in place to ensure sustained ecological benefits, while retaining the buy‐in of land managers.” It is essential therefore that there is a transparent and standardised process in place to assess whether an agreement should be five years or longer, dictated by the needs of the environmental priority in question. 31. What approach should we take to targeting the new environmental land management scheme? We fully support Defra’s aim to design a scheme that is significantly more targeted than Environmental Stewardship, in particular recognising the flaws associated with ELS. There is a significant amount of evidence and experience to support a move to a more targeted scheme. The consultation states that there are two possible approaches to targeting, one using geographically defined and mapped areas, the other focusing on areas of opportunity for particular priority themes or outcomes. We feel however that the two are not mutually exclusive, and that to combine them would be to effectively embrace an evolution of the approach that has been used to date to target HLS. This combination of geographically discrete target areas and target themes offers a flexible and effective approach to targeting. If this approach were adopted, it could be envisaged that NELMS (or elements of) would be available everywhere, but on a competitive basis with more directed option choice, thus addressing the flaws of ELS and negating the need for a universal capital grant scheme. Themes could still be spatially explicit under this approach, e.g. to designated landscapes, priority catchments or priority areas for farmland birds35. Alternatively, NELMS could adopt selection criteria based on willingness to meet a certain package of measures, e.g. the farmland bird package, or collaborative working within a priority catchment. This approach would build on that adopted for the directed option choice trials funded by Defra36, which found that this would improve the environmental 33
Fagan, K.C. et al (2008) Do restored calcareous grasslands on former arable fields resemble ancient targets? The effect of time, methods and environment on outcomes. Journal of Applied Ecology, 45 (4): 1293‐1303 34
Lawton, J.H., Brotherton, P.N.M., Brown, V.K., Elphick, C., Fitter, A.H., Forshaw, J., Haddow, R.W., Hilborne, S., Leafe, R.N., Mace, G.M., Southgate, M.P., Sutherland, W.J., Tew, T.E., Varley, J., & Wynne, G.R. (2010) Making Space for Nature: a review of England’s wildlife sites and ecological network. Report to Defra. 35
e.g. the Bird Conservation Targeting Project 36
FERA & ADAS (2013) Evaluating the impacts of limiting free choice in management option selection by Entry Level Stewardship (ELS) applicants. A report for Natural England. 30 outcomes derived from ELS. The latter would recognise the importance of an agreement holder that is motivated to achieve the outcomes required, rather than relying on a totally top down and strategic approach, as the two will not necessarily match. The approach of adopting target areas and themes would also overcome the issue of designing a scheme that was totally inaccessible to elements of the farming and land management community, which would potentially undermine faith in agri‐environment amongst the people that we need to deliver it. A decision could be made to direct an indicative proportion of funding to target areas, to ensure these priority areas received adequate funding. With regard to target priorities, clearly priority species and habitats covered by Section 41 of the Natural Environment and Rural Communities Act (2006) should be one of the main areas for targeting. There will however be species and habitats not covered by Section 41, but which are currently targets for HLS, such as snipe and redshank. The Birds of Conservation Concern provides a strong rationale for targeting those species outwith Section 4137. In terms of synergies and multiple‐objectives, we support this in principle, but would caution against trying to ensure that every agreement is multi‐objective. The evidence suggests that the most effective agreements are often those with a clear, single objective. Insisting that every agreement has to be multi‐objective could reduce effectiveness and lead to spreading resources too thinly. Not every agreement has to be multi‐objective in order to build a multi‐objective scheme. Rather, we would support a focus on synergies where it is clearly the best way of achieving value for money and a range of objectives – the uplands are a case in point here, where restoration of blanket bog for instance has significant benefits for biodiversity, water quality and climate mitigation and adaptation.38 However, there will always be instances where an agreement tailored toward a specific species or assemblage is the best way to achieve that priority outcome, and therefore value for money. Cirl buntings, stone curlew and lowland breeding waders are all examples of this. With regard to local prioritisation and targeting, we would support a greater role for local partnerships in the coordination of schemes, but strongly feel that there remains a central role for an overarching national strategy when it comes to scheme targeting. Local approaches should operate within this, and in tandem with the Delivery Body, who should retain the central role in scheme implementation. 32. With the exception of the highest priority sites, is there a case for making advice and guidance available increasingly on line or through third parties under the new environmental land management scheme? Online advice can complement but not replace tailored, face‐face advice for NELMS. As we have stressed at every opportunity, we see advice as a crucial part of the success (or otherwise) of current and future agri‐environment schemes.39 Advice is not a ‘nice’ to have, but an essential prerequisite to the success of an agreement, and should therefore not be categorised as an administration cost. This is driven by a mindset that focuses on ‘least 37
http://www.rspb.org.uk/Images/BoCC_tcm9‐217852.pdf http://www.iucn‐uk‐peatlandprogramme.org/ 39
New Environmental Land Management Schemes in England: A shared approach from Wildlife and Countryside Link (2013) 38
31 cost’ not ‘cost effective’ delivery – there’s no point saving a few tens of millions in implementation costs if it leads to poor use of RDPE funds, i.e. hundreds of millions of pounds. There is a significant amount of evidence to suggest that advice is key to successful implementation of a scheme40. The evidence that suggests targeted schemes are more effective also supports the contention that advice is critical, as a targeted scheme requires a competent adviser to be able to interpret the local priorities and develop an agreement that addresses these at the holding and land parcel scale. Schemes that have attempted to ‘design out’ the need for advice have generally shown that this is counter‐productive. For instance, many of the complexities associated with Glastir in Wales are associated with trying to develop a scheme that removes the need for one‐to‐one on the ground advice, ultimately hindering the utility of the scheme. This suggests that the quality of advice is also critical. Generic guidance is no substitute for carefully tailored advice from a trusted advisor, and we therefore feel that all agreements in the upper‐tier of NELMS should continue to operate under the model of advice used for HLS, with a one‐to‐one visit from a Natural England adviser, supplemented by third party advice. For HLS, this advisory role is critical to the development of agreement pipelines, identification of indicators of success and general cost effective implementation of the scheme. Currently, Natural England and Forestry Commission jointly provide the largest source of specialist environmental advice to farmers and land managers, a resource that could not be matched by any other organisation. This advice is also generally welcomed by farmers who, far from seeing it as a ‘burden’, appreciate knowledgeable advice from a trusted adviser. Natural England should also remain responsible for the implementation of the scheme in its entirety. We do appreciate though that it’s probably not reasonable to expect NE to expand their advisory offer to cover all elements of NELMS. There will therefore be a role for non‐governmental advisers, and we feel that the use of RDPE funding to support on‐the‐ground advisers offers an effective way to provide advice in a way that would be synergistic with efforts to facilitate better landscape‐scale working. The proposed model to incentivise facilitation could address this area of need. 33. Where should we set the scheme entry requirements (ie above the legal baseline) for the proposed new environmental land management scheme? The baseline for NELMS should not just comprise cross‐compliance, Pillar I greening and other regulatory standards, but also many elements of good farm practice. For example, we have objected to the inclusion of many of the proposed soil and water options for NELMS based on the approach that many are effectively funding good business practices, the cost of which should be internalised by businesses. These include options such as ‘Cultivations, barriers and grass strips to control soil erosion in potatoes, field vegetables and sugar beet’, ‘Equipment to Disrupt Tramlines in Arable Areas’ and ‘Compaction Removal in Improved Grassland’, all of which are explicitly covered in the Code of Good Agricultural Practice (CoGAP)41. 40
