Y Pwyllgor Newid Hinsawdd, Amgylchedd a Materion
Gwledig | Climate Change, Environment and Rural Affairs
Committee
Ymchwiliad Bioamrywiaeth | Biodiversity
Inquiry
Ymateb gan : Undeb Cenedlaethol yr Amaethwyr (NFU
Cyrmu)
Evidence from : National Farmers’ Union Cymru
(NFU Cymru)
- NFU
Cymru welcomes the opportunity to respond to the Climate Change,
Environment & Rural Affairs Committee Inquiry into
Biodiversity.
- We
note this inquiry is intended to explore biodiversity restoration
in the context of the proposed Public Goods Scheme and
asks:
-
- How
could the Welsh Government’s proposed Public Goods Scheme,
set out in Brexit and Our Land be applied to restore
biodiversity;
- How
could the various existing Welsh Government policies and
legislation for biodiversity restoration be applied in the design
and implementation of the proposed Public Goods Scheme;
and
- What lessons can be learned from the Glastir Monitoring and
Evaluation Programme (GMEP) to ensure effective monitoring and
evaluation of schemes to support restoration of biodiversity.
How should the new Environment and Rural Affairs Monitoring and
Modelling Programme (ERAMMP) be designed and implemented
effectively for this purpose?
- Firstly, we note in the background narrative provided to the
Inquiry, the Committee refers to Natural Resources Wales (NRW)
State of Natural Resources Report (SoNaRR) as well as the State of
Nature Report produced by environmental NGOs. We would take
this opportunity to refer you to the body of evidence presented in
GMEP here which refers to a
number of positive trends emerging from this Programme which is one of the most
comprehensive monitoring of agri-environment schemes anywhere in
Europe. These include:
-
Stable overall plant species richness in woodland
habitat but evidence of a decline in arable, improved and habitat
land up until 2007 when it appears to have stabilised
-
Recent stability for upland farmland birds and an
increase in woodland bird species
-
No further decline over the last 10 years in
specialist butterfly species
-
General ongoing improvement in the condition of small
streams since 1990 based on macro-invertebrate communities with 80%
of streams surveyed through GMEP in good or high ecological
condition
-
A significant trend for increasing area of woodland
over the last 15 years.
-
An increase in woodland bird indicators
-
Land use, land use change and forestry in Wales has
changed from a small GHG source to a sink between 1990 and
2013 as a result of increased carbon storage in vegetation
and soils
-
Reductions in nitrogen fertilizer consumption across
Wales by approximate 45% between 1990 and 2013
-
A significant decline in available phosphorus for
improved land providing benefits for freshwaters
- The
30 year record of topsoil carbon indicates no decline and there is
ongoing recovery of soil acidity – both are positive
outcomes.
- Overall the GMEP Programme findings show an overall picture of
stability and some improvement.
- With respect to how the proposed Public Goods Scheme as
proposed in Brexit and Our Land could be applied to restore
biodiversity we would make the following points. You are also
referred to the NFU Cymru response to the Brexit and Our Land
consultation
available here.
- NFU
Cymru key principles for future policy include:
-
- A
policy that underpins and secures the continued support of safe,
quality, traceable, affordable food for our nation, in the context
of future global challenges, must be at the heart of any future
agricultural policy
- All
farmers must be fairly rewarded for the environmental/public goods
they already delivery and will continue to deliver in future for
society
- Policies must be simple to administer, easy to understand and
target support at those active farmers who take the financial risks
associated with food production
- Investment measures are required to ensure that farming
businesses are well equipped to face the challenges and maximise
the opportunities of a post-Brexit marketplace
- The
regulatory regime must be proportionate and evidence-based and
policies must be adequately funded to ensure that Welsh farming
remains competitive with farmers in the UK, EU and
globally
- In
terms of a new agricultural policy for Wales, NFU Cymru proposes a
single, integrated, flexible framework based around three
cornerstones – productivity, environment and
volatility/stability.
- Farmers manage over 80% of the land area of Wales. Over
many centuries farming has shaped the countryside we all now
enjoy. Over the past 30-40 years, farmers have carried out a
huge amount of work to encourage wildlife, enhance the landscape,
benefit soils and water and reduce climate impacts.
- Every farmer in Wales already contributes and has the
potential to further contribute to practical environmental farm
management that includes the protection and enhancement of existing
features on their farm as well as the maintenance of actively
farmed land to support biodiversity, carbon, soils, water and air
quality alongside their core food production
role.
