CAP consultation – here’s one I prepared earlier (and have updated slightly)

This Corn Bunting can't respond to a government consultation whereas the farmer whose land it inhabits can.  The Corn Bunting would asl you to speak up for him if he could.  Photo: Steve Riall  via Wikimedia Commons.
This Corn Bunting can’t respond to a government consultation whereas the farmer whose land it inhabits can. The Corn Bunting would ask you to speak up for him if he could. Photo: Steve Riall via Wikimedia Commons.

In each part of the UK, the governments are consulting on how the tweaked Common Agricultural Policy (CAP) should be implemented.

I have drafted my response to the Defra consultation and here it is for people to comment on. If you like it you can simply copy and paste it into the consultation and send it off.

If you think I should say something different then please tell me – the consultation ends on Thursday.

If you care about wildlife in the countryside then you should respond to this consultation. There will be plenty of people who have an economic vested interest in this consultation who will be mobilising their troops.  Wildlife doesn’t have a vote or a voice – you can be that voice.

The consultation is well-designed although a few questions aren’t perfectly worded. And it’s a pretty complicated technical area so it isn’t easy for the lay person to respond. That’s why I have had a go but it’s also why I am happen to receive comments on my draft.

I have entered my comments on the consultation website but a nice aspect of that site is that one can save it and come back to it.

See what you make of it…

But don’t sit around moaning about the loss of wildlife in the countryside if you aren’t prepared to spend some time arguing its case. I guess this has taken me a couple of hours – it can take you not much more than 20 minutes (there’s a fair amount of copying and pasting if you use my draft).  This consultation is about your money, your wildlife and your countryside – make your voice heard.

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Question 6 – 150,000 euros the max any farmer can receive

Question 7 – salary mitigation should be allowed

Question 8 – we should implement redistributive payments instead of progressive reductions

Question 9 – the negative list should be extended

Question 10 – 25% the lowest possible

Question 11 – we should not add additional criteria

Question 13 – I disagree

Direct Payments comprise the vast majority of CAP funding.

Direct Payments provide no environmental benefits.

Direct Payments should be cut as much as possible and then greened as much as possible.

Question 14 – No – I want my taxpayer’s money going to farmers to be as closely linked to environmental improvement (and other public goods) as possible.The system is failing and it needs radical reform.  Please ensure my money is spent better – or I’d like my money back and you out of government please.

Question 15 – These are not great options but we are now stuck with them.  Land laying fallow is far and away my preferred option.

Nitrogen fixing crops, if clover, might deliver some benefits for pollinators but then the UK position on neonics is antipathetic to the needs of pollinators, isn’t it?

Question 16 – The UK approach to neonics has been unhelpful in this regard.

Nectar-rich patches are important – clover?

Question 19 – Axis 2 is the most appropriate element of the ERDP as it delivers public goods for public money. 

You really haven’t got a clue when you talk about building on its successes – do you?

The ERDP is shockingly badly designed, because successive governments have listened too much to  the NFU (the recipients of money) instead of the public (who are paying for this scheme). Agri-environment schemes are delivering too little for my taxpayer money.  Despite high coverage in land area, farmland wildlife is not recovering in England as shown in the NGO State of Nature report, the BTO/BWI/SOC Bird Atlas and numerous other scientific reports and publications (including the government’s own measures https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/252487/Overview_of_assessment_table_final.pdf).

At present, I would rather have my money back than see it wasted in this way.  

Question 20 – You have missed the point that ELS is failing very badly.

Question 21– You claim you are helping wildlife but the scientific evidence shows that you are not. Stop pretending that ELS has been a successful scheme and reform it so that its successor is successful at reversing wildlife declines.

Question 22 – overwhelmingly the proper way to spend Pillar II money is delivering public goods rather than intervening in farm businesses in other ways. The priority should be to deliver environmental good  through Axis 2 much more efficiently

Question 23 – Switch money from Pillar I to Pillar II.

Prioritise HLS approach over ELS approach.

Improve design of ELS in successor scheme.

Question 24 – Have fewer, more effective options in ELS’s successor.

Question 25 – No problems in that respect with what I have suggested.

Question 27 – I’m concerned that those farmers who have been in HLS may not get access to continuing support.  If this happened then it would mean that we, the taxpayer, had supported ephemeral wildlife benefits through temporary funding that then disappeared.

 HLS has been a very successful scheme and I can see that some of its benefits will be protected in the site specific element of the new scheme. It is not clear from the consultation whether existing HLS farmers whose land is not designated will be able to continue to receive funding. What is your intention?