http://www.relu.ac.uk/news/policy%20and%20practice%20notes/37%20Bullock/PPN37.pdf For example, paragraph 332 ‐ “Certain crops can only be grown, and particular management practices can only be carried out, under appropriate conditions. If you exceed the limitations of your land it can lead to poor production and may cause unacceptable damage to the environment.” 41
32 To provide support for investments that should be covered by simple good practice risks an unacceptably poor use of public money, and may also distort competition within the sector. For instance, providing the same grant rate for conifer as for broad leaved tree species ignores that fact that the former are often highly commercial, essentially providing a production‐linked subsidy, something that Defra have categorically rejected in other areas of the CAP. In terms of the entry criteria for the scheme, the overriding concern should be quality of application, and its coherence with the national and local targeting frameworks. Extra weighting should be given to those working collaboratively, and also to organic applicants given the integration of organic support into NELMS. 34. Have we identified the right areas of support under the new Rural Development Programme to help improve the competitiveness and efficiency of the farming, forestry and other land‐based sectors? Are there any other areas which could be supported? The areas identified for support are broad and varied, and include areas that we would support, and areas that we do not. Areas that we would support include providing advice and support to improve environmental performance, and areas that we do not include supporting improved business management practice. Whilst the latter is clearly important, it is a cost that should be borne by the private business as part of the costs associated with running a business. This leads on to a more general point about the list of possible interventions; the need for the presence of market failure, or a complementary link to environmental or other public goods. For instance, we would support the inclusion of efforts to improve the effective operation of supply chains if this was linked into a broader package of support for High Nature Value farming. We have addressed this point in more depth in answer to Questions 23 and 38. Many of the possible investments listed would also lend themselves to the use of financial instruments such as loans or loan guarantees. The use of loan for a productive investment such as some of those aimed at improving production efficiency may improve the quality of application due to the need for a robust business case, thus providing a better use of public money. We have elaborated on this point in answer to Question 40. 35. What activities to support the farming, forestry and other land‐based sectors under the new Rural Development Programme would provide the best value for money for the UK taxpayer? We believe that the investments that provide best use of public money are those targeted at the provision of environmental public goods that are subject to high degrees of market failure. Of the potential investments listed in Section 5.55 of the consultation document, those that represent the best value are therefore those that best complement these objectives, such as – ‐ Providing support and advice to farmers to support environmental performance, including the Water Framework Directive; ‐ Supporting the woodland enterprise supply chain and venison supply chain to increase the area and benefits of woodland management. 33 That said, the potential synergies that these investments (and others like them) may have with environmental management will only be achieved if their implementation is targeted. This may be achieved through the use of innovative selection criteria. Alternatively, it could also be achieved through environment focused Operational Groups using the European Innovation Partnership. We have elaborated on this point in answer to Question 38. 36. How should we support advice and skills for the farming, forestry and land‐based sectors under the new Rural Development Programme? We support a continued role for Natural England in leading the delivery of specialist advice to support existing and future agri‐environment schemes. But we also recognise that the ambition set for NELMS potentially exceeds the capacity of Government to provide advisory support. We therefore feel that there is a role for the RDPE in supporting the provision of advice for the area‐specific element of NELMS in particular, with a focus on facilitating collaborative working between groups of farmers and land managers. This support needs to take lessons from the ELS Training and Information Programme (ETIP). ETIP was in part a function of the flaws in the design of ELS, as it focused on increasing the uptake of priority options, which the design of the scheme failed to achieve. Future advice should be more focused on the actual target outcomes, and should be provided by a trusted adviser, as opposed to a consultant on a contract who will be unable to provide follow up advice and support. This picks up on the finding of the Advice, Incentives and Partnership Approaches (AIPA) review that “delivery at a local level by trusted sources works”42. 37. How can we ensure any advice provided to the farming, forestry and other land based sectors and through the new environmental land management scheme is integrated and linked with advice provided within the industry in the light of the Review of Advice and Partnership Approaches? Environmental advice will often need to be provided by a specialist adviser, as recognised by the review of Advice, Incentives and Partnership Approaches (AIPA). A continued advisory focus on environmental outcomes is key if NELMS is to be effective. The review of Advice, Incentives and Partnership Approaches (AIPA) concluded that in order to be effective, advice needed to be targeted at clear objectives, and that incentives were more effective when coupled with advice. We feel that this supports the continued provision of specialist environmental advice in support of the implementation of environmental land management schemes. It is also worth noting that farmers and land managers do not see advice as a burden. In fact, advice is often requested by farmers, and welcomed and valued when it is received. Taking this into account, the Campaign for the Farmed Environment (CFE) has an important role to play in acting as a hub for environmental advice from industry, Government and environmental organisations. Importantly, working through the CFE, these organisations have already developed 42
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/221046/pb13900‐review‐incentives‐
partnership‐approaches.pdf 34 agreed packages of best practice environmental land management measures for arable43 and livestock44 farmers. This will help to ensure consistency of message, regardless of who is providing the advice. 38. How do we ensure innovation is considered across the breadth of the new Rural Development Programme? How could we develop proposals for an England specific European Innovation Partnership to support this? There is an urgent need for innovative action to tackle the decline of HNV farming systems in England. Such systems produce high levels of environmental social and cultural benefits alongside food production (generally extensively grazed livestock) but face significant economic challenges, in part due to the failure of CAP payments to adequately reward public goods delivery. The challenge for such systems is not to improve their environmental sustainability ‐ because they have essentially already got this right ‐ instead it is to find ways to boost their economic performance whilst retaining, indeed enshrining the very value of their approach to land management. As such, increasing intensity of production would be wholly inappropriate for HNV systems’, as this would come at the expense of their environmental ‘production’. Simply channelling more money to HNV systems is not the appropriate response: additional funding, whilst urgently needed, must be explicitly linked to the continuation of appropriate land management practices, for example, by helping HNV farmers to differentiate and add value to their products, and a broad range of measures are likely to be required. The EIP approach could provide the means to develop and test a coherent package of Pillar II support measures for HNV systems, for example combining environmental support (through agri‐environment schemes) with knowledge transfer schemes, co‐operation, investment in physical assets and food quality schemes. Operational Groups, which will be responsible for achieving the objectives of each EIP, provide an important opportunity to bring together farmers and a range of stakeholders, including researchers, advisors, NGOs, businesses and researchers. We urge Defra to consider an EIP for HNV farming systems in the next RDPE. 39. How can we strengthen LEADER’s contribution to delivering jobs and growth in rural areas? How can we make the LEADER approach more effective and deliver better value for money? Defra must take steps to make sure all LAGs reflect the principles of good governance and include an appropriately wide set of rural interests. There is an alarming degree of variability in the quality, governance and stakeholder engagement across England’s Local Action Groups (LAGs), the bodies responsible for community‐led delivery of Rural Development funding, via Leader. 43