- In
terms of environment measures, NFU Cymru proposes a farmed
environment scheme that is open and accessible to every farmer that
wishes to undertake activities that go beyond the regulatory
baseline. This scheme should be multi-annual and the ambition
should be to have the maximum amount of farmed land under the
scheme. The scheme must be developed in genuine partnership
with the farming industry and be properly trialled and piloted
ahead of roll-out. Detailed assessment of impacts –
economic, environmental, social and cultural – are vital
prior to any changes being implemented.
- Complimentary to the farmed environment scheme, NFU Cymru
would support the introduction of an advanced scheme for farmers
who wish to go above and beyond the measures in the farmed
environment scheme. This scheme would be suited to those
farming is designated areas or farmers with designated sites on
their farm, those with significant natural constraints and those
who have been in agri-environment schemes or farming organically
for a significant number of years.
- Future environment support should include a mix of management
and capital payments.
- Given the proportion of land in Wales that is tenanted,
special consideration will need to be given as to how tenant
farmers can access support in the future.
- In
framing payment for the delivery of public goods related to
resilient habitats and ecosystems, NFU Cymru would highlight the
need to consider and understand the concept ‘natural
environment’. No area of Wales is truly natural in the
sense that it has been unaltered by human activity. The vast
majority of what is described as the natural environment is in fact
semi-natural vegetation and semi-improved grassland which is
reliant on active and continuing land management by
farmers.
- The
natural environment should not be presented within the future
Public Goods scheme as something that requires
‘protection’ from agricultural activity. Rather
it should be viewed as being conserved by the farming community who
have created, shaped and maintained the environment over
centuries.
- There is a need to recognise and value the maintenance of
habitats within the Public Goods scheme alongside habitat creation,
restoration and enhancement.
- Significant areas of habitat already exist of Welsh
farms. These habitats and their connectivity through
provision of well managed hedgerows and streamside corridors and so
on must be valued through the future approach. The aim should
be to maintain diversity of habitats. This will include
improved grasslands and diverse cropping which are all highly
important feeding areas for many bird species.
- NFU
Cymru strongly rejects the proposal that future support should only
encompass the provision of additional public goods from the
land. Farmers alongside their role as food producers have and
continue to produce a vast range of goods and services for
society. It is important to recognise that many of our most
valued species and habitats are the result of active management by
farmers, for example, through grazing of livestock.
- NFU
Cymru believes the starting point for the development of any
proposed public goods scheme should begin with an assessment of the
public goods farmers are already delivering. We would
highlight, in the context of possible radical changes to the
trading and policy support environment, there can be no guarantee
that these baseline public goods will continue to be delivered in
the future.
- More information is urgently needed on the methodology by
which public goods, values and outcomes will be determined for
public goods. We have concerns that the sheer complexity in
identifying outcomes, their proxies and values may limit the
inclusion of very important public goods. The basis on which
public goods are included in the future public goods scheme may be
subject to lobbying pressure and not considered on an objective
basis.
- We
foresee that the process by which outcomes for biodiversity and
ecosystems will be valued and monitored to be highly complex and
difficult. The outcomes for biodiversity and the capacity of
farmers to deliver results is likely to be influenced by a range of
factors, many of which will be completely outside their
control.
- For
example, consideration will be needed of pressures and drivers of
biodiversity change at the appropriate spatial scale. Many
species on the red list, for example, will be migratory species and
subject to pressures outside Wales. A further example of
factors beyond the farmers control would be predation which is a
significant issue that is contributing to the decline of some
species. There will be a need to recognise that effective
species management varies from strict protection through to
deployment of active control measures where species populations
start to increase to unsustainable levels, impacting negatively on
their habitat and other species.
- The
timing of inspection for outcomes that are seasonal or weather
sensitive is an additional area where farmers could be placed under
stress.
- NFU
Cymru believes that the pros and cons of an outcome based approach,
therefore, merits further detailed consideration. Whilst the
inflexible, prescriptive nature of the Glastir Scheme has proved
challenging for farmers, results based approaches have their own
advantages and disadvantages. Thus far, such approaches have
been for singular priority environmental outcomes as opposed to the
delivery of multiple public goods. Results based approaches
have, to date, also operated alongside Pillar 1 direct support.
Welsh Government, through proposals, is in very much uncharted
territory as a result and great care is needed to ensure that
impacts and unintended consequences are fully
understood.
- It
is important to recognise that results-based approaches increase
the risk for farmers and embed an inherent volatility in the key
mechanism aimed at delivering rural resilience.
