27 Heol y Wig / 27 Pier Street, Aberystwyth, SY23 2LN ( : 01970 611621 :
Cadeirydd / Chair : Russel Hobson Cyfarwyddwraig / Director : Susan Evans www.waleslink.org
Response to the review of land management actions under Axis 2
of the Rural Development Plan for Wales 2007 – 2013
December 2008
Wales Environment Link (WEL) is a network of environmental and countryside Non-Governmental Organisations in Wales, most of whom have an all-Wales remit. WEL is officially designated the intermediary body between the government and the environmental NGO sector in Wales. Its vision is to increase the effectiveness of the environmental sector in its ability to protect and improve the environment through facilitating and articulating the voice of the sector.
Wales Environment Link values the opportunity to take part in this important consultation.
1. Summary
a) WEL believes this review is a key opportunity to promote sustainable resource and land management and establish schemes which are better suited to the future challenges facing farmers, and other land managers, the wider society and the environment.
b) WEL strongly supports the consultation’s more sustainable approach that prioritises measures to address climate change, responsible resource use, biodiversity declines and water management. We believe that, if well designed, agri-environment schemes can deliver wider objectives for landscape, historic environment, access and socio-economic benefits.
c) Effective agri-environment schemes are vital for delivering many of the targets set in the Wales Environment Strategy.
d) WEL agrees with the Assembly Government's analysis in the consultation that the current schemes only deliver partially against the objectives now required of them, by the Wales Environment Strategy and the EU Challenge agenda. WEL is of the view that reform of the status quo is overdue and urgent. We do not believe that options 1a or 1b address this.
e) WEL believes it is necessary to realign the resources in Axis 2 into schemes where all the funding available is directed to delivering on the Assembly's stated environmental priorities. In our view, this means the realignment of the Tir Mynydd schemes to one with measurable environmental outputs.
f) We believe that Wales has a good track record in delivering agri-environment schemes (Tir Cymen, Tir Eryri and Tir Gofal) which have potentially positive environmental benefits particularly in terms of habitat management, public access and the conservation of the quality and heritage value of Wales’ diverse landscapes and the historic features within them. We believe that it should be possible to build on the widely accepted elements of these schemes and agri-environment experiences across Europe to design an exemplar scheme that meets the challenges facing Wales.
g) WEL members are generally supportive of the Option 2 structure, though not the tiering of the elements as currently proposed. We believe that significant further work on the detail of these schemes is required before it would command our full support. WEL members have many suggestions for new prescriptions, prescriptions packages and methods and maps to assist the Assembly to better focus these prescriptions. We are enthusiastic about working with the Assembly to design a scheme that delivers for the range of environmental priorities. We have specific concerns about option 3 in the form proposed, such as exclusive emphasis on carbon and water in the first tier. Hence, we could not support this option in the form proposed. We recognise, however, that if these weaknesses were addressed, this approach would have some advantages, as it could potentially lead to greater, joined-up, landscape scale action.
h) WEL believes that well-trained project officers should support all aspects of the new agri-environment scheme structure so that the agreements are tailored to achieve the environmental outcomes in ways that work for individual farm businesses.
i) We believe that robust, outcome focused, Axis 2 schemes that can clearly demonstrate delivery of wider public goods and services, will be one of the best ways of ensuring subsidy support in Wales in the longer-term context of declining Pillar 1 support payments, and international pressure to discontinue CAP.
j) Any change in scheme structure will require transitional support to minimise negative impacts, and support farm businesses to adapt.
k) Sources of financial support beyond Axis 2 are required to deliver the objectives of the Wales Environment Strategy and reward land managers for the public benefits they provide.