http://www.cfeonline.org.uk/cfe_leaflet_rebrand‐web_version/ http://www.cfeonline.org.uk/assets/11723 44
35 It is vital to recognise that Leader is a multi‐objective approach and concerns rural quality of life and the environment just as much as it concerns jobs and growth. Leader should epitomise place‐based sustainable development and as such there is a need to ensure LAGs take a more holistic and balanced view to EAFRD‐funded development in their locality. Defra must therefore not place undue emphasis on jobs and growth in Leader as this could potentially undermine environmental considerations. It is imperative that projects funded through Leader represent good value for public money and deliver against wider societal interests and not simply private gain for the beneficiary. It is also vital that Leader projects support environmental protection and enhancement wherever possible and adequate safeguards and assessment procedure are in place to ensure Leader projects do not produce environmental problems. 40. What role could loans or other financial instruments play in delivering the Rural Development Programme? The RSPB believes that there could be an important role for loans to deliver environmental public goods in a cost‐effective way. Loans could, for example, be used to leverage private money on larger investments, or to split financial risk between Government and the farmer for an environmentally beneficial investment where future financial benefits are predicted but uncertain. They would seem a particularly appropriate tool in situations where an initial capital outlay is necessary to deliver both public and private benefits over the longer term. An example might be the building of an on‐farm reservoir, which would reduce abstraction pressure in that catchment (with possible environmental benefits) while benefitting the farm business. Conditions of providing a publicly‐funded loan should ensure delivery of public goods (in this case, for example, the reservoir should be designed so as to optimise biodiversity benefits as well as water storage potential). Loans could potentially be used to fund changes that make it possible for a farmer to comply with regulation, for example the building of a slurry store, but again there should be conditions attached that ensure that this funding is helping to improve the overall environmental performance of the farm, rather than supporting unsustainable systems. We agree with the view expressed by Defra in earlier communications that it would be vital to ascertain there is a real need or market failure that would necessitate using government loans rather than other market forces. Inter‐pillar transfers 41. Should we transfer funding from Pillar 1 to Pillar 2? If so, should we transfer the maximum 15% or less? We strongly support the maximum transfer of 15% from Pillar I to Pillar II, and see it as the key step in achieving anything like meaningful CAP reform in England. We therefore welcome the Secretary of State’s assertion that Pillar II “unquestionably represents the better use of taxpayers money”, and urge Government to follow through on their intention to maximise the benefits that Rural Development can deliver. 36 The RSPB and Government have shared the long‐term ambition to reform the CAP toward a policy that is focused on the provision of public goods, addressing areas of market failure that would otherwise fall by the wayside. Unfortunately, this round of reform stalled the progress that previous rounds of reform had set in train. The opportunity to transfer funding from untargeted direct payments however provides the Government with the best opportunity to maintain momentum toward this ambition, and make sure that as much public money as possible is being used to secure public goods. We have structured our argument for a maximum transfer around the economic benefits it will provide, the public demand that exists for such a move, the legal obligations and policy commitments that will be addressed by the RDPE and the scale of need associated with these commitments. a) The economic case It has long been recognised that transferring funding from Pillar I to Pillar II is the best way to realise value for money from expenditure on the CAP. The Government’s own Natural Capital Committee recently reaffirmed this when they stated that “...redirecting this expenditure [on direct income support] towards incentivising farmers to produce the things that the market will not provide...– the public and environmental goods – could increase wellbeing and potentially have knock‐on impacts for the wider economy.” 45 The Impact Assessment (IA) produced for the next Rural Development Programme for England (RDPE) also makes it clear that the benefits provided by the programme “increase the greater the level of transfer”46 with the benefits provided by a 15% transfer outweighing the costs associated with lost production by a ratio between 27:1 and 33:147. b) Public demand There is significant public demand for Government to maximise the funding available to Pillar II schemes. Our supporters have shown that they care passionately about funding for the environment through RDPs. Since 2011 37,660 have called on UK and EU Governments to build a better CAP, 40,253 votes have been cast for outstanding farmers in the RSPB’s Nature of Farming Awards and over 22,000 people from across the UK have called for an implementation of the CAP that boosts support for farmers to give nature a home, and help wildlife thrive again. Repeated surveys show that there is a willingness to pay for the public benefits that agriculture provides48 49, indicating that the public highly values the benefits that rural development funding can deliver. At a time when all public spending is under intense scrutiny, there is an expectation that Government will make the right choices to deliver the greatest public benefits from the funding available. As the Defra’s consultation document and supporting evidence paper makes abundantly clear, a full 15% transfer from Pillar I to II is the best way to achieve this. c) Legal obligations and policy commitments 45
Natural Capital Committee (2013) State of Natural Capital Report Defra (2013) Impact Assessment for the Rural Development Programme for England 2014 to 2020. Page 14. 47
Defra (2013) Implementation of CAP reform in England: Evidence paper. Page 19. 48
GHK (2011) Benefits of SSSIs in England and Wales. A report to Defra 49
Christie et al. (2011) Economic Valuation of the Benefits of Ecosystem Services Delivered by the UK Biodiversity Action Plan. A Report to Defra. 46
37 Annex A of the main consultation document50 outlines an array of major legal obligations that the next RDPE will be expected to make a major contribution toward. These legal drivers are particularly strong for the environment, with obligations associated with the Birds and Habitats Directives a key part of environmental legislation in England, in addition to those associated with the Wildlife and Countryside Act (1981) and Natural Environment and Rural Communities (NERC) Act (2006). As previous analysis from Natural England makes clear, there are few alternative mechanisms available to meet these obligations other than Pillar II funded land management schemes51. The consultation makes it clear that even with a 15% transfer, there would be insufficient funding available to meet the legal obligations and policy goals associated with biodiversity and water quality alone, let alone the other areas of need and ambition outlined in Annex A of the consultation52. We have covered this area in more depth in the answer to the following question. d) Scale of need – why 15% is essential In addition to the commitments outlined above, our analysis of the different scenarios for the RDPE outlined in Annex B of the consultation document illustrates that only 15% is enough to maintain the momentum developed by the current Rural Development Programme. Looking at the ‘balance as now’ expenditure scenarios, it is clear that a 9% transfer is only sufficient to fund existing commitments in 2015/16, with a minimal amount of funding left for new activity. This is set out in Figure 1 below. Figure 1 50
Defra (2013) Implementation of CAP Reform in England: Consultation Document. Farming and Biodiversity: understanding the potential role of CAP funding and other delivery mechanisms in delivering the Biodiversity 2020 outcomes in the agricultural environment. A report to Defra. Natural England July 2012 52
Forestry and Woodlands Policy Statement, European Landscape Convention, Uplands Policy Review and objectives associated with growth and productivity. 51