- The
provision of some public goods is reliant on farming activity and
the intrinsic links between public goods and farming activity is an
area which requires further exploration. Fundamentally we
believe a fundamental principle for moving forward should be the
development of a public goods scheme that pays for the public goods
and benefits arising from agricultural activity.
- Whilst the proposed Economic Resilience Scheme has not been
made the subject of this Inquiry specifically, we take this
opportunity to highlight that investments that improve productivity
of farm holdings can often deliver improvements in the
environmental performance of the business also.
- In
terms of the existing Welsh Government policies and legislation
that should underpin the development of the proposed Public Goods
Scheme, we would refer you the Well-Being of Future Generation Act
(2015) as well as the Environment (Wales) Act (2016).
- The
Well-Being of Future Generations Act establishes how all public
bodies must work to enhance economic, environmental, social and
cultural well-being of Wales. The proposed land management
scheme must be designed through this lens. Indeed, it our
view that it is only through achieving economic resilience that the
continued delivery of the range of goods and services provided by
farmers will continue to flow. The lack of coherence between
proposals in Brexit and Our Land and a wider suite of policy
drivers fundamental importance to well-being and the economy of
Wales is, therefore, concerning.
- We
are clear that economic resilience underpins environment, social
and cultural resilience. The delivery of biodiversity
outcomes will be one of many objectives that the future policy will
need to secure. We would further highlight that whilst this
Inquiry seeks to examine biodiversity and there will be
international commitments for Welsh Government in this area, it is
also important to note that there will be a range of international
and national obligations Wales has to meet and future policy should
not be used for the advancement of any one of these obligations
over another.
- The
requirement for future agricultural policy to deliver against the
Natural Resources Policy is, therefore, concerning and out of line
with the wider legislative agenda.
- The
Environment (Wales) Act (2016) establishes the principles of the
sustainable management of natural resources and sets outs ways of
working. We would highlight that the framework established
under this Act is still new and not widely understood. The
process of developing area statements for example, is at its early
stages. There are risks that area statements could result in
a post code lottery of support for farm businesses across Wales
– areas where public goods delivery is prioritised and areas
where food production is prioritised. In our view a scheme that has
as its sole objective delivering the Natural Resources Policy
cannot be assumed to deliver equal access to all farm
businesses.
- We
would be concerned if future public goods approach specified areas,
set boundaries, placed restrictions on what public goods can be
delivered where. We would highlight that the spatial mapping
process underpinning Glastir Advanced has been a significant source
of frustration to many farmers who have been denied opportunities
to participate in the scheme. Ultimately, the delivery of
outcomes for the environment is dependent on farmers wanting to
participate in schemes.
- In
terms of lessons that can be learned from GMEP, NFU Cymru would
highlight that we have long expressed disappointment that the
positive outcomes resulting from the investment of public funds in
existing agri-environment schemes like Glastir (highlighted above)
have been very poorly communicated or promoted to the
public.
- In
reality, farmers who have participated in schemes which have been
designed by experts, which are challenging to comply with and which
contribute a very limited amount to farm profitability as payments
are based on a cost-incurred basis, frequently express frustration
that they continue to be criticised for their environmental
performance despite doing exactly what they have been told to
do. This is an important point as it undermines confidence in
participation in future schemes.
- On
the issue of moving beyond ‘cost incurred, income
forgone’ calculations, we would highlight that Welsh
Government have stated as fact that the future scheme will not be
paid on a cost incurred, income forgone basis. Whilst this
would be welcome, at this stage NFU Cymru does not share the same
confidence that this will be achievable and 100% certainty is
required before progressing.
- We
would highlight that the stakeholder group established to guide the
operation of the GMEP programme has not been continued in the
ERRAMP programme and we believe that this is a significant
omission. A clearer communications plan by which findings can
be communicated is also required.
- Overall we would highlight that farmers in Wales have a long
track record of delivering practical environmental action and
management at farm level to deliver positive outcomes for
biodiversity. Before moving forward, Welsh Government must
seek to address the issues and uncertainties set out in this
response.
- NFU
Cymru believes that biodiversity obligations have to be balanced
with a range of other economic, broader environmental, social and
cultural objectives. We are clear that the focus of the
future public goods scheme should be on optimising multiple
benefits through sustainable agricultural
systems.
- We
note the invitation to submit oral evidence to the Committee on
Thursday 7th February 2019. NFU Cymru looks
forward to giving evidence at this event.