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.
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!