38 As Figure 1 illustrates, a 9% transfer creates a ‘pinch point’ at the beginning of the programme. This would effectively delay the start of the programme by a year, and lock Defra into a trajectory of spend on agri‐environment schemes which would leave them spending £133m less per year on land management schemes in 2020/21 than they were spending in the final year of the current programme (2013/14). This is against a backdrop of rising need associated with legal obligations over the same period. The cost of renewing all expiring existing agreements in the next programme would be around £925m up to 2020/21, assuming all were renewed with 5‐year agreements. However, the amount of funding available for new agri‐environment and forestry agreements [with a 9% transfer and balance as now focus] is £507m. This would inevitably mean that many farmers currently with agreements would not be able to access the scheme in the future. Although scheme design is likely to change, and being in an agreement now is not necessarily a guarantee of being able to access NELMS in the future, the consultation makes clear that a 9% transfer would force Defra’s hand, forcing them to restrict the availability of the scheme for financial reasons, regardless of environmental need. A 9% transfer would also significantly reduce the size of the overall programme in the next period, from expenditure in cash terms of £3.8bn now, to £3.2 billion in the future. This would be equivalent to cutting spending on rural development by over 15%, whilst direct payments were only reduced by 2% relative to 2012. This would be in effect protecting untargeted subsidy, whilst cutting the spending that all the evidence suggests provides meaningful and significant public benefit. With a 15% transfer however the budget available for schemes within rural development is more or less maintained. However, spending on land management schemes still tails off toward the end of the programme, with spending in 2020/21 reducing to £415m [under a balance as now scenario] against an annual spend in 2013/14 of £450m. This indicates that a full transfer is important from the beginning of the programme in order to re‐profile funding transferred at the beginning toward the end to maintain spending. This is illustrated in Figure 2 and Figure 3 below. Figure 2 Figure 3 39 As the first agreements under NELMS will not start until January 2016, some have suggested that a lower level of transfer may be possible at the beginning of the programme. However, Figure 3 indicates that this initial transfer is needed in order to be re‐profiled into the latter stages of the programme, and therefore maintain spending on land management schemes. Maintenance of spending is essential in this area if Government is to meet the legal obligations and policy commitments it has made with respect to the environment. 42. RDP funding can improve the rural environment, improve the competitiveness of the farming sector and productivity of the forestry sector, support growth in the rural economy, and strengthen rural communities. What priorities should we spend RDP funding on? It is our belief that the environment should be the main priority for the next RDPE. This is based first‐
and‐foremost on the fact that environmental public goods are subject to high degrees of market failure. There is therefore a compelling case to use public money to secure these public goods that the market would otherwise fail to provide. Specifically, we feel that there is a compelling case to dedicate funding to the conservation of biodiversity. Biodiversity is one of the most unambiguous of public goods, and the next RDPE will cover the critical window for meeting the Biodiversity 2020 outcomes, is the primary mechanism by which to achieve the ambitions of the Natural Environment White Paper (NEWP) and represents the Government’s best opportunity to respond to the situation highlighted by the recent State of Nature report. Unlike spending on environmental public goods, other areas of potential spend on the whole have the potential to realise a significant amounts of private gain. For instance, using public money to improve the productivity of a farming system could easily become another form of subsidy, using public money to boost private profit without a clear intervention logic driven by the presence of market failure. Although there will undoubtedly be instances where RDPE funding may justifiably be used for other objectives, we believe there to be a compelling case to make the environment the overarching priority for the next programme. In Section 4 of the Impact Assessment for the next RDPE, the Rationale for Intervention outlines a clear case for public intervention across a range of priorities. However, whilst we do not contest the validity of this rationale when testing the robustness of the case for public intervention of some kind, it does not clearly make the case or develop a clear intervention logic for the RDPE specifically. We strongly feel that the case for the environment in the most general sense as the main priority for the RDPE is clear, based on the argument that there are few alternative mechanisms to safeguard and enhance the public goods that agriculture can provide. When looking at other areas outlined in the rationale for intervention on the other hand, there seem to be several alternative mechanisms better suited to delivering that objective. These include – ‐ Agricultural research to improve the overall productivity of the sector. Alternative mechanisms included the £160m Agricultural Technologies Strategy, primarily funded by the Biotechnology and Biological Sciences Research Council (BBSRC), Technology Strategy Board, Department for 40 ‐
International Development (DfID) and Exchequer funding53. Whilst there may therefore be scope to use RDPE funding in a targeted way to add value to this investment, it is likely to be peripheral in terms of achieving the core objectives of the Agri‐Tech Strategy relative to this primary funding. Support to improve rural broadband. There is clearly a need to improve rural broadband, but this is likely to rely primarily on the £530m allocated to stimulate “commercial investment to roll out high‐speed broadband in rural communities”54. Although targeted use of RDPE funding, such as the £10m Defra has provided to the Rural Community Broadband Fund may be important, it is likely again that RDPE funding will be of peripheral importance in terms of achieving the core objective. In other parts of the rationale for intervention, it is recognised that the reason for intervention in part stems from Government failure. The classic example of this is low levels of innovation in parts of the agricultural sector due to subsidies retaining “low performing businesses in the market”. Using significant amounts of RDPE funding to address this problem is clearly not a good use of public money. However, we not feel that the difference in terms of intervention logic can be drawn simply between environmental and non‐environmental objectives. As the rationale for intervention makes clear, the RDPE can address two principal categories of market failure – 1. The provision of public goods such as biodiversity and; 2. The mitigation of negative externalities, such as diffuse pollution from agriculture. We feel that the intervention logic for the RDPE is much stronger for the former than the latter. As a ‘pure’ public good (one that is both non‐rivalrous and non‐excludable), there is a strong case to use public money to safeguard and enhance biodiversity, building on a strong legal baseline of site and species protection. This case is reinforced by the fact that few other mechanisms exists to achieve this policy objective55. The use of RDPE funding to address water quality however needs to be very carefully targeted in order to ensure that Defra does not breach the polluter pays principle, a principle that is enshrined in the Water Framework Directive56. One of the best ways to achieve this is to focus water quality interventions where they have synergistic benefits for biodiversity. Other mechanisms such as regulation, advice and potentially loans will also have a significant role to play in the improvement of water quality. 53
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/227259/9643‐BIS‐
UK_Agri_Tech_Strategy_Accessible.pdf 54
https://www.gov.uk/broadband‐delivery‐uk 55
Natural England (2012) Farming and Biodiversity: understanding the potential role of CAP funding and other delivery mechanisms in delivering the Biodiversity 2020 outcomes in the agricultural environment. A report to Defra. 56
