CAP Reform Post 2013 - Response Form

Department for the Environment, Food and Rural Affairs CAP Reform post 2013 Response Form December 2011

Please use this form to answer the questions contained within the ‘CAP Reform post 2013’ discussion paper.

The closing date for the submission of responses is midnight 5th March 2012.

Responses can be returned by email (preferable) or post.

Email address: [email protected] (clearly mark the subject field “Cap Reform post 2013”

Or by post to: EU Agriculture and Budget Strategy Team Department for Environment, Food and Rural Affairs EU Budget and Agricultural Strategy Programme Area 5D 9 Millbank C/O Nobel House 17 Smith Square London SW1P 3JR

In order to help us analyse responses, please provide details of your organisation below. Name The Heritage Alliance

Organisation / Company Charity

Organisation Size (no. of employees) 2.4 FTE

Job Title Policy and Communications Officer

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Address Clutha House, 10 Storey's Gate, SW1P 3AY

Email [email protected]

Telephone 0207 2330 500

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Public Sector (eg, local / central government, hospitals, universities) (please give details)

Retail Sector (eg, supermarkets) (please give details)

Service Sector (eg, cinemas, hotel chains, banks) (please give details)

Light Industry / Manufacturing

Property Management

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Research Institute

Other (please give details) The Heritage Alliance is the largest coalition of heritage interests in England. Established in 2002, it brings together 92 major national and regional non- Government organisations concerned with heritage. These include larger bodies like the National Trust, CLA, and CPRE, and many smaller organisations, supported by over five million members and thousands of local groups. Together Alliance members own, manage or care for the vast majority of England’s historic environment, and more than half of rural England. From specialist advisers, practitioners and managers, volunteers and owners, to national funding bodies and organisations leading major regeneration and access projects, their specialist knowledge and expertise across a huge range of issues is a national resource, much of which is contributed on a voluntary basis for public benefit. The Alliance has a specialist Rural Advocacy Group which has written this response. N.B. on the form below, please leave the response box blank for any questions that you do not wish to answer. All boxes may be expanded as required. 1. What are your views regarding the direct payments proposals?

The historic environment is rightly (see evidence in Q3 below) one of the five priority areas for agri- environment scheme funding in England. The Alliance is represented on DEFRA’s Rural Development Programme Monitoring Committee.

In our view it is important that the emphasis of CAP funding should continue to move away from income- support direct payments to farmers, and towards rewarding farmers and land managers for the provision of public goods, especially landscape, including the historic environment. This was the direction of movement established in the previous round of CAP reform from 2003, and it appeared to offer a defensible long-term future for the CAP in which its emphasis would move to delivering important environmental public benefits which the market would not provide.

We are therefore concerned that the Commission proposals do not appear to continue that direction of travel, and seem to be abandoning the vision developed in the Agenda 2000 reforms in which funding would transfer in stages from Pillar 1 to Pillar 2. Merely ‘greening’ Pillar 1 appears to deliver few additional public benefits at least in England, and very few for the historic environment, and may well conflict with the successful agri- environment schemes which as below do deliver proven environmental and historic environment benefits. We see Pillar 2 as a more effective use of public funds than Pillar 1, and are disappointed that the proportion of funding going to Pillar 2 remains at just 25 per cent. Worse, given overall budgetary pressure, and the addition of climate change as a further objective in Pillar 2, and reduced ability to modulate funds from Pillar 1 to Pillar 2, it seems likely that funding for existing Pillar 2 objectives will come under ever-greater pressure. Given that in England Pillar 2, especially agri-environment schemes, have delivered substantial benefits for the historic environment which would not have arisen in other ways, we are very concerned about this.

What do you think about limiting payments to ‘active farmers’? What do you think of the capping proposal?

We do not support these proposals. Although Pillar 1 payments are not targeted directly at the environment and as above are unlikely to be the most efficient means of delivering environmental benefits, for as long as they continue they do have direct and indirect benefits for the environment, including the historic environment, encouraging and helping to fund conservation work. Payments are only made where there is cross compliance, and (under these proposals) greening. The environmental benefits do not depend on whether they are carried out by someone falling within an artificial definition of ‘active farming’. An airfield, racecourse, water company, or an owner managing land primarily for heritage or ecological benefits, may deliver the same or greater environmental and heritage benefits as traditional active farmers. Nor do environmental benefits depend on scale of operation, for similar reasons.

As an example, we are aware of the National Trust’s concern that, although it is clearly engaged in large-scale farming activities which produce substantial environmental benefits, the ‘active farmer’ definition might make it ineligible for direct payments at all. The NT is also concerned that capping might reduce its direct payments by between one-third and two-thirds. Either would clearly have seriously negative impacts on its contribution to meeting EU objectives for biodiversity, water, and climate change, and on funding the historic environment, and put at risk the economic viability of many of its farming activities. Similar concerns apply to many other land managers of all kinds.

In addition, these proposals seem complex and arbitrary, discouraging the international competitiveness of English and EU farming for no adequately-explained purpose. They would also be likely to discourage diversification activities which have major benefits for the historic environment, like the repair of traditional rural buildings for sympathetic new uses.