 I would be in favour of continuing investment in most HLS-supported farms.  Is this what is intended?

 It is biologically easier, and economically more effective, to protect existing biodiversity warm-spots (there are few remaining hot-spots in the farmed countryside) rather than create new ones.  protecting what we have also provides the islands from which recolonisation of wildlife-poor farmland can happen.

I support the intention of the Area Specific option to favour the ‘right’ options.  For example, skylark patches should be difficult to avoid in those arable areas where winter cereals predominate,  This option has been proved to work biologically, and is of trivial inconvenience to any efficient and conscientious farmer.  It’s exactly the type of option that should be pushed since we know, from CFE, that the farming unions will not promote its voluntary uptake effectively.

I believe that much wildlife benefit could be achieved through a smaller public expenditure on a smaller area of land if the scheme is well designed.

Question 29 – link Single Farm Payments to regional trends in Farmland Bird Index. Birds increase regionally – so do payments for all.  Birds decrease – so do payments for all. We’re all in it together as someone once said (though he didn’t mean it).

Let’s reduce any payments, year on year, to those landowners farming in SPAs for Hen Harriers, Merlins, Short-eared Owls where numbers are below the levels that led to their designation (which I think will be all of them).  Why should landowners be paid for good stewardship when their stewardship isn’t delivering the wildlife for which the site was designated? In fact, if money is tight, then withdraw it from the English uplands for the next five years and spend it on lowland farmers currently in HLS.

Question 31 – Yes – or longer still. 10 years would be much better.

Question 32 – Areas of depleted farmland wildlife but where that wildlife still exists in reasonable numbers.  in other words, places in need of restoration but where there is still something to work with!

Use recently published BTO/BWI/SOC Bird Atlas, Plantlife’s studies of arable and other farmland plants and nous of invertebrate experts (eg Butterfly Conservation, Buglife, Bumblebee Conservation Trust) to target areas. Give them 3 months to come up with proposals and don’t take much notice of NFU or CLA on this subject.

Question 33 – Are you suggesting giving less face-to-face advice to landowners through NE etc? That would be flying in the face of all advice on how to win over farmers.

Yes, more online etc but ‘no’ to reduction in face-to-face contact. And no, most third parties who are in it for the money will not deliver this advice particularly well. You’ll be suggesting privatising prisons next – oh, you have!

Seriously, the best outcome would be to ensure that NE has enough well-trained staff to deliver advice in line with government policy.  Having cut the NE budget and disillusioned many of the remaining staff, you haven’t got off to a very good start on this.  If NE is a ‘delivery agency’ then you need lots of motivated and well-trained staff to deliver advice that will deliver farmers’ actions that will deliver more wildlife on the ground that will deliver good value for money.

If you use third parties without ensuring the quality of the advice you will save money on advice delivery and continue to waste huge amounts of public money on failure to deliver results on the ground.  This is a tricky area but it is important.

Question 34 – Quite high.  This isn’t a very clear question.

My answer to Q32 is relevant.

Question 35 – This is government intervening in inefficient businesses.  Public money should be for public goods. Forget all this and save on scheme administration.

Question 36 – Public money for public goods – if those public goods are efficiently delivered – haven’t you got this message yet?

Question 37 – Face-to-face advice from people who know what they are talking about and are public servants not looking to make a fast (or even a slow) buck.

Question 39 – This is government intervening in inefficient businesses.  Public money should be for public goods. Forget all this and save on scheme administration.

Question 40 – This is government intervening in inefficient businesses.  Public money should be for public goods. Forget all this and save on scheme administration.

Question 43 – yes we should transfer money from Pillar I to Pillar II and yes it should be the maximum amount of 15% – even that is too low!

Question 44 – 88% envt; 3% competitiveness; 4% LEADER; 5% growth.

Public money for public goods.

Government is inefficient at increasing competitiveness – particularly with handouts.

I would cut LEADER, farming competitiveness and growth even further if I could.  Why is government meddling in these areas?  It is hardly Conservative policy to prop up inefficient businesses.  Public money for public goods!

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67 Replies to “CAP consultation – here’s one I prepared earlier (and have updated slightly)”

  1. I would agree with almost all you say Mark, but we need to remember that currently many grouse moors are SSSIs and are entitled to claim HLS money vaste quatities of it yet we have no Hen harriers, no breeding Peregrines and precious few Short-eared Owls on them, my own belief is until this changes they should be getting no such money.

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    1. Paul - good point. I have updated my answer to Q29 appropriately (well, I think it's appropriately). Thank you.

