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CAP implementation

We recognise that agricultural businesses play a significant role in the protection of our natural environment, and in turn benefits from the services provided (pollination, helping to prevent diffuse pollution and air pollution, pest control and supporting tourism etc.). It is therefore important that we maintain a competitive farming industry which is has the tools and resources available to protect and maintain a functioning natural environment. 

We answered the following questions from the conultation:

Regional distribution of direct payments: 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

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 a higher rate of reduction but less than 100% (please explain what reduction you favour)


Please comment further if you wish, or explain what other reduction you favour :
We feel that it is important that larger farms are not given a competitive advantage. Greening is likely to be much more cost efficient on larger farms than smaller
farms, and therefore without reduction they will have an advantage. However we also agree with government that we should minimise distorting influences on the
decisions that farmers take about the management of their land, and the possibility of artificial restructuring. The level of reduction should be carefully calculated
to achieve both these aims.


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
Please comment further if you wish, or explain what types of businesses should be added to the list and why:
There is no reason to exclude any other operators.

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?
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?:
Whatever greening measures are put in place, they need to provide the 'best value' for our natural environment, whilst also being achievable for the farming
community. There is a building list of evidence to show that farms can implement options to protect the natural environment without significantly affecting
profitability.
A certification scheme has the benefit of being able to be improved at a later date with the potential for it to be a long term mechanism for incorporating the
environmental agenda into mainstream thinking.
A certification scheme can also be used as a positive tool, allowing farmers to proudly demonstrate a commitment to the natural environment, instead of greening
simply being seen as more red tape and an exercise in 'ticking the minimum number of boxes'. There may even be potential for it to lead to the provision of
advice.
However a certification scheme will be more complex, and could therefore reduce implementation from many farming businesses.
Our decision of whether an NCS should be set up would ultimately depend on the shape of the scheme.


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?
We feel that organic farms should not be exempt, as is not always correct to assume organic farms are always 'green'.
We also feel that the threshold for arable land to be exempt should be reduced to 5ha, so that it is in line with the minimum claim size.


Making available the full list of Ecological Focus Areas (EFA) options would mean that much of the EFA requirement could be met without additional action and that various options may have differing environmental benefits. Which selection of EFA options do you favour?
The environmental benefits provided by EFA options will vary on a case by case basis. For best effect there should be the full list of options to provide flexibility
with the provision of tailored advice, the current ELS handbook is a good example.


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? 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?
The management of hedgerows for wildlife is a good option as better management from a wildlife perspective often costs less than keeping hedges 'neat and
tidy'. Hedges will provide a good nectar source for pollinators, especially when planted with a variety of native species. However caution needs to be taken before
further restricting 'no trimming' dates, so as to not make this option unachievable to many businesses.
Wild flower mixes are also valuable for pollinators, whether in buffer strips or field corners, however this is expensive. An alternative is to implement an annual
pollinator mix which is easier to do with good results and will build enthusiasm.


Cross compliance standards of Good Agricultural and Environmental Condition (GAEC) under the new CAP aim to protect soils, water and maintain the landscape. Are there any current GAECs that you think should not be carried forward and included from 2015? If so, what are your reasons and evidence for this?:
No


What lessons can be learned from the current Rural Development Programme? How can we build upon its successes?
Agri-environment schemes have made a major contribution to the conservation and enhancement of our natural landscape. It is important that farmers and
landowners retain confidence in the continuity of these agri-environment schemes.
We recognise that the agri-environment programme needs to evolve, and we support changes to incorporate adaption to a changing climate, production of
renewable energy and the sustainable management of water.
We would encourage a cross cutting theme across all Rural Development Fund streams, which takes regard for the environment and sustainable development.


Are there any key areas we have missed in our assessment of need to support the new Rural Development Programme?
Are there any key areas we have missed in our assessment of need to support the new Rural Development Programme?:
We are concerned that the RDP does not specifically identify the importance of building and supporting sustainable (both economically and environmentally) rural
communities.


How we can best target investment under the new Rural Development Programme to help gain the maximum value for money for UK taxpayers? 
Better accounting for natural capital.