e.g. Article 9, Recovery of costs for water services, “Member States shall take account of the principle of recovery of the costs of water services, including environmental and resource costs, having regard to the economic analysis conducted according to Annex III, and in accordance in particular with the polluter pays principle”. 41 Given the scale of need associated with biodiversity and water quality alone (outlined in Section 6.17 of the consultation and Figure 4), relying too greatly on the RDPE to address water quality objectives could have significant opportunity costs for biodiversity given the two differing intervention logics associated with these two objectives. This would jeopardise the Government’s chances of meeting its Biodiversity 2020 commitments and represent a poor use of public money given the context. 43. What proportion of RDP spend should we apply to: - Environment — agri‐environment and forestry - Farming competitiveness and forestry productivity - Growth Programme - LEADER Please explain your reasoning. We strongly support the 15% transfer, environment focused scenario for the next RDPE outlined in the consultation, relative to the other scenarios outlined (see Table 1). Table 1 – Scenarios for the RDPE 2014‐2020 Scenario Agri‐environment LEADER Farming/forestry Growth and forestry competitiveness Programme
Balance as now 83% 4% 5% 8% Environment focus 88% 4% 3% 5% Growth focus 78% 4% 3% 15% Competitiveness 80% 4% 8% 8% focus Our argument for this is based on the following reasons – - Scale of need and strength of commitment - Evidence of effectiveness - Economic benefits - Impact of spend a) Scale of need and strength of commitment It is immediately clear from the consultation that many of the strongest legal obligations and policy commitments relate to the environment. As the consultation highlights, the “...cost of meeting our environmental obligations and objectives is more than we can afford to meet through the new Rural Development Programme, even with a maximum transfer.” We have attempted to underline this fact in Figure 4, which plots the environment, balance as now and growth focus scenarios (under both a 9% and 42 15% transfer) against just the costs associated with meeting Biodiversity 2020 outcomes and Water Framework Directive (WFD) requirements57. Figure 4 Figure 4 serves to emphasise the extent to which the quantified scale of need associated with just two environmental objectives far exceeds the available budget, even under an environment focused RDPE. As the analysis that underpins these estimates makes clear, there are few other mechanisms available to achieve these objectives and obligations other than the RDPE, particularly those relating to biodiversity. This serves to highlight the importance of focusing on the environment in the next RDPE if the Government is to stand any chance of meeting these commitments, and ultimately following through on the Natural Environment White Paper’s core aim of safeguarding and enhancing our shared natural inheritance58. Focusing on biodiversity as the area with the most compelling intervention logic, analysis undertaken by Natural England59 for the Terrestrial Biodiversity Group (TBG) has found that around 68% of Section 41 species are in part dependent on agri‐environment and woodland grant schemes for their future conservation. b) Evidence of effectiveness 57
Costs for Biodiversity 2020 taken from, Natural England (2013) Statutory and policy commitments in relation to the deliveryof terrestrial biodiversity through agri‐environment schemes. March 2013, unpublished. Costs for WFD taken from the consultation document 58
Defra (2011) The Natural Choice: securing the value of nature. 59
Natural England (2012) Interim analysis of delivery mechanisms for S41 species, for TBG Dec 2012. A report for the Terrestrial Biodiversity Group. Unpublished. 43 There is a significant body of literature to suggest that well designed and targeted land management schemes supported by advice can be highly effective, and we do not intend to summarise this here60. To provide a few examples though, agri‐environment schemes have proven to be pivotal in reversing the declines of some rare and localised species such as the cirl bunting, stone curlew and marsh fritillary. There is emerging evidence to suggest that at a farm scale, well implemented agri‐environment schemes can lead to rapid and significant increases in priority species such as the reed bunting, yellowhammer and tree sparrow61, and also the first signs that they are having an effect for priority species at a landscape scale62. c) Economic benefits Environmental spending can also provide significant and meaningful economic benefits. The Impact Assessment for the RDPE finds that an environment focused RDPE with a maximum 15% transfer would provide the highest level of public benefit, with £3,222m of benefits in Net Present Value (NPV) above the baseline scenario. The next most beneficial scenario is a 15% balance as now RDPE, which would also provide the second highest level of spending on the environment. Our conclusion from this is that the more spent on the environment via the next RDPE, the higher the level of benefits provided relative to the other possible options. In earlier input on NELMS submitted to Defra alongside other NGOs63, we identified three particular areas where significant economic and ecosystem service benefits were provided by spending on land management schemes. Firstly, the available evidence suggests that agri‐environment and woodland grant schemes have provided significant ecosystem service benefits. Christie et al,64 looked at the value of Biodiversity Action Plan priority habitat across the UK. This concluded that UK BAP conservation provided benefits estimated at £1.36 billion per year. A second study calculated the cost:benefit ratio of spending on Sites of Special Scientific Interest65. This found that for the annual expense of £111 million on SSSIs in England and Wales, society derived £956 million in benefits, a cost benefit ratio of 1:8.6. Both of these estimates were based on ecosystem service benefits and ‘willingness to pay’ surveys. The latter is an important consideration given that most of the funding for SSSIs and BAP conservation is derived from the public purse, with a large proportion coming from environmental land management schemes. Secondly, there is evidence to suggest that spending on environmental land management realises tangible benefits for the rural economy. Studies have shown that agri‐environment schemes, particularly higher‐level schemes, create jobs directly and have a multiplier effect on the rural economy, especially in more remote areas66. A key contribution is to sustain the high quality rural environment 60
For example, Natural England (2009). Agri‐environment schemes in England 2009, a review of results and effectiveness., Stevens, P. & Wilson, P. (2012) Species‐rich Grassland Re‐creation Projects. A Route to Success. Aspects of Applied Biology, Pywell et al (2012), Wildlife‐friendly farming benefits rare birds, bees and plants, Biology Letters, published online. 61
Bright et al., RSPB/NE unpublished report 62
Baker, D., Freeman, S., Grice, P. & Siriwardena, G. (2012) Landscape scale responses of birds to agri‐environment management: a test of the English Environmental Stewardship Scheme. Journal of Applied Ecology 63
New Environmental Land Management Schemes in England: A shared approach from Wildlife and Countryside Link (2013) 64
Christie et al. (2011) Economic Valuation of the Benefits of Ecosystem Services Delivered by the UK Biodiversity Action Plan. A Report to Defra. 65
GHK (2011) Benefits of SSSIs in England and Wales. A report to Defra. 66
CCRI (2010), Estimating the Incidental Socio‐economic Benefits of Environmental Stewardship Schemes. Report for Defra. 44 that supports much of the English visitor economy and can be a key factor in attracting inward investment. The total asset value of a high quality countryside is very hard to estimate, though the scale of economic damage inflicted on the whole rural economy by the closure of the countryside during the foot and mouth epidemic gives an indication of its significance. Box 4 below outlines a recent example where woodland grant spending targeted at biodiversity realised significant economic benefits. Box 4 ‐ East Midlands Woodland Biodiversity Project Many woodland species are in rapid decline, such as the willow tit, an endemic subspecies in Britain, which declined by 87% between 1970 and 2005 and continues to do so. To address these, RSPB and the Forestry Commission have developed a package of English Woodland Grant Scheme (EWGS) grants targeted at woodland birds in the East Midlands (a priority area for the assemblage). The project is supported by one‐to‐one advice from the RSPB and FC, in conjunction with local land agents. In the first 3 years of the project between 2009‐2011, the grants have led to 8227ha of woodland being entered into management, providing benefits for target species. It has also led to £12m of potential woodfuel being harvested, with potential carbon savings if used as a replacement for fossil fuels of £7m. This project illustrates that significant economic benefits can arise from environmental land management. And thirdly, environmental land management can deliver important benefits for agricultural production. Agricultural production, more than most other sectors of the economy, depends upon the continued availability of some key ecosystem services, such as the pollination and pest control services provided by populations of beneficial insects. Agri‐environment schemes have for sometime been shown to be effective at addressing a range of environmental priorities, but recent research suggest that it is now possible to attribute certain ecosystem services to schemes funded under Pillar II. For example, a recent paper, Ecosystem services from Environmental Stewardship that benefit agricultural production67, demonstrates a link between Environmental Stewardship and several ecosystem services upon which continued food production depends, such as pollination, soil formation and water purification. Although a great deal more research is needed in this area, there is scope to strengthen the link between food production and environmental land management in a future scheme. d) Impact of spend and rationale for intervention As outlined in our response to Question 42 above, we are also convinced that an environmental focus represents the best use of RDPE funding, when looked at relative to other areas of funding available for Figure 2: Value of potential wood fuel produced in East Midlands before and since the project started
