Consultation Responses - Berkshire LNP

3. As an overarching priority, our strategy emphasises the need "to secure better access to talented people and bright ideas and to use both more effectively".

Do you agree with this?

Yes totally

We agree with the statement 'people will choose Thames Valley Berkshire as the place to live and work'. We believe that the quality of our environment and quality of life is essential to attracting talented people to the area, and retaining those that we already have.

4. Four programmes for implementation are set out, focusing on:

• Promotion and international positioning
• Enterprise, innovation and business growth
• Skills, education and employment
• Infrastructure

Do you agree that these four encapsulate the top priorities for investment in Thames Valley Berkshire?

Yes totally

5. Of these four programme areas, which one would you regard as the single most important in making Thames Valley Berkshire a better place for your business (tick one only)?

Investment in infrastructure  

6. In implementing these programmes, we want to achieve our vision for Thames Valley Berkshire, namely that by 2021, "The vibrancy of our business community will be internationally envied. The ambition and creativity of our established businesses will be energised through strong, knowledge-rich, networks. Our workforce will be the lifeblood of our economy: young people will be inspired and older workers valued. Our infrastructure will match the scale of our ambition and potential. And people will choose Thames Valley Berkshire as the place to live and work".

Do you agree with our vision?

Yes totally

This resonates completely with the overarching aim of the Local Nature Partnership, which is to ensure "Berkshire is a great place to live, great place to learn and great place to work"

7. If you wish to make further, constructive comments please do so below; this could include factual inaccuracies or areas that you feel strongly are not covered by the current draft SEP, in particular the implementation mechanisms and levers.

We were delighted to see recognition in the strategy that the quality of the natural environment is one of our outstanding locational advantages and that it must be sustained in order for Berkshire to continue to be a place in which people want to live and work.

Our partners would have liked to seen 'outstanding locational advantages' quantified as 'contributing to the health and wellbeing of the population as places to exercise, relax and inspire, whilst also providing much needed services such as controlling air quality, water filtration, flood defences and supporting the local food growing and horticultural economy.'

Whilst we recognise that the remit of the LEP is enterprise and growth of the economy, and we welcome comments that acknowledge the role of the natural environment in contributing to the economic success of Berkshire, our partners would like to have seen more detail on how the SEP ensures that the environment can continue to provide the numerous services that individuals and businesses benefit from, which form the bedrock for our economic progress.

This could be achieved by including the following points in section 'How we will monitor progress':

• the vibrancy of town centres – measured through number and size of business networks; number of new bars, restaurants, etc. opening in key town centres; provisions of green and blue infrastructure; footfall; and rents in town centres

• the percentage of capital investments in building and infrastructure which are environmentally sustainable
We would encourage rephrasing of the paragraph on page 21:

"First, as Figure 7 (on page 23) indicates, TVB is highly constrained in development terms. Much of the west of TVB is a protected landscape (North Wessex Downs Area of Outstanding Natural Beauty) while the Metropolitan Green Belt features strongly in the east"

This does make the AONB and greenbelt area sound like an obstacle but in fact it is where many Berkshire residents go at the weekend to relax, both areas contribute considerable sums to the local economy and it is just possible that those sums are equal to what could be achieved if they were developed.

Perhaps something like '......Much of the west of TVB comprises our protected landscapes.....'

8. We see your business as crucial to the strategy. Would you like to stay in touch with the strategy's implementation as we move forward?

Yes

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.

The BLNP submitted the following responce to the EA Challengaes and Choices consultation - Thames, South East and South West river basin districts:

1. What do you consider to be the biggest challenges facing waters in the Thames/South East/South West River Basin District?
The Berkshire LNP is mostly part of the Thames River Basin District, but also contains parts of the South East (Test and Itchen and Loddon Catchments)
Significant localised impacts must not be ignored. This includes Interaction with other water bodies, such as canals which can lead to increased pollution and sediment load; bank-side erosion and invasive species. Often the solutions to these problems can be best determined at a local level.