What are your views on the structure of the proposed new environmental land management scheme, in particular the new "landscape scale" approach?
We agree with the idea of a landscape scale approach in order to achieve the aims set out in the natural environment white paper of creating functional habitat
networks. This would require the scheme to only be available to farmers within ecological networks, and for the options available to be tailored to the habitat aims
of that area. Ecological networks are mapped, defined areas that link current aggregations of priority habitat, not simply a random cluster of agreements.
Whilst this has the potential to provide great gains for biodiversity, it is also very exclusive.


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?
Ecological networks are mapped, defined areas that link current aggregations of priority habitat, not simply a random cluster of agreements.
Although ELS has proven to not have been fantastic value for money in terms of biodiversity gain, we believe that it did help to start the process of considering
the environment in management objectives, and acted as a stepping stone to HLS. We are concerned that the reduction in the amount of agreements may lead to
an overall decline in the amount of consideration given to the natural environment.

 

How could we help facilitate landscape-scale approaches under the proposed new environmental land management scheme?
Ensuring that habitat connectivity and therefore visions for ecological networks are adequately mapped across all of England.


Should we offer a capital only grant as part of the proposed new environmental land management scheme?
No. Capital items were seen as a bonus of an agri-environment scheme. If there is no agreement associated with the capital item then how can we ensure the
desired environmental gain occurs? For example, you could pay someone to fence an area of semi-improved grassland so that the area could be grazed
sympathetically with the aim of creating a species rich sward, only to find that after a year they then decide to intensify the grazing and destroy the grassland.


Do you agree with the principle that five year agreements should be the norm under the new environmental land management scheme?
Yes, although longer agreements offer a much better mechanism for managing nature we realise that this length may be a barrier, preventing many businesses
signing up. We therefore recommend 5 year agreements, but put together in a way that continuation after the 5 years is a simple process.


What approach should we take to targeting the new environmental land management scheme?
Ensuring that habitat connectivity and therefore visions for ecological networks are adequately mapped across all of England will allow targeting of the scheme at
a landscape scale, which will have the maximum benefit for nature.


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?
Advice and guidance is key to getting the maximum benefit from environmental land management options. Expert knowledge is required to know what options
would work best for different locations and/or farming systems at all levels (even EFAs), and to be able to coordinate agreements at a landscape scale. Whilst we
agree with the idea of making more advice available online, we do not think this should replace the provision of knowledgeable, trained advisers who can offer
personal advice and develop positive relationships with farmers and land owners.


Where should we set the scheme entry requirements (i.e. above the legal baseline) for the proposed new environmental land management scheme?
This should depend on the available budget, with the priority being schemes going far above the legal baseline (i.e. doing the maximum for nature). If there is
then left over budget schemes with lower entry requirements can be implemented.


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?
Yes

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?
Supporting improved environmental performance, resilience and efficiency.


How should we support advice and skills for the farming, forestry and land-based sectors under the new Rural Development Programme?
We support the findings from the Review of Advice and Partnership Approaches, and believe that these should be acted upon. Effective communication between
advisory bodies is essential, as is access to trusted and reliable advice.


How can we ensure any advice provided to the farming, forestry and other land based sectors and through the newenvironmental land management scheme is integrated and linked with advice provided within the industry in the light of the Review of Advice and Partnership Approaches?
We support the findings from the Review of Advice and Partnership Approaches, and believe that these should be acted upon. Effective communication between
advisory bodies is essential, as is access to trusted and reliable advice.


How can we strengthen LEADER's contribution to delivering jobs and growth in rural areas?
LEADER should be available to a greater proportion of the country so as to select the best value projects.


How can we make the LEADER approach more effective and deliver better value for money?
LEADER should be available to a greater proportion of the country so as to select the best value projects.


Without a transfer there would be no new investment in rural development over the next 7 years. Transferring funding to Pillar 2 would allow us to deliver improvements in the natural environment, productivity and longer term competitiveness of UK agriculture and help us to grow the rural economy in England.

Do you agree there should be a transfer?
Yes

What percentage should be transfered?
15%

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?
The Environment - agri-environment and forestry should be the priority. However we also appreciate the importance of maintaining a competitive industry and
forestry production.

What percentage should be spent on each?
Environment - Agri-environment and forestry:
88
Farming competitiveness and forestry productivity :
3
Growth Programme:
5
LEADER:
4
Please explain your reasoning:
We need to increase the environmental focus in order to stand a chance of achieving the objectives set out in the England Biodiversity Strategy 2020.
Continued loss of our natural environment will negatively affect farming competitiveness and forestry productivity and economic growth.