67
Food and Environment Research Agency (2012), Ecosystem services from Environmental Stewardship that benefit agricultural production. Natural England Commissioned Report 45 the other possible priorities. For instance, fairly exhaustive analysis by Natural England68 has concluded that there are very few alternative mechanisms or sources of funding available to secure Biodiversity 2020 outcomes other than the CAP, with a primary focus on agri‐environment and woodland grant schemes. This is reflected in the fact that Government have steadily increased their reliance on these mechanisms over the last 20 years to be able to achieve many of their environmental policy objectives and legal obligations. To take growth as another possible focus however, the RDPE is only one small fund that could possibly contribute to this objective. Specifically, the Growth Programme will be primarily funded by the European Regional Development Fund (ERDF), European Social Fund (ESF), together providing €6.2 billion to 2020. Table 2 ‐ Percentage and £m spent on agri‐environment and forestry commitments 2014‐2020 Scenario 14/15 15/16 16/17 17/18 18/19 19/20 20/21 Average
£m % 15% transfer/balance £m as now % 15% transfer/growth £m focus % 9% transfer/ £m environment focus % 9% transfer/balance as £m now % 9% transfer/growth £m focus % 15% transfer/ environment focus 481 96 475 96 468 94 476 96 467 94 459 92 527 94 512 91 496 88 443 98 440 97 436 96 505 90 482 86 458 82 415 92 400 89 386 86 490 87 459 82 429 76 394 87 369 82 345 76 477 85 442 78 406 72 377 84 346 77 315 70 470 83 431 77 392 70 366 81 331 73 295 66 459 81 415 74 371 66 351 78 309 69 267 59 487 88 459 83 431 78 403 88 380 83 358 78 However, the impact that the associated reduction in spending on environmental objectives would have on the prospects for wildlife, and following on from that the ability of Government to meet its legal obligations, would be severe. For instance, a 15% growth focus would leave 66% of the RDPE being spent on agri‐environment schemes by 2020/21, relative to 83% in 2013/14. Table 2 indicates that, in cash terms, this would be £371m per year by 2020, against the £726m a year that Natural England estimate would be required to achieve Biodiversity 2020 outcomes alone69. This £355m discrepancy between costed scale of need and spending on environmental land management would effectively spell the end of Defra’s ability to deliver against the Biodiversity 2020 outcomes, including significantly undermining the UK's ability to meet the requirements of the Birds and Habitats Directives, with an associated increase in the risk of infraction. However, under a 15% environment focus, if Pillar I funding transferred in the first few years was re‐
profiled to the back end of the programme, there would potentially be scope to dedicate £537m per year to land management schemes by 2020 (albeit as a rough estimate). Although it’s not as simple as 68
Natural England (2012) Farming and Biodiversity: understanding the potential role of CAP funding and other delivery mechanisms in delivering the Biodiversity 2020 outcomes in the agricultural environment. A report to Defra. 69
Natural England (2013) Statutory and policy commitments in relation to the deliveryof terrestrial biodiversity through agri‐
environment schemes. March 2013, unpublished. 46 saying this reduces the discrepancy between need and expenditure to £189m, as environmental land management schemes will need to address more than just biodiversity, it will provide at least some hope of meeting the Biodiversity 2020 outcomes. It also increases the feasibility of other funding mechanisms such as the Heritage Lottery Fund (HLF) and Payment for Ecosystem Service (PES) funding being able to bridge the gap. We can provide the detailed analysis done to inform this answer on request, but have not included it in this response for the sake of brevity. In terms of best use of RDPE funding therefore, we feel that to focus on environmental land management would deliver most ‘bang for your buck’ in terms of the public investment made. Market management The RSPB has no comments on this section. Summary table of main impacts of the new CAP 44. Do respondents agree with the main conclusions of the analysis in the CAP reform evidence paper and in the RDPE Impact Assessment? Overall, we think that the evidence paper and the impact assessment (IA) provide sufficient evidence to justify the decisions that have been taken. Clearly these are not exhaustive studies; for example there is a large body of detailed work on the biodiversity and environmental benefits of agri‐environment schemes which could be brought into the assessment if necessary. However we believe that the current assessment is fit for purpose and further refining it would produce diminishing returns. As a general point, we note that the approach taken in these documents is to make a purely economic assessment whereby total costs and benefits are compared (for example the analysis of greening starting on page 40 of the evidence document). However a distinction should be made between private and public costs and benefits. In some instances, it may be fully justifiable to raise private costs in order to deliver increased public benefits, for example to comply with the polluter pays principle. Applying this logic may lead to a different conclusion than simply seeking the lowest cost: benefit ratio overall. Specific points we would like to pick up:  The IA concludes from the evidence available that the Rural Development scenario that delivers the best value for public money is a 15% transfer of funds to Pillar 2 with an increased environmental land management focus. It is worth highlighting the following additional points. o The evidence for the benefits of environmental spend is much stronger than for investment in the ‘growth’ or ‘innovation’ objectives. This is partly a result of the way the previous programme was administered and monitored, but the fact remains that spending on environmental objectives is more clearly justified by the available evidence. The returns on the other two objectives are far more uncertain. 47 There are reasons to prioritise spending on the environmental objective that are not necessarily apparent from a narrow cost‐benefit analysis. A healthy environment underpins all economic activity. Protecting and enhancing the environment can have synergistic benefits for other objectives: for example promoting tourism or increasing sustainable agricultural production levels70. Investing in short‐term growth is counter‐productive if it leads to environmental degradation over the long term. o The intervention logic for the ‘growth’ objective is not entirely clear cut. The IA gives the example of the ‘free rider’ problem as a market failure justifying government intervention (page 22). However, free rider problems in practice are not as prevalent as they are in theory. Social capital and mutual reliance built between businesses enables trust to develop and co‐operative investment to flourish. Unlike a purely public good, tourism investment can be driven by private business in the right circumstances. The South West Tourism Alliance is a good example of such a venture http://www.swtourismalliance.org.uk. Economic growth in itself is not necessarily a public good; it should be viewed as a means to other ends (improved quality of life, increased investment in sustainability) and public spending should be directed with this in mind.  Page 61 – 62 of the evidence document explore possible perverse interactions between the different greening measures, and between greening and agri‐environment schemes. While this section is largely speculation on what might happen, we feel that it illustrates clearly the shortcomings of this approach to greening. The Commission’s basic measures incorporate a raft of exemptions and have different applicability to different farm types. This creates a non‐level playing field and could effectively increase complexity as farmers (understandably) seek creative ways to bypass bureaucratic requirements that bring little clear benefit to them or the environment. The RSPB strongly believes that a National Certification Scheme represents Defra’s best opportunity to design a greening scheme that will work for England.  