Defra discussion paper on the impact in England of EU Commission regulatory proposals for Common Agricultural Policy reform, post 2013.
Read our response to the Defra proposals
Submission from the South West Uplands Federation
South West Uplands Federation (SWUF) is a farmer led initiative representing hill farmers from Bodmin Moor, Dartmoor and Exmoor. Our members are passionate about the uplands and wish to see their management of these national and internationally important areas continue.
The uplands of South West England provide an impressive array of public goods and eco-system services. These assets are largely under threat from insufficient land management, especially on the open moorland where most of these public goods and services are found. The hill farming that delivers this essential land management is under threat and a fair return for that delivery is still to be arranged by government.
In the South West of England the three main upland areas provide a unique array of ecosystem services including:
- 90% of the drinking water to 1.6 million people at an average of 446.7 megalitres/day.
- 10% of England’s Scheduled Monuments on 1.4% of the country’s land area.
- 73,800 ha. of public access.
- Providing carbon sequestration (9.2 million tonnes carbon on Dartmoor alone).
- Internationally important wildlife including blanket bogs, upland mires and heaths.
- World famous landscapes that contribute significantly to the South West’s character and associated tourism.
The proposed changes to the CAP provide an opportunity for the Government to honour its pledge to address some the problems facing hill farmers and to reward those providing and managing an impressive array of public goods and services. The iniquitous tiering of the Single Farm Payment has done much to damage the sustainability of hill farming, particularly in the South West. This could be addressed by a flat rate Basic Payment becoming available to all farmland below the Moorland Line. Additional support, from pillar 1 and from pillar 2, could provide the support essential to those farming the uplands, especially those areas rich in ecosystem services and public goods. However the proposals also have the potential adversely impact on hill farming. Of particular concern is the Less Favoured Area review; the reclassification may lead to areas currently within the LFA failing to meet the criteria for being within an Areas with/facing Natural Constraints (ANC). This is of particular concern to the South West of England where initial reviews suggest that if the current proposals were to be implemented large parts of the Dartmoor National Park, Exmoor National Park and Bodmin Moor AONB would lose this special recognition and its accompanying support mechanisms.
SWUF welcomes the opportunity to submit our views on the proposals. In our comments SWUF has focused on those proposals most relevant to hill farming and livestock farming in the south west of England.
Q1: What are your views regarding the direct payments proposals?
- Direct payment is essential to retain farming in the uplands. The proposed Basic Payment is welcomed and provides the opportunity to address the serious adverse impact on hill farmers that resulted from the three tiers of the Single Payment Scheme (SPS). Our preference is for a two tier Basic Payment; one for all land below the Moorland Line (ML) and another for land above the line. We estimate that this might cause the basic payment to fall by 1% on non SDA land but would increase payment to those in the SDA (below the ML) by 18% based on 2010 SPS payments. We would not expect land above the Moorland Line to attract a similar payment per hectare but it should increase slightly from its current value (c£46 per ha. at 2010).
- Do you support the idea of a small farmer scheme? The principle of supporting a small farmer is sound but will be very difficult to administer. Differentiating between someone who is a farmer and someone who is a hobby farmer may prove problematic. We recognise that some small farmers can provide a disproportionately high contribution to the land management so essential to maintaining the landscapes and associated benefits. However on balance we believe the funds allocated to this ambition might be better directed to young farmers and new entrants who, in turn, should be generating at least 70% of their income from farming.
- We support the principal to provide a top up for young farmers under 40 years old. However especially within the hill farming community most farmers remain in a family partnership until they are well over 40 years old. There are many farmers over this age who are still not farming in their own right. The amount of money on offer may not be enough of an incentive for people to act on, especially if it means changing the current structure of the business.
- Funding only active farmers.SWUF strongly supports the principle of agricultural payments (including pillar 2 payments) only going to active farmers. We are aware of cases where the SPS is claimed by a landowner denying essential funds to the farmer who is incurring the costs of managing the land and its related natural assets.We appreciate the difficulty of identifying active farmers and the proposals suggested in the EU’s proposals appear too complicated. We had hoped to suggest that those wishing to claim direct payments must complete a simple form based on the criteria below:
- The landowner must be able to confirm that they have a holding number,
- have the means of complying with cross compliance regulations on all their land,
- are registered with the State Veterinary Service for sheep and/or cattle movements, and/or
- are registered with an approved grain assurance body.