2. Existing schemes
The current suite of Axis 2 schemes is not entirely effective in delivering environmental benefits.
a) WEL supported the idea of an entry level scheme but Tir Cynnal has been disappointing because it has been designed more for ease of administration than for the delivery of environmental outputs. The lack of project officer support has been a disincentive for entry.
b) Tir Mynydd, while providing income support to LFA farms, does not by its design guarantee any environmental outputs. Ways need to be found to redeploy the LFA payments to secure environmental outcomes while providing a secure income stream for hill farmers. Cross compliance should apply to any successor or transition scheme and in particular should require that public rights of way comply with the legal requirements. In addition, any potential improvement to access land should be secured.
c) WEL is a strong supporter of Tir Gofal and experience has shown that the scheme has great potential to deliver a range of benefits for wildlife, landscape and historic heritage. The role of project officers in working with farmers to deliver high quality agreements is central to the success of the scheme. Lack of funding, however, has limited the scheme's ability to deliver. The scheme was designed over 10 years ago and needs a fundamental re-appraisal of its objectives to reflect current priority concerns - biodiversity declines and climate change and the promotion of effective ways of realising the services value of the range and quality of Wales’ many types of ecosystems.
d) A fundamental flaw in the design of existing schemes is that there was no monitoring system in place from the outset, and a lack of data on scheme outcomes. This makes it difficult to analyse the schemes’ environmental impacts or demonstrate value for money.
e) We are concerned that the ability to deliver environmental outcomes is at present restricted by the funding available for Axis 2. Demand for Tir Gofal outstrips supply; many farmers have faced lengthy delays in entering the scheme. Currently there are almost 1000 farmers on the waiting list and we understand that only 200 will be able to enter this year. The recently announced budget reallocation will further restrict access to agri-environment schemes and subsequently the environmental benefits delivered. The condition of many environmental resources, notably farmland biodiversity, is currently poor and continuing to decline; investment is required to reverse this then maintain the improved condition. This will require a considerable reallocation of resources.
3. Our aims for future schemes
a) WEL believes that the longer term focus of CAP should be to support sustainable resource and land management with payments targeted to those undertaking positive actions to deliver public benefits.
b) We welcome the high level outcomes set out in the consultation document and broadly agree with the assessment of the drivers for change and the intention to focus on delivering the objectives of the Wales Environment Strategy.
c) We would like to see all Axis 2 schemes delivering tangible public goods such as actions to deal with climate change mitigation/adaptation, the management of water quantity and quality and restoration and enhancement of biodiversity and landscape character.
d) We would expect a sustainable development approach to be adopted so that the delivery of public goods supports the social and economic health of rural areas.[1]
e) The limited resources available under Axis 2 must be used as efficiently as possible. This could be achieved by integrating measures to deliver multiple objectives.
f) Axis 2 measures should be used to help Welsh farmers adapt to the likely situation after 2013 where CAP Pillar 1 funding is predicted to drop significantly. An effective suite of RDP measures which have clear outcomes demonstrated by comprehensive monitoring will be crucial in defending continued support for rural Wales.[2]
4. Outcomes
a) Restoring and enhancing biodiversity is a pressing need in the face of biodiversity declines across a broad spectrum of habitats and species. Focused action for declining species on farmland and improved management of designated sites is needed. Addressing biodiversity declines is identified as a national and international priority[3], [4].
Many species of farmed habitats have suffered steep population declines in Wales over recent decades – the following are some examples;
· Yellowhammer declined 44% between 1994 and 2006
· Curlew declined by 81% between 1993 – 2006 in Wales
· Lapwing declined by 77% between 1987 - 1998 in Wales
· Downy Hemp-nettle is now extinct in UK - last seen in 1975 on a farm near Bangor
· Small-flowered Catchfly has been lost from 93% of sites
· Chamomile has been lost from 37 sites
· Shepherd’s-needle is now found at just 2 sites
· Brown Hares have undergone a substantial decline in numbers since the early 1960s
· Marsh Fritillary declined by 32%, Small Pearl-bordered Fritillary by 36% and Brown Hairstreak by 50% between 1970/82 – 1995/2004
· It is widely considered that agricultural intensification practices have contributed to the decline of several European bat species
b) All the actions that have been taken so far under agri-environment schemes have yet to make a significant impact on tackling these and other biodiversity declines. There is increasing evidence that agri-environment schemes can work for priority species if they are sufficiently well focused and the right prescriptions are delivered in the right places.[5], [6]
c) The extent of managed farmland in Wales means it has an essential role in improving ecological connectivity. In order to adapt to climate change, biodiversity will need this space to move, requiring a network of strong links between habitats. We believe this scheme must deliver through prescriptions to create habitat corridors and complementary buffers/transition areas around designated sites.