The RSPB agrees with the conclusion that, of the three basic measures, the EFA measure has the most potential to deliver biodiversity benefits. The realisation of these benefits will depend on the inclusion of the appropriate selection of options from the Commission’s list. o Fallow: the benefits of fallow land to biodiversity are well known especially through work conducted on set‐aside. Key studies showing benefits for farmland birds include: Henderson et al, 2000,J Appl Ecol 37: 335‐347 & Buckingham et al. 1999, Bird Study 46: 157‐169. Studies showing benefits for wider biodiversity include: Firbank et al. 2003, AEE 95, 73‐85; Tscharntke et al 2011 AEE, 143, 37‐44; van Buskirk & Willi 2004 Cons Biol 18, 987‐994. o Landscape features: again, for certain landscape features there is a vast literature on biodiversity benefits. This is summarised for birds in Wilson et al 2009 Bird Conservation & Agriculture (Cambridge University Press). For examples of biodiversity benefits of hedges see Holland & Fahrig 2000, AEE 78, 115‐122 & Dover et al 2000, AEE 80, 227‐242. For biodiversity benefits of farmland ponds: Declerck etal 2006 Biol Cons 131, 523‐532. o Buffer strips: these have proven benefits for wildlife (e.g. ground beetles: Cole et al 2012. J Appl Ecol 49, 1384‐1395) including modest benefits for birds71.  In the evidence document the assumption is made that that the Crop Diversification measure will have no environmental benefits (page 48). While we agree that the way this measure has been o
70
For example, see Green Infrastructure’s contribution to economic growth: a review. A Final Report for Defra and Natural England, July 2013. 71
Vickery et al 2009 AEE 133, 1‐13 48 designed by Commission will mean that it leads to very little change to farming practices, we would challenge the assertion that ‘there is limited evidence that monocultures have a detrimental impact on biodiversity’. One issue with the evidence is that areas of mixed cropping tend to be those with smaller field sizes and larger amounts of non‐cropped habitats, so the effects of field size, cropping diversity and non‐cropped habitat are confounded. There is quite a lot of evidence linking habitat variation on farmland with wildlife variation, although much of this is associated with non‐cropped habitats rather than variation in cropping. However, evidence is available of the benefits of crop diversity to biodiversity. For example, studies72 have found higher densities of lapwing and skylark in areas with high crop diversity, and an experimental study on arable farmland in England showed increased densities of grey partridge, buntings and skylark following crop diversification73. These studies highlight the benefits of spring sown crops, broad‐leaved crops and fallows. Furthermore, monocultures are an unsustainable farming practice due to their impacts not on only biodiversity, but soil health and pest populations. The Sustainable Use Directive requires Member States to promote Integrated Pest Management, one of the key principles of which is crop rotation. Given that Commission’s greening measure is flawed, Defra should explore alternative ways of meeting this need, including implementing greening through a National Certification Scheme  With reference to the permanent pasture greening measure, the evidence document states that ‘the benefits of preventing further grassland being converted to cropland are primarily in terms of reduced greenhouse gas emissions from fertilizer use. There may also be some biodiversity benefits, but these have not been quantified.’ (page 62). We would strongly contest this attitude. Although, again, the Commission’s basic measure is not well designed to deliver for biodiversity there is scope within this measure to protect the most ecologically valuable grasslands. The biodiversity benefits of permanent pastures come primarily from high quality, semi‐natural & extensively managed grasslands74. Such grasslands are destroyed by tillage and cannot be readily reinstated: successful restoration takes decades of intensive work and is only possible if similar donor sites survive75. A broad range of declining farmland bird species specifically require high quality permanent grasslands (but not intensively managed permanent grasslands) in mixed farmland landscapes76. In mixed farmland, suitable grasslands can provide a high proportion of the invertebrate prey required to successfully rear young77. A further requirement of some declining bird species, exemplified by the cirl bunting, is the requirement for both invertebrate‐rich grasslands (supporting breeding) and seed‐rich arable habitats (to survive winter) in close proximity78. Intensively‐managed grassland generally lacks species‐richness but can provide important soil‐invertebrate resources for farmland birds79.  The evidence document makes a clear case that direct payments provide poor value for money and can have detrimental impacts. Transferring money away from Pillar I into Pillar II would not be expected to have significant adverse impacts on the farming sector, and would deliver a large net benefit. We strongly support this finding and offer additional evidence below to further reinforce these points. 72
Galbraith 1988 J Appl Ecol 25, 487‐503; Schlapfer 1988, Der Ornithol. Beob 85, 309‐371 Henderson et al. 2009, AEE 129, 149‐156 74
Vickery et al. 2001 J Appl Ecol 38, 647‐664; Buckingham et al. 2006 AEE 112, 21‐40 75
e.g. Woodcock et al 2012 Biol Cons 146, 136‐143 76
Peach 2010 Defra report BD5202, Stevens et al 2002 Biol Cons 107, 307‐313 77
Buckingham 2006 PhD thesis, Reading University; Evans, A. (1997) The importance of mixed farming for seed‐
eating birds. In: Pain,D & Pienkowski,M (eds.); Farming and Birds in Europe: the Common Agricultural Policy and its implications for bird conservation. London: Academic Press. 78
Evans (1997) The importance of mixed farming for seed‐eating birds. In: Pain,D & Pienkowski,M (eds.); 79
e.g. Tucker 1992, J Appl Ecol 29, 779‐790 73
49 45. Are there any important impacts of the CAP implementation package that have been overlooked?  The RSPB fully supports Defra in its view that coupled payments are a regressive component of the CAP, and that, in the main, such support has a high risk of subsidising, and perpetuating, unsustainable forms of land management. However, article 38 of the Direct Payments Regulation is not only restricted to ‘conventional’ coupled support as it provides Member States with the flexibility to channel additional funds to sectors or regions where specific types of farming are particularly important for economic and/or environmental reasons. The economic challenges facing HNV farming are well documented, as is their environmental and social value. Therefore we urge Defra to research ways in which the coupled support measure could be used to support HNV farms in England.  While we are broadly supportive of the intention to increase basic payment rates to SDA regions, we are concerned about the lack of environmental conditionality attached to these payments. We request that Defra carries out an impact assessment into the likely environmental and socioeconomic impacts of this payment redistribution, identifying possible risks such as inappropriate intensification of farming in upland areas, and ways to mitigate these.  Government has decided to raise the minimum claim size for direct payment to five hectares. This would mean smaller holdings would not be subject to cross compliance. While we recognise the administrative savings that this move would bring, we are concerned that no attempt has been made to assess the possible environmental impacts of this change. The consultation document notes that ‘many components of cross compliance will continue to apply under existing…law’. Before this change is made, we would wish to see further assessment of a) those elements of cross compliance which are not covered by law and b) for those which are enshrined in law, whether enforcement would be adequate to ensure environmental protection in the absence of cross compliance inspections.  The consultation document states that Government is ‘minded’ not to implement greening through a National Certification Scheme. However, while the evidence document assesses the basic greening measures (and demonstrates their extremely limited scope to deliver benefits), no attempt has been made to assess the costs and benefits of a National Certification Scheme. The RSPB believes that a well‐designed National Certification Scheme would represent far better value for public money than the Commission’s three basic measures, and urges Defra not to close off this option at this point. 46. Are there any key inputs or assumptions where better evidence is available? Negative impacts of Pillar 1 payments:  Empirical studies80 find significant capitalisation of the Single Payment Scheme in the EU, but with strong variation among regions and among farms. Each additional euro of SPS leads to an increase in land rents of between €0.06 and €0.94.  There is a wealth of evidence illustrating that ‘conventional’ coupled payments are distortionary and can have a negative impact on productivity. For example, a recent paper81 looked at the issue of agricultural subsidies and commercial farm competitiveness/productivity in the EU 15 over the period 1990–2008. The results show that: 80