However whilst recommending that this approach should be seriously considered and developed we recognise that in its current format it may deny payment to legitimate farmers and that some non-farming land owners may find ways of complying.
SWUF recommends that all land owners, who wish to claim the Basic Payment, must be able to demonstrate, by their tax return or accounts, that they are farmers and that farming provides a substantive proportion of their turnover.
Whatever system of identifying active farmers is selected there must be heavy penalties for non-compliance or providing incorrect information and a programme of inspections.
- What do you think a ‘minimum level of agricultural activity’ should look like? SWUF is unclear over the implications of this proposal and offers no comment at this time.
- SWUF supports the capping of the Basic Payment Scheme, however we are concerned that the capping should not be applied to common land where many farmers benefit. The capping should apply only to an individual or a farm business. In the South West common land covers 49,453 ha. and some commons are of a significant size, the largest being the Forest of Dartmoor covering some 11,200 ha. At today’s SPS payment rates ( it is above the Moorland Line) the collective value to that common from the SPS is above 300,000 euros. However over 300 commoners will have entitlements relating to that one common and individually will receive funding of a value well below the threshold. Common land that has no active rights holders and the land owner claims the entire Basic Payment should be subject to the capping.
- What do you think about the proposal to abolish existing SPS flat rate entitlements and
establish new flat rate entitlements? SWUF is unclear over the implications of this proposal and offers no comment at this time.
- Claim at least one entitlement in 2011 to claim in 2014. We support the intention to prevent large farms being sub-divided to avoid the capping. The proposal must not disadvantage new entrants or those farming in their own right for the first time. On many family farms the parents may well have claimed in 2011 and there needs to be a simple way entitlements can pass from one generation to the next.
- Greening proposals.The greening proposals in their current form appear to be imposing excessive administrative burdens. Providing flexibility to Member States would better achieve the aims and enable those areas already delivering significant environmental benefits not to endure further administrative burdens and regulation. Most farming in the uplands is extensive and provides real benefits to the natural environment. Often these benefits are over and above those provided by organic farming. Farmers who are already in UELS and/or HLS should be considered to have met the greening requirements.We would wish to see livestock farmers exempt from the proposals relating to arable cropping. If a farm is a predominately a livestock farm (grass) but grows fodder crops to feed only stock then they should not have to meet the criteria for arable cropping. SWUF supports the principle of no deep ploughing and permitting reseeding. The ability to replenish the sward by cultivation is extremely important in maintaining grass utilisation and efficiency. However the proposals suggest that if reseeding is not undertaken within 5 years the land reverts to permanent pasture and further restrictions apply. The frequency of reseeding to avoid re-classification should not encourage more frequent reseeding than what is currently undertaken, (often a 7 year cycle in the South West).
- What land do you think should be targeted in a farm’s ecological focus area. SWUF is not convinced that EFAs are necessary on moorland and livestock farms. The predominance of small field systems, extensive semi-natural vegetation and a predominance of High Nature Value Farming suggests such land is already delivering a range of ecological benefits.
- SWUF does not support the proposal for the reintroduction of coupled support.Whilst the reintroduction of headage payments initially sounds useful to livestock farmers in the SDA/LFAs we are concerned that the additional bureaucracy would out-weigh the benefits. Many farmers would be unable to benefit due to the imposition of stocking rates from agri-environment agreements. We would rather see the use of the proposed voluntary payment to farmers in Areas facing Natural Constraints (including the SW uplands LFA).However there might be compelling case for coupled support to be introduced (re-introduced) on to the highest and most inaccessible moorland. In such areas there is , currently, little incentive to provide grazing cattle. Cattle are essential to maintain or enhance the ecosystem and targeted headage payments might be used to encourage the most suitable breeds and to improve immunity to parasitic diseases.
Q2: What are your views regarding the single common market organisation proposals?