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  2. I haven't yet seen a conservation body's response, but think that DEFRA proposals supported by the NFU include:

    - small farms do not qualify for any support. This is ostensibly to save on admin (?) but of course means more money available for large landowners for whose benefit the NFU is run. If I have interpreted this correctly, it would rule out small conservation bodies getting CAP support as well as organic smallholders and other non-intensive agricultural businesses.
    - small areas of land do not qualify for support. This is another interpretation of the above, which would discriminate even more against conservation NGOs, especially local wildlife trusts who tend to run small reserves.
    - only 'proper farmers' qualify for support. This if true would obviously benefit NFU-style intensive farming, and discriminate against conservation bodies. The NFU proposal seems to be that only if you earn a living mainly from food-production can you qualify. So wildlife trusts would be ruled out - in fact anyone who owns some land and is managing it for wildlife conservation, or even in a less than full-on intensive way.

    Have I interpreted these correctly, or have I mixed up the proposals with an NFU wish-list? If this is correct I would have expected more of a noise from conservation folk in general.

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    1. OK, just had an answer from DEFRA. Landholdings less than 5ha are going to be EXCLUDED from CAP payments: a potential disaster for conservation.

      It should not matter what the size of the landholding is: it is the management that counts.

      This is a blatant attempt to take environmental payments away from conservation bodies and put it into the hands of NFU members who won't exactly bust a gut to do anything environmental with it.

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      1. Jamie - I disagree strongly.

        Under the current SPS system, landowners with as little as 1 ha of eligible land can apply. This is plainly ridiculous and offers the tax-payer a spectacularly poor deal. Thanks to the RPA, the costs of administering SPS are staggeringly high and in reality it doesn't cost much less to process an SP5 form claim for a 4 ha small holding as it does for a 40 ha farm. The small holders and pony paddock keepers, who all of a sudden became eligible for Pillar 1 payments in 2005, previously managed to scrape by.

        I post this comment as the owner of a 2 ha wildflower meadow, on one-hand I suppose it would be nice to think that I should receive an annual cheque from the taxpayer for £440 - £500 each year for doing absolutely nothing, but in reality the total cost to the taxpayer would be significantly greater once the RPA have weaved their administrative magic. Therefore I have never claimed.

        "This is a blatant attempt to take environmental payments away from conservation bodies and put it into the hands of NFU members who won't exactly bust a gut to do anything environmental with it"

        I don't think you need worry, I really cannot see how lifting the minimum area to 5 ha would impact the likes of TWT, rspb, WWT & NT in way, shape or form.

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      2. Jamie - Ernest has beaten me to it. i don't think this is aimed at conservation organisations, and I don't think it would affect them much at all. i imagine it is aimed at what tend to be called, rather disparagingly, 'hobby farmers', who have acquired small parcels of land for horse grazing or keeping their pet llamas or some such. As ernest says, the large number of small holdings increase the costs of administration greatly and are probably not that important in either food production or environmental terms. though, having said that, i expect, as with most rather blunt policy approaches, there will be some deserving folk who will be disadvantaged.

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        1. I have heard mutterings about NGOs whose core business is not farming being excluded from the SPS in future - is there any truth in that?

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          1. filbert - you've been talking to too many farmers! Seems very unlikely as buying and selling land would get quite complicated! Best way would be to limit payments to any single landowner - as in blog above. That would apply to all sorts of folk.

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        2. Your usual measured analysis. I would just point out (in environmental terms) that the Suffolk Wildlife Trust realised there is such a large area of what you seem to refer to as “sum such” areas in Suffolk that they appointed a member of staff to record and advise on what was unfortunately called, but are, Private nature reserves and are now called the Nature Network. They are not SSSIs but ...
          Also in biodiversity terms surely the maligned horse paddocks are the equivalent of our rabbit grazed heathland turf in other parts of the country. Pied Wagtails seem to be particularly associated with horse paddocks. Does the BTO have any data that can link the two.

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  3. Mark, I agree its a difficult technical area to comment on but persevered on Friday to submit responses to most questions, as this is so important. I applaud your offer to share your answers before submitting and to allow others to make use of it. Broadly I would concur with many of your responses.

    Things I'm in particularly strong agreement on: the key role of face to face advice for farmers and (Q27) ensuring that HLS farmers do not suddenly find the rug pulled from under them. I agree that skylark plots deserve a particular push and (wish I'd thought of it) should be well-nigh compulsory given the tremendous results they can deliver, weighed vs the negligible land-take.