See Chapter 3, Land, Labour and Capital Markets in European Agriculture: Diversity under a Common Policy. 2013. Rizov, M. et al. (2013). CAP Subsidies and Productivity of the EU Farms. Journal of Agricultural Economics 64: 537 – 557. 81
50 o
o
coupled subsidies distort farm behaviour and have a negative effect on farm productivity decoupled subsidies have a small but ambiguous effect (positive in some countries, negative in others including the UK). In general, decoupled subsidies are less distortive and can enhance productivity in some contexts. However, Pillar I payments which are explicitly targeted at environmentally beneficial farming systems (permitted under the current CAP using the national envelope/article 68 mechanism and under the new CAP using article 38 – voluntary coupled support) can be beneficial and fully in line with the ‘public money for public goods’ principle82. Positive impacts of past modulation:  A report from 2009 explored the economic, social and environmental effects of introducing compulsory modulation at the EU level.83 It finds that increased rates of modulation have a small overall net positive impact on the competitiveness of both the agricultural sector, and of rural areas, compared with the baseline scenario. The impact on agricultural value added is also very slightly positive. This is the case even without taking into account the contribution that the anticipated positive impacts on public goods and environment might make. The positive impact is mainly caused by the impacts of the availability of additional funds for Pillar 2 measures. Added value of Pillar 2 support:  The production of agricultural goods is highly dependent on the services provided by natural ecosystems84 and there is real potential for environmental stewardship to enhance a range of ecosystem services of benefit to agricultural production.85  More generally, there is a strong case to be made for providing greater support to farmers for delivering multiple ecosystem services. For example, Bateman et al. (2013) show that targeting the CAP budget so as to provide farmers with greater incentives to protect wildlife and provide other non‐market ecosystem services (public goods) could produce annual benefits of over £18 billion per year, well in excess of the current market value of agricultural output and other non‐market values provided by agriculture in the UK (£8 billion). This would have only a small impact on food production.86 82
IEEP (2008) Options for using National Envelopes in the UK as part of Common Agricultural Policy Reform Study on the economic, social and environmental impact of the modulation provided for in Article 10 of Council Regulation (EC) No 1782/2003. 84
Firbank et al (2013) Delivering multiple ecosystem services from Enclosed Farmland in the UK. 85
FERA (2012) Ecosystem services from Environmental Stewardship that benefit agricultural production 86
Bateman, I. J., Harwood, A. R., Mace, G. M., Watson, R. T., Abson, D. J., Andrews, B., ... & Termansen, M. (2013). Bringing ecosystem services into economic decision‐making: land use in the United Kingdom. Science, 341(6141), 45‐50. http://www.sciencemag.org/content/341/6141/45.full.pdf 83
51 Annex 1 – Estimating the percentage of the area of eligible arable land likely to be occupied by features and crop types eligible as Ecological Focus Area under Article 32 of the Direct Payments regulation The purpose of this Annex is to estimate the total area of eligible arable land in England that is currently covered by one of the features, land or crop types listed as potentially eligible in Article 32 of the Direct Payments regulation agreed in June 2013. For these estimates, the total croppable area is used as a proxy for eligible arable land. Land in agri‐environment scheme (AES) options has not been factored in to these estimates for the sake of simplicity, and ambiguity over how these areas will relate to greening. The following potentially eligible measures are therefore not covered by this Annex, due to there similarity to existing AES options or irrelevance to England – ‐ Art 32 ‐ Buffer strip; Uncultivated land along forest edge; Areas with catch crops of green cover; supported agro‐forestry; terraces. The total croppable area for 2012 was 4,828,00087 ha in England. The following percentages are as a proportion of this area. Land lying fallow The area of uncropped land in 2012 was 136,000 ha. This amounts to 2.8% of the total croppable area in England. Landscape features As of 2007, there was 547,000km of woody linear features in England, and 402,000km of managed hedgerow88. Given that landscape features are only likely to count toward the eligible area of the EFA if they are adjacent to arable land, it is difficult to assess the overall length/area of existing features which will be eligible from these totals. The Countryside Survey divides England into three regions89 – 1. Easterly Lowland 2. Westerly Lowland 3. Upland 87
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/183194/defra‐stats‐foodfarm‐
landuselivestock‐farmingstats‐june‐statsrelease‐junefinalengland2012‐121101.pdf 88
Countryside Survey (2007) Boundary and Linear features. http://www.countrysidesurvey.org.uk/sites/default/files/pdfs/reports2007/england2007/CS‐England‐Results2007‐
Chapter05.pdf 89
Countryside Survey (2007) England Results from 2007 ‐ http://www.countrysidesurvey.org.uk/outputs/england‐results‐2007 52 To try and arrive at a rough estimate, we have used the English Easterly Lowland totals from the Countryside Survey as a lower limit, and the totals for both the Easterly and Westerly Lowlands as the upper limit. The Uplands were discounted due to the extremely small amount of arable land in these areas. We took this approach as when you compare the distribution of these two lowland regions against the crop distribution maps produced by Defra90, there is a broad (albeit rough) overlap between the highest concentration of arable cropping for wheat, oilseed rape and barley and the Easterly Lowland area. Maize is the exception to this, being predominantly cultivated in the Westerly Lowlands. Table 1 – total lengths of woody linear features and managed hedgerows in England % of total Feature type Environmental zone Length in 2007 Equivalent in croppable (England) (000s km) ha91 area England (inc Upland) 547 109,400 2.3 Woody linear features92 Easterly lowland 264 52,800 1.1 Westerly lowland 263 52,600 1.1 Managed England (inc Upland) 402 80,400 1.7 hedgerows (as a Easterly lowland 197 39,400 0.8 subset of the Westerly lowland 195 39,000 0.8 above) For lowland England then, and using only these two main linear landscape features, the total area of landscape features is approximately 0.8 to 2.2% of the total croppable area. If other landscape features were included in this calculation such as walls and earth banks, this percentage would inevitably increase further. Areas of short‐rotation coppice In 2012, the area of short rotation coppice was 3000 ha93, or 0.06% of the total croppable area. Afforested areas The area of land afforested under the current Woodland Creation Grant as part of the 2007‐13 RDPE is 10,107 ha94. As this will presumably no longer count toward the croppable area, the percentage for this is derived from the proportion of the total croppable area plus afforested area (i.e. 4,828,000 + 10,107). 10,107 ha is therefore 0.2% of the likely eligible area. 90
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/183108/defra‐stats‐foodfarm‐
landuselivestock‐june‐detailedresults‐cropmaps111125.pdf 91
Calculated using the formula – total in km * 1000 to get total in metres. Multiply total in metres by 2 to reflect x‐compliance width of 2 metres. Divide total by 10,000 to reflect number of square metres in a hectare. 92
Note that because of the statistical model used the total woody linear features is not simply the sum of managed hedges and other linear features. For the purposes of this Annex though, managed hedgerows have been treated as a subset of woody linear features. 93
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Defra (2012) RDPE 2007‐2013 Annual Report 53 Areas with nitrogen fixing crops In 2012 the combined area of field beans, peas and leguminous forage crops was 125,000 ha95. In terms of percentage, the combined area of these leguminous crops was therefore 2.6% of the total croppable area in England. However, as recently as 2010, the combined area of these three crop types was 210,000 ha, or 4.5% of the total croppable area in that year (4,654,000 ha). Table 2 – amount (in %) of each measure relative to the total croppable area, with totals Measure % of Total % of Total % of Total % of croppable croppable area croppable area croppable area land currently eligible currently eligible (excluding (all measures) (excluding leguminous leguminous crops) crop, SRC and afforested areas) Land lying fallow 2.8 Landscape features 0.8 to 2.2 6.46% lower limit 3.86% lower limit 3.6% lower limit Areas of short‐
0.06 7.86% upper limit 5.26% upper limit 5% upper limit rotation coppice Afforested areas 0.2 Areas with nitrogen 2.6 fixing crops 95
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