Q3: What are your views regarding the rural development proposals?
i. Do you support the removal of axes from the new regulation and the proposal that the
measures be used together? Do you agree with the removal of minimum spends?
The removal of the axes and the merging of the Measures should provide greater flexibility and reduce confusion but much will depend on how they are delivered in the Member States. Removal of minimum spend is welcomed. Minimum spends in the most recent FFIS window were far too high for most upland livestock producers, especially those not able to claim 50% intervention because they were not farming sufficient SDA land.
ii. Do you agree with the six strategic priorities that the Commission has set? Are there
priorities or actions you consider to be missing?
The priorities are:
- fostering knowledge transfer and innovation in agriculture, forestry and rural areas;
- enhancing competitiveness of all types of agriculture and enhancing farm viability;
- promoting food chain organization and risk management in agriculture;
- restoring, preserving and enhancing ecosystems dependent on agriculture and forestry.
- promoting resource efficiency and supporting the shift towards a low-carbon and climate-resilient economy in the agriculture, food and forestry sectors;
- promoting social inclusion, poverty reduction and economic development in rural areas.
SWUF supports the priorities as set out above. In particular we welcome the acknowledgement the farming has crucial role in protecting and enhancing an array of public goods and ecosystem services. Farming in the uplands has a particularly crucial role in managing land that benefits, for example, water supply (quantity and quality), stored carbon (in peat), enabling public assess, the historic environment and the natural environment. In addition the nation’s iconic landscapes can only be protected and managed by farming.
We call for clearer guidance to prevent farmers from receiving potentially conflicting advice/regulation when managing these assets.
SWUF believes it is essential for capital grants to accompany agri-environment- climate agreements. In many cases capital works are required to ensure the outcomes of such agreements are delivered.
iii. Which measures in this proposal do you think would be useful for you? SWUF is unclear over the implications of each measure and offers no comment at this time.
iv. Do you support the increased and strategic focus on innovation and technology? What
benefits do you think it will provide?
Opportunities for innovation and new technologies within the uplands are limited. In fact it in the nation’s interest to retain established farming systems to maintain an impressive array of ecosystem services. Farming often created these natural assets and established farming methods are often the only means of sustaining them.
There may be room for some new technologies and in the hills it is the younger generation that is most likely to utilise them. However we must avoid a significant part of the budget becoming allocated to technology whilst the funding to reward environmentally friendly farming declines.
v. Do you support the new measure for organic farming?
SWUF supports a new measure for organic farming but the significant differential between organic and non-organic payments needs to be reviewed. Today many non-organic farmers have adopted good practise originally confined to organic farmers but fail to receive similar support. Whilst organic farming is important within the uplands so is extensive livestock farming, both can have a low carbon footprint. We would support the inclusion of organic farming within a wider ambition that includes local sourcing and local markets.
vi. Agri-environment-climate schemes. SWUF supports the move to widen the scope of pillar 2 funding to secure outcomes that mitigate against climate change and enhance a range of ecosystem services and goods. The uplands are unique in having such a crucial role in safeguarding water supplies, protecting carbon and providing extensive farming. Agri-environment-climate schemes have the potential to play an essential role in rewarding and sustaining farming that provides so many public goods, including public access to internationally recognised landscapes. Designation of open public access is worthless if the growth of vegetation prevents such access.
vii. What are your views on the new Risk Management provisions? No comments.
viii. Are there any positive measures under the current rural development programme that
you do not see continuing in these new proposals? No comments.
ix. Do you support a continued role for Leader, including a minimum spend of 5%? Do you
agree that Leader should apply across the Common Strategic Framework Funds?
The Leader approach is valuable and can provide support to rural communities and farmers. SWUF supports the principle of Leader continuing but this funding must be available to all those who qualify. In the past Leader has been unavailable to some parts of the country and encouraged in others.
x. What are your views on the proposed “Areas facing Natural Constraints” designation,
which is intended to replace the current Less Favoured Area?
SWUF supports the principle of identifying areas where physical natural disadvantages of the land impact on land management and reduce the opportunities for farmers. However we think the current LFA boundaries are adequate and any changes to the existing boundaries will lead to confusion. The existing LFAs identify areas where farming is restricted and where farmers are unable to change their farming practices to benefit from market opportunities. In the SW uplands the LFA clearly identifies those areas where farmers have little option but to remain livestock farmers.