    I was uneasy about the way the Ecological Focus Areas seemed to be pre-occupied with the pollinators issue? Whilst I'm in no doubt pollinators are of critical importance, I had a sense that EFA obligations might be too easily waved away by planting some fields of clover, rather than addressing wider resource protection and farm wildlife issues in an holistic way. Not sure I managed to express this though. Perhaps you can do so more adroitly.

    In Q28, my response was 'a flexible approach is needed as different areas of the country will have different ways of coming together through (EG) LNP,s NIA's, Landscape Partnership Schemes, National park or AONB initiatives, smaller partnerships between farmers and local heritage or conservation organisations.'
    I worry that if they are too prescriptive it will preclude models that may yet arise.

    Also I feel that 5 yrs (even 10yrs) is not long enough for farmers to take long term business decisions (particularly in my realm for wetland options). This came up in Q31. Finally, I found the percentages question very difficult Q44 as I do not know what the current funding split is... however at Envt 80% , Competitiveness 6%, Growth 6%, LEADER 8% I'm rather comforted to know that mine was not too dissimilar to yours.

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    1. Tim - many thanks. The current split is 83% envt, 4% LEADER, 5% competitiveness and 8% growth according to Defra (there is a button to click where you can find this info).

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  4. Is 'consultation' just another word for 'opinion'?

    And we all know what this Government thinks of 'opinions'.

    So I suspect that all responses will be dismissed as opinions and ignored, unless of course, they support the Government's objectives. In which case, it's science.

    Richard

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  5. Thank you Mark, and others,

    This is hugely valuable to me. I am quite shocked that despite a degree in Zoology from a reputable university (I am pretty certain we sat through a few lectures in the same room, Mark), being a competent naturalist, and a lifetime spent working with conservation bodies and hanging out for fun with ecologists (Reader, I married one), I still do not feel competent to address these questions without access to this sort of help. I am very grateful to you all for enabling me to participate, moderately intelligently, in something that is so important to me.

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  6. Susan - I wonder if its meant to be that way ?

    My one concern with the cap on CAP, which is in theory a good idea is who is it going to catch ? I've always worried it'll get NT, RSPB etc but the people its aimed at will simply split their farms around the family and duck under the net - isn't that the way things work for the very rich these days ?

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    1. Roderick - yes, perhaps. Of course it won't catch the Wildlife trusts, or at least not as much, as it would the RSPB and NT.

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  7. Mark, you appear to have nailed most of the questions, however a couple of points that you may wish to reconsider.

    Question 33: "And no, third parties will not deliver this advice particularly well"

    Have you thought this one through ? The bottom line it depends on the who the 3rd party is. If we are talking about well-qualified, well-informed ecologists who understand the practicalities of farming then the answer should be an unequivocal yes. Thanks to the last Government, a large proportion of Natural England's 'Land Management Advisers' have no formal environment training or environmental qualifications and limited knowledge of wildlife. Why should they ? Many of them worked for the RPA processing IACS forms, undertaking field inspections, processing beef special premium scheme claims etc. When it was decided that cuts had to be made at the RPA, they were sent on a series of one day training courses and turned into 'land management advisers', despite their being an abundance of significantly better qualified ecologists in the job market place that could have been appointed to these positions. As a result of the skill gap that exists, NE has become increasingly reliant on formulaic and generic land management prescriptions, which in many cases is to the detriment of wildlife.

    Last summer I spent a few hours on a site with an NE staff member, who despite having been in post for several years, was clearly uanable to recognise and indentify fairly basic grasses and flowering plants. I was really quite shocked and saddened.

    I think it was a Dutch study that found that one of the most important factors in influencing the decisions a farmer makes regarding agri-environment schemes, is confidence in the person providing the advice.

    I would also argue that contracting out advice provision to suitablly qualified 3rd parties is likely to offer the tax-payer a much better deal, plus what is to stop the rspb or TWT's providing some of this advice ?

    Question 44: I would tweak this to 89% envt: 7% competitiveness; 2% LEADER; 2% growth.
    I think it makes sense for environmentalists to support capital grant schemes such as the Farming & Forestry Improvement Scheme, these are funded under the heading of competitiveness. FFIS provides grant aid, typically up to 40% of costs of projects costing up to £25k. Applicants are assessed on their ability to meet one or more of six objectives: 1, Improve animal health and welfare 2, Reduce energy usage 3, Improve the management of manures 4, Improve soil quality 5, Improve water resource management 6, Improve use of forestry resources.

    Last year, I know from experience that FFIS helped two small family run dairy farms purchase trailing shoe slurry spreaders, purchases which have made significant improvements to the nutrient efficiency on both farms. I also know of a small family run forestry business that was able to purchase a low ground pressure, tracked machine, for extracting timber from lowland bog sites being restored under HLS. They could not have afforded it otherwise.