Nutrients, sedimentation and algal growth, invasive species and over abstraction of aquifers are currently some of the biggest challenges. There are also opportunities, such as the recognition of river environments as significant landscape scale corridors for biodiversity.

2. Do you agree with our description of how the significant issues are affecting the water environment and society? Please specify which issue(s) your response refers to and provide relevant information to help explain your answer.
we support the significant water issues as described. In addition, we would hope to see much more emphasis on protection and enhancement of key habitats and species, greater demand side management and an absolute reduction in abstraction at key points.

Although it is difficult to quantify the value of healthy river environments to landscape quality, this should form part of the assessment of issues. It is surprising that catchments located in Areas of Outstanding Natural Beauty, or National Parks are not recognised.

3. How do you think these issues should be tackled, and what would you choose to do first? Please specify which issue(s) your response refers to. Please consider any resource implications.
The virtuous circle of reduced diffuse and point pollution leading to benefits for river habitats and lower treatment costs is well known. Greater integration with Environmental Stewardship objectives, control of hazardous substances (such as Chlorpyrifos), managing runoff and incentivising use of lower quantities of inputs are a significant priority.

The use of demand side measures must be accelerated in order to ease pressures on valuable river habitats. Local small‐scale storage will help decentralise supply and reduce reliance on mains water. This applies most obviously among large agricultural, horticultural, fish‐farming and leisure users, but also at the domestic level (e.g. through rainwater harvesting). The potential landscape of possible large new surface reservoirs should be thought of as a last resort.
The Environment Agency and partners need to compel water companies to develop pricing mechanisms aimed at reducing demand, such as banded tariffs, seasonal pricing etc. Furthermore, ensuring greater supply efficiency through reduction in leakages will help to reduce the amount of water required to be abstracted and treated.

Working with developers, planning authorities to make wastewater re-use and other efficiency measures a condition of any future planning permissions. The availability of supply should also form part of the test in determining housing allocations and permissions. Assisting rural and land based businesses to install greater water storage solutions could drastically reduce the demand for water in rural areas.

At present, there are a significant number of initiatives funded by Government, the private and the not for profit sectors. We would like to see a much more integrated and simplified approach to catchment management. The sheer volume of plans and initiatives makes it difficult for partners to engage. For example, in addition to the River Basin Districts, there are Catchment Partnerships and Catchment Management Plans, Demonstration Test Catchment Projects, Catchment Sensitive Farming areas, Water Framework Steering Groups, Flood Forums, Water Resources Management Plans, Love Your River, Living River and RESTORE, to name but a few.

7. Is there any other information that we should be taking into account as part of this strategic environmental assessment?

Management plans for designated wildlife sites, landscape scale partnerships, statutory designations such as Areas of Outstanding Natural Beauty and Local Nature Partnerships.
The Chalk Stream Charter, published in May 2013.

"We own over 90 hectares of woodlands many of which have had little management in recent years. This means that they are not as healthy or as accessible as they could be. We are now working in partnership with the Forestry Commission to revitalise them for the people that use them and to protect wildlife" More info at  http://www.reading.gov.uk/council/consultations/openconsultations/woodlandsproject/

Berkshire LNP's comments:

The Berkshire LNP was glad to hear of plans to better manage Reading’s woodlands for wildlife and people.

We encourage consideration of the contribution this project will make towards Berkshire’s biodiversity strategy (and in turn the national objectives). Several of the woodlands are within the ‘West Reading Woodlands and LNRs’ Biodiversity Opportunity Area (BOA), and as such have been identified as key areas of opportunity for the creation of a functioning ecological network across Berkshire.

The inclusion of this information in the management plans of the woodlands will help ensure that there is collaboration with the owners of the neighbouring woodland sites, and that the achievements of this project are effectively recorded (against county and national targets), so as to better inform future management of the counties ecological networks.

Accordingly the BOAs may be a tool to help the council identify if any other woodland under their ownership should have a similar management plan.

For any queries or questions on the biodiversity strategy, or BOA, please contact the Berkshire Local Nature Partnership.