However we are very concerned that the combination of the new criteria and the method of delivery (by LAU2 boundaries) will remove this valuable designation from land that clearly deserves to be included with the new ANCs. The adoption of electoral boundaries or parish boundaries are both unsuitable and if one of these is adopted, as the delivering mechanism, the SW uplands may lose their LFA/ANC status. This would be very damaging to those farming within the current LFA. Not only would the farming community lose the recognition that they farm in more difficult conditions but access to essential funding may be denied. As an example hill farmers in the South West moors are often unable to enjoy the financial benefits of adding value to their finished cattle and lambs. The same farmers are often unable to grow their own fodder crops and therefore incur high costs associated with their production of calves and lambs. If this system was to breakdown due to insufficient support then the only means off managing these uplands and their associated public goods would also stop with disastrous implications for the ecosystem services found in these areas.
SWUF suggests that the ANC designation is farm focused; available to all farms and common land within the areas where the criteria apply.
xi. What do you think of the proposal for two separate discretionary payments to farmers in
Areas facing Natural Constraints – an area-based direct payment top-up, and a
compensatory payment under the Rural Development Regulation
Farming in the current LFA requires financial support. Currently this is provided by the SPS, Upland Entry Level Stewardship and in some places Higher Level Stewardship. Together they are essential to those farming the hills and moors providing 40% of a farm business income. Sales of calves, lambs and wool fluctuate and are all too often achieved by incurring increased costs from feed, bedding and animal welfare. Hill farms in the SW uplands are barely profitable BUT provide essential land management.
SWUF welcomes and supports the proposal that offers an area based top-up payment from pillar 1. We also support the proposal to offer a compensatory payment from pillar 2. Both payments would make an important contribution to the survival of hill farming and to the array of public goods and ecosystem services sustained by hill farming. In the south west of England such ecosystem services include providing 90% of the region’s drinking water, preventing the loss by wild-fire of c9.2 m t of carbon locked into the peat and over 10% of the nation’s most important archaeological sites.
Q4: What are your views regarding the financing, management and controls proposal? No comments.
Q5: What are your views regarding the proposals fixing certain aids and refunds? No comments.
Q6: What are your views regarding the transitional arrangements for direct payments in
Direct payments and pillar 2 payments are essential to sustain hill farming providing in excess of 40% of a Farm Business Income. A gap in payments (in 2013) would bring enormous hardship to hill farmers and could lead to some farmers abandoning the land. SWUF believes transitional arrangements that ensure direct and pillar 2 payments continue are essential.
Q8: Do you have views on any further areas you think we should consider concerning this package of CAP reform proposals?
In the proposals, relating to direct payments, the current category of “permanent pastures” is renamed “permanent grasslands”. This explicit move away from pastures in general and towards grass pastures is a concern to SWUF. Increasingly farmers in upland forage areas are being funded to manage the land to encourage a rich and diverse sward; heather moorland, blanket bogs and upland heath. These areas are part of extensive farming practices and continue to provide browsing and grazing for hill livestock. Whilst we recognise that the new definition for permanent grasslands includes reference to “other species suitable for grazing provided that the grasses and other herbaceous forage remain predominant” we are concerned that this approach downgrades the value of vegetation other than grass. SWUF would wish to see greater clarification and an explicit statement reassuring upland farmers that the diverse vegetation they are required, by agri-environment schemes and by local conditions, to provide will not deny those farmers access to direct payments.
Financial support from the CAP is essential to hill farmers. However the support , or reward, they receive enables them to continue to manage some of the UK’s most iconic landscapes and treasured places. Also the hills provide an unparalleled suite of ecosystem goods and services. Often the only payment to the managers of these natural and national assets are the direct payment and agri-environment payments. It is likely the CAP budget will come under increasing pressure and the resulting budget may be less than is currently anticipated to be. In such circumstances Government must recognise the need to support hill farming and ensure public money is focused on those areas delivering the most public benefits; the uplands.
This submission was provided by John Waldon on behalf of the South West Uplands Federation
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