    These are things that environmentalists should be supporting, imho.

    I'm really not sure about LEADER these days, the whole process always seems overly bureaucratic these days and too reliant on uninformed committee panel members.

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    1. Ernest - thank you. Think you make a good point about Q33 - I will probably reword that. My concern is that the state gives up on advising farmers and any old Tom, Dick or Harry (they all sound like land agents to me) gets involved with rather little buy-in to the aim of the schemes or the needs of the environment.

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      1. In my experience state-sponsored advisers have so little time allocated to a job that they can do little more than trot out the state-sponsored line, as per the advice template. Their advice is limited also by the policy boundaries of their employer. The needs of the client farmer and the environment are not necessarily served well under this regime. Do you remember the popularity of Painting by Numbers, years ago? Well ...

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  8. I've change many of these as youth employment in the countryside should be a major issue especially as forestry seems to have lost its way. Walked in a great wood yesterday which used to have Lesser spotted Woodpecker. The timber was amazing but the understorey was dominant. [too many deer removed!] natural regeneration was every where but was this the reason for the loss of this woodpecker. As a young lad starting out in forestry a Yorkshire bill was always in my hand [despite the blisters!] and the job was often clearing the forest floor and marking bigger trees for felling. Certain jobs are best done by labour [unless you want to bring fire back!]

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  9. I assume that this "consultation" is just a public display of the government being seen to consult. Like all important decisions, they have already been made before public "consultation"? Natural England will not oppose schemes such as windfarms because NE are probably instructed not to interfere with "business." I wonder if our guardians of our Environment are now surplus to requirements? Thatcher said this country should be like America. It is.

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    1. Why would they, Natural England will receive £55,000 for 35 years as a result of accommodating E-On's access across public land at Tween Bridge wind farm, Thorne Moors SSSI. The local community pot is a mere £50,000 for 25 years!

      To be fair I suppose they (local staff) did put in an objection at the start (whilst Senior Directors negotiated behind behind closed doors). The funds are retained by HQ and are not allocated locally, so no serious monitoring of impact upon interest features.

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  10. Are public consultations true consultations or not? Who knows? I often suspect they are merely policy-based evidence gathering, supported by bias-confirming responses. But without public consultation some law cannot be enforced - as the EA know

    Consultations ought to be a means of viewing the spectrum of opinion, or even some informed views, but the medium of online submissions is making things very iffy. A couple of years ago there was a Green Food consultation that took the form of a blog, as I recall. As the days went by it became clear that every swivel-eyed loon in the country was hunched over their keyboard tapping out their prescription for sustainable malnutrition. I have great sympathy for whomsoever had to filter the workable ideas from the gibberish.

    To copy and paste the responses of one person subverts the process of consultation. A true consultation by intent is no longer true once duplicates are returned.

    Copying and pasting views of another online could be dangerous - to borrow from elsewhere, it would be tragic if Dr Avery woke up one day and found he had been elected President of Zimbabwe

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    1. filbert - consultations are an opportunity to influence government policy. I could give you plenty of examples where I know that either weight of responses or particular arguments had some influence on what looked like a done deal. I'd say this particular government is less susceptible to good argument than others though.

      There is nothing disreputable about offering help to others on to how to fill in a complicated form - and this subject is really quite complicated. This is a consultation about how the countryside is managed and funded - and it is we, the electorate and the taxpayer who should have a major say in those subjects. Making it very difficult to comment because of the complexity of the issue is not very helpful and actually I think that Defra has done quite a good job in making this relatively simple - but relative simplicity in the land of the CAP is not very simple.

      All responses received will be published. I'll be interested to see what the NFU, CLA, RSPB, WT, NT etc say in their responses. I'll do an analysis of the responses at some stage.

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  11. Mark you said in reply to Earnest above you might reword Q 33. I already thought it might be better if environmental enthusiasts advised farmers. The enthusiasm would help in convincing the farmer. ( think it was on this blog I saw a farmer saying he had done env. work but no one came to see the effects.) I agree it would be catastrophic if just any one who had done a course was able to compete, but it sounds (from Earnest) as though that is the case anyway.
    Already RSPB offer advice especially for certain things like cirl bunting, the WLT here has specialist advisers, there is FWAG.
    Can you see another way forward.

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  12. "nothing disreputable"

    I didn't say it was. But copied and pasted replies give a false impression of a consensus whereas it is the response of one person. It's akin to to shilling an auction. Identical responses could of course be dumped by anti-plagiarism software, if anyone had a mind to.