d) The improvements that have been made to water quality over recent decades need to be consolidated and developed at a landscape / catchment scale and on a collective basis. The analyses which are guiding implementation of the Water Framework Directive in Wales illustrate that diffuse pollution from agriculture is still a significant problem in many catchments[7]. Improving the management of water resources is closely linked to addressing the challenge of climate change. In particular, land management schemes have the potential to reduce flood risks. This can be done by increasing the capacity of upland areas to retain rain water, thus slowing down the rate of run-off and by providing increased floodwater storage capacity in the lowlands. There is considerable potential for multiple benefits for water and biodiversity from measures that could be undertaken under a higher tier scheme such as floodplain restoration, managed coastal realignment and raising water levels.[8]
e) Organic soils, especially peat soil, can act as a carbon store and land management measures can protect this stored soil carbon. Climate change impacts are likely to increase soil erosion and degradation making it important to improve soil condition and resilience. Many upland areas, particularly degraded blanket bogs, are a major source of greenhouse gases. We believe that cross compliance and good practice should prevent organic soil degradation where it is related to unsustainable management practices. There are clear biodiversity and water quality benefits from restoring blanket bog whereas the greenhouse gas emissions savings require further investigation.
f) A revised agri-environment structure should also contribute to the conservation of the historic landscape and vernacular buildings. This is an aspect of existing schemes, notably Tir Gofal, which is considered to be broadly successful but there has been no systematic monitoring. Monitoring of the impact of schemes on the historic environment should be integral. A capital grant element for the historic environment should be retained
g) There are recognised links between public health and the environment and an increasing body of research to support this.[9] The provision of a quality landscape with existing access rights in good order and new ones being developed and wildlife spectacles can contribute to the public health agenda as well as tourism benefits.
h) Producing the kind of countryside that we want is a labour intensive process requiring a skilled workforce. Measures need to be put in place through the other RDP Axes to help the rural workforce adapt to the changing expectations placed on land managers. For example, as carbon and water management continue to gain in importance, land managers will need to develop new skills and knowledge based on an understanding of why certain practices are being promoted. A suitably skilled and informed workforce underpins all agri-environment management practice and training should form an integral part of all such schemes in future, even if funded under different RDP Axes. In particular, Farming Connect needs to have environmental advice and training as an integral element, currently this is still not the case.
5. Options and Scheme structures
a) Of the options put forward in the consultation paper, WEL considers Option 2 to offer the best basis for the design of future Axis 2 schemes. This option, as opposed to options 1a and 1b, deploys resources to delivering direct environmental goods. An added advantage of this option is that it has a relatively simple structure but with its similarity to current agri-environment schemes lending a degree of familiarity. We have specific concerns about option 3 in the form proposed, such as exclusive emphasis on carbon and water in the first tier. Hence, we could not support this option in the form proposed. We recognise, however, that if these weaknesses were addressed, this approach would have some advantages, as it could potentially lead to greater, joined-up, landscape scale action.
b) There is a great deal of work to be done in developing option 2 into a fully fledged scheme or set of schemes, but the initial structure seems to be capable of accommodating both a broad based and a more focused approach. To tackle the key environmental challenges requires both a broad based all-Wales approach and a higher-tier scheme which allows more focused, in depth action.