    It would be nice to think that we the electorate and taxpayers have a major say but in truth it is a tiny unelected subset - vested interests, advocates and activists - who have a disproportionate influence on outcomes. That's before we even get to the Delphi-like facilitated stakeholder workshop stage.

    That reminds me - I must get round to sacking my bank. Ethics, schmethics ...

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  13. Thanks, Mark I have responded much as your draft, with a few tweaks. I wouldn't have been able to fill all this in without your prompts!
    Rowena Baxter (Cambs Bird Club)

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  14. Farming must be the only business that receives huge amounts of taxpayers money and still can`t get it right. Its time to totally rethink how this money is spent and that
    means using it to grow food as well as helping wildlife etc. The comments about grouse moors are also valid, here is a totally useless man made ecosystem that is crying out for change.

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  15. Oliver, sorry are you saying that the 0.5% of the population of the UK who provide 60% of the food consumed in the UK just can't get it right ?

    I've got an an idea, give up the day job and come and give us a hand, you know just like it was in the old days before Tesco and the CAP. Don't you just miss the good old days. !

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  16. Job done. I used your responses, Mark, but changed the wording as much as I could to make it sound more independent. I wait with baited breath for the outcome...

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  17. Sorry slight update on that figure after a bit of research. It's not 0.5 % of the UK population it's actually 0.23% and out of that tiny workforce. (140,000 as a last census) 16% of them provide labour for exports of food. I can't do the math as the Americans say but CAP consultate all you like but don't expect miracles on the environmental front as we're all a bit busy at the moment !

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    1. Julian - maybe you'd like to tell us what your answers to some of these questions would be? How about starting with Questions 6, 21-27, 29, 43 and 44?

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  18. Okay Mark, sorry I was fooling about a bit but since you've set me some homework.

    Question 6

    I would agree with you however my best result would be no subsidies at all so long as this was no unilateral.

    Question 21

    Els is a difficult with low labour available. The options worth doing are rotational but ultimately the scheme forms such a small percentage of the business but consumes disproportional time. Result easier to implement options are chosen. Reform could be so simple, just go back to the CSA model.

    Questions 22-26

    Pillar I or Pillar II it's just an argument for people who answered question 6. My view is get rid of all the subsidies. Base farm support on the federal crop insurance model on the US and let the market rationalise the industry. Again it has to be level playing field for all producers.

    Given that's not going to happen, yes reluctantly I suppose I will have to play the game so I'd agree, support HLS

    Question 29

    Very funny. Could we include Pheasants please.

    Questions 42-44

    It's all just messing about at the edges. CAP payments are dropping considerably and the max 15% will be modulated.

    Farm businesses will continue to consolidate and simplify. The SPS payment will continue to form less and less of the TIF income.

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    1. Julian - excellent! We agree quite a lot and you are, it appears, a farmer. I always like that. Thank you for your homework - you get high marks!

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  19. Oh ? I'm surprised I thought you were a bit left wing liberal interventional sort of chap. Obviously I'm wrong.

    Your of the mark on the fallow land response. Very bad for organic matter and soil erosion. Always plant a cover crop, there's no fallow on nature ( apart from sand of course )

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    1. Julian - you're right of course. But I'd like to see Pillar 1 dropping like a stone as it is a payment without a policy (so we agree there). And I believe we could get much better value from less money in Pillar 2 if it were spent in the correct left-wing interventionist way (so we agree a bit there, reluctantly perhaps). And you favour HLS over ELS - and I strongly do (so we agree there too). They should put us in charge - I'm sure we'd find a way through this despite a gulf of political ideology between us - what do you say?

      I imagine temporary fallow a bit like set-aside - that was jolly good for wildlife (even though it was by accident not by design).

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  20. Thank you, Mark. I make an effort to participate in all relevant campaigns and petitions and I certainly needed help with this one!

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  21. I'm sure we would. I had an old employee of yours out here a few years ago (STom) and we discussed exactly this scenario of environmental concerns versus a changeing agricultural industry and the effect of reduced subsidies on both. Simplicity is the key to unlock motivation (every farmer would do his bit if he felt he wasn't being drowned by rules)

    Here's some radical solutions for you.

    Get rid of cross compliance. It's madness and the implementation is farcical.

    Introduce a simple menu based system for environmental payments, no form filling, no maps, no ridiculous measuring of ditches or counting trees onto forms. Self assesment backed up by inspections. Take the savings in IT and support staff and role it back into the payments. HMRC and VOSA already run self assessment with vast savings in admin.

    Bring in GM, it's going to happen so why not just get on with it. Use a biodiversity offset for those who want the advantages of the technology.

    Introduce best practise credits on payments. Organic matter improvements via better soil management with carbon credits would be an obvious one as would say reduced agrochemical or fertiser applications. All self assessment as above.

    Use your Pillar II monies more intelegently. You can invest in businesses to add value to the environment. For example GPS systems for more accurate use and lower use of inputs to crops, modern low disturbance drills and cultivators to improve soil organic matter, training on soil and crop integrated management. Cover cropping used extensively in the US has massive benefits both to the business concerned and the environment. The environental savings are vast (eg fuel use cut by 80% etc) There's no cash, expertise or machinery in the UK or EU to even begin to close this gap.

    Okay none of this going to happen, back to reality. Nothing like a consultation to create a sense of hopelessness !

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    1. Julian - that's very stimulating. We must share a bottle of wine some time.

      Happy to get rid of cross compliance as soon as we get rid of Pillar 1. Cross compliance is there to make sure that the billions of £££££ going to farmers each year have some conditions attached to them. At the moment there is lots of money, lots of paperwork, and rather few conditions that aren't already legal necessities. I'd add more conditions - but then I'm a lefty!

      We have a simple menu-based system - except it's too easy to get money for old rope and there is too much money spent on checking. I'd favour big fines for farmers who cheat - but there have to be some rules otherwise no-one knows what cheating is.

      I am not ideologically opposed to Gm crops - but I would want them to prove their environmentally benign nature. I wouldn't object to neutral or positive GM crops.

      Not sure how best practice credits would work - sounds interesting. Can't really see why I, the taxpayer, should pay for an industry to use new technology that will save it money!

      Many thanks!

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  22. Thanks Mark, I've filled in as much as I could using your "answers", with a few tweaks and additions from me, especially on diffuse agricultural pollution. I couldn't and wouldn't have done it without much help from you, and even having skimmed some of the consultation document struggled to grasp the detail. The consultation requires some fairly indepth knowledge to really do it justice, which I don't have, no matter how much I care about the environment and dispair at its current state of health. Is this a deliberately "niche" consultation, only accessible to those already in the know?

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    1. Sian - well done for raising your voice for nature.

      To be fair, I think the consultation is better than many. It is a complicated subject and there is quite a lot of explanation in the consultation. But it certainly isn't 'man 9or women0 on the Clapham omnibus' easy to understand! I hope I've understood it.

      Certainly, the main respondents are likely to be NGOs (not many though), farmers (not that many though, I'd guess), farming unions, agribusiness and some think tanks. But we'll see when responses are published.

      Given the complexity of the issue, it is unlikely that many 'ordinary' people will respond - which is a pity since there is a lot of money from ordinary people involved. That's why I tried to make it a little easier to respond. Thank you for taking the time.

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  23. Filbert's scepticism about Government consultation is justified - but I don't think it is 'cheating' to follow Mark's lead on a consultatio0n where the complexity is such it is exactly the sort of thing that is eroding democracy - whilst at one level that complexity is unavoidable, at another there will be some (many ?) who would be anything but upset if it resulted in only establishment insiders responding.

    Where I think consultation falls down is if decisions are made by weighing the pile - policy making should be about more than that but we have a fundamental problem within Government in that the people assessing these consultations are usually generalists, bright guys with excellent degrees in say History (like Owen Paterson) or PPE (David Cameron, Ed Milliband). I wouldn't argue that farmers should make the decisions on CAP - although by default I suspect most of the professional input come straight from NFU which as you'll recall from the BADGER FOI can be considered almost part of Government ! - but it really would help if policy makers had a grounding in , for example, soil science, genetics and similar.

    On GM, I agree with mark: not ideologically opposed, but unlike him I couldn't say I am neutral: I was always suspicious at the level of real assessment carried out on possible implications and am shocked rigid by the reports of weed resistance in Brazilian GM Soya: far from being a boon, my present view is that GM could turn out to be one of the most serious threats to world food supply imaginable and no, I'm, sorry, I'm not convinced by Owen with his history degree any more than I am by Nigel Lawson on climate change - but, for once, I do find myself agreeing with Chemistry graduate Margaret Thatcher on CC.

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    1. "consultation falls down" if decisions are made by weighting the pile - was my point.

      Policy-makers with a grounding in , for example, soil science, genetics and all that there - would be lovely but went out with flared trousis. Moreover, CAP policy stuff is likely to induce catatonia in people interested in the interesting.

      GM: I was always mildly opposed because the first cultivars offered protection against yield loss but no inherent yield advance - so why bother? There was obviously great benefit for Monsanto, faced with the expiry of patents for glyphosate. Weeds resistant to glyphosate are now abundant on every continent - given the quantity used worldwide it is surprising it took so long for resistant biotypes to appear. It is almost a given that virulence will evolve in weeds, insects or plant pathogens for any resistance measure that is introduced be it chemical or genetic. Wild oats and blackgrass are good examples closer to home - no GM involvement there. There are some promising lines of development going on which don't on the face of it have any drawbacks, unless it is mint flavoured bread or sourdough flavoured chewing gum. I wouldn't be lining up to oppose N-fixing cereals ...

      As for Mrs T - while she accepted the plausibility of warmism because she had heard of Arrhenius and was an early advocate of action to mitigate the anthropogenic element of climate change, she later decided she was for turning after all. By 2003 she was backtracking on her earlier advocacy, calling climate activism a "marvellous excuse for supra-national socialism," and denounced Al Gore's calls for international action on climate change as "apocalyptic hyperbole."

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    2. Then there is this sort of stuff to mull over.

      http://www.theecologist.org/News/news_analysis/2176082/deformities_sickness_and_livestock_deaths_the_real_cost_of_gm_animal_feed.html

      It's also worth remembering that - afaik - most glyphoshate is manufactured in China, and that wetters and adjuvants may be present in commercial formulations in addition to glyphosate.

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          1. Wouldn't work on Firefox, does on Safari.

            Interesting, if not more than a little concerning, stuff.

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  24. Phew. Finished it. Thank you for your help. Sad to live in a country where lobbying is necessary for every single thing. Also sad to have seen the demise of so many birds in the short 16 years we have lived in mid Suffolk.

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    1. Anne - not sure that having a say can be worse than not having a say. Government can't really win on this one.

      Mid-Suffolk. You are in one of the few areas where it might be possible to see Turtle Dove, Corn Bunting, Yellow Wagtail, Tree Sparrow and Grey Partridge in the same day. do you, ever?

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      1. No. Obviously glad to be able to have a say and have the problems brought to our attention. Really appreciate your input and that of all the wildlife organisations.
        Thanks.

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  25. Mark try this link if you have a moment, the French are miles ahead of us in conservation tillage. The environmental benefits and cost savings to farming are immense and the depth of science which us building up behind this is impressive. Pillar II support into this sector to try and replicate the rests in the US and Canada would be more than justified.

    Julian

    http://agriculture-de-conservation.com/sites/agriculture-de-conservation.com/IMG/pdf/lifs-jrc.pdf

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    1. Julian,

      The benefits of conservation tillage really hit home to me during the very wet summer of 2012. In my area, it was so obviously apparent that those farms who had been implementing conservation tillage practices for a good few years were able to cope much better with the excessive rainfall. Their crops looked better, they were able to access the land much more easily and in some cases had harvested and drilled-up whilst others on similar soil types still had standing crops.
      It was a real eye-opener.

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  26. In the good old days farmers had dairy herds. The bi-product of winter storage of cattle was spread on the fields to promote increased food yields. In sandy areas the manure helped bind the soil together. Now the top soil is blown away in the march winds. Milk quotas drastically reduced dairy herds. This in turn removed many pastures and with it grassland birds. Every seven years in our area, fields were left "fallow" to rest. This prevented the need for intensive chemical substitutes, the build up of nutrients being supplied by a crop of clover. Because animals were in the pastures, hedges were needed to enclose them. This in turn provided habitats for wildlife. Ponds were excavated for the cattle to drink from, this was a home to amphibians. In which direction are we progressing? Do we need a "policy on farming" when we have learned how to do it for thousands of years?

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  27. Earnest, I'm not surprised. I spent a training day on Thursday with BASE Uk listening to Frederick Thomas who has been both practising conservation tillage and heads up the French equivalent to BASE over there. The advantages of understanding how actually some very simple techniques can be adopted is actually a mind blowingly complicated subject. Still when you hear that ten year trials have increased yields by 20% while reducing fertiliser inputs by half you start to get quite involved. Certainly if I could adopt 10% of what I saw being done in Europe mainland I would transform my business however there is a considerable capital and technological investment to be made and it will be a long process...one I'm quite excited about however !

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  28. thank you for this Mark. Very hard for most of us to do enough research to make any sort of meaningful response. While it's a pity to just 'cut and paste' it isn't just one person's response, it's lots of people's responses although influenced a good deal by one person. But that's because we trust your opinion to a large extent. The flaw in democracy: the ignorant get the same vote as the well informed, although the politicians daren't mention that of course!

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