What do you think of the greening proposal? These greening proposals obviously have little or no direct benefits for the historic environment. More importantly, Pillar I and Pillar II must work coherently together: we have concerns that greening may conflict with or damage existing agri-environment schemes, which have considerable environmental benefits, including (see below) important benefits for the historic environment. Again, we would not want to see funding for higher-level targeted schemes which are delivering strong and proven benefits for the historic environment and landscape being diverted into lower-level schemes.

2. What are your views regarding the single common market organisation proposals?

3. What are your views regarding the rural development proposals?

Do you support the removal of axes?

We do not have strong views on this, though there is a concern that it may dilute the importance currently attached to agri-environment schemes. Our main concern is with funding, both in total (see Q1 above) and funding priorities (see below).

Do you agree with the six strategic priorities?

Not as drafted. There seems to be a general view that landscape and the historic environment are implicitly included in the six priorities, and it is true that both are referred to in the Commission’s more detailed proposals (see below). But the lack of any explicit mention of landscape in the six priorities is very surprising, given that rural landscape is the first thing you see in rural areas. It is also worrying, because there may be an argument either that landscape and cultural landscape and the historic environment are actually excluded, or that their priority will be lower (perhaps we should say even lower) than before. It is therefore of paramount importance that “the historic environment” or “cultural landscape” is explicitly mentioned in the six priorities, probably by amending priority 4.

In England (as in most other member states) traditional farm buildings, walls, archaeology, and other heritage landscape features are a crucial part of rural landscapes, but most are redundant in the sense that agricultural use can no longer generate the income needed to sustain them. A high proportion has already disappeared over the last century, and continuing loss causes real harm to our landscapes. Where sympathetic economic re-use is not possible, agri-environment funding may well be their only chance of survival.

The historic environment is not covered by EU Directives, unlike natural heritage and biodiversity, and there is a real danger that it slips between departmental, national, and EU agendas and fails to be included in integrated approaches to land management. Its exclusion from the six priorities is another instance of this. There was very little funding to deal with market failure in the rural historic environment in the past, especially the large part of it which is not in public ownership, until agri-environment schemes began (at least in a modest way) to have a real impact on this. Agri-environment funding now provides some £23m a year for historic environment objectives, a small proportion of the current budget of over £400m but a crucial part of rural heritage funding. It has made a fundamental difference to the achievement of targets for the removal of heritage, especially archaeology, from Heritage at Risk registers. Heritage outcomes are acknowledged as one of the most successful elements of agri-environment schemes so far (Agri-Environment Schemes in England 2009: a review of effectiveness, Natural England, 2009).

The importance of heritage and landscape to the public (who are also the taxpayers who fund the CAP) has been demonstrated both by tourism and DEFRA research: the EFTEC Uplands survey carried out for DEFRA in 2006 showed that cultural heritage was the public good most valued by members of the public, significantly ahead of biodiversity objectives. And research carried out by the Countryside and Community Research Unit at the University of Gloucestershire on behalf of DEFRA showed that investment in the historic rural environment has significant social and economic benefits.

Which measures do you think would be useful for you?

We strongly welcome the references to landscape and to the historic environment in the Commission paper, including the references to “natural and cultural heritage” in the Pillar 2 paper paragraph (22); “renewal of villages and activities aimed at the restoration and upgrading of the cultural and natural heritage of villages and rural landscapes” in (24); the reference to “the protection and improvement of the…landscape and its features” in (28); to “restoring and preserving…the state of European landscapes” in Article 5 (4) (a); to “the maintenance, restoration and upgrading of the cultural and natural heritage…” in Article 21 1 (f); and to “the conversion of buildings or other facilities located close to rural settlements” in Article 21 1 (g). But as above we are very concerned that less funding may flow to these areas than in the past.

In addition, a particular concern is that funding must reach heritage buildings being converted to new uses, creating new rural economic activity, jobs or housing, projects which are usually ineligible for agri-environment schemes. There is much evidence of such projects creating new jobs and workspace (cf DEFRA/English Heritage Public benefits of historic farm building repair studies of the outcomes of traditional rural building conversion in the Lake District and Yorkshire Dales).

Do you support a continued role for LEADER, including a minimum spend of 5%?

We support a continued role for LEADER, which has had historic environment benefits in some cases, but have some concerns about its administrative complexity and that a minimum spend percentage might divert funding from the areas listed in our previous answer.

4. What are your views regarding the financing, management and controls proposal?

5. What are your views regarding the proposals fixing certain aids and refunds?

6. What are your views regarding the transitional arrangements for direct payments in 2013?

7. What are your views regarding the proposals to support vine growers?

8. Do you have views on any further areas you think we should consider concerning this package of CAP reform proposals? We would welcome Defra's continued recognition that any division between natural and historic is artificial since the cultural value of our landscapes includes both aspects. As the European Landscape Convention (to which the UK is a signatory) states, landscape can be defined as "an area…whose character is the result of the action and interaction of natural and/or human factors."

Thus an holistic approach is required in legislation and policy-making to recognise the fact that in England our living landscapes are all cultural landscapes. They are the place within which the natural world exists and a vital repository for our cultural inheritance in the form of historic features, archaeology, traditional buildings, distinctive settlements and local customs, traditions and produce. Field walls, water management, semi natural features such as hedges and woodlands and the landscape pattern as a whole provide diversity, beauty and the sense of place that defines our countryside.

This landscape inheritance is important for its own sake but also has the potential to benefit rural communities; to generate jobs and wealth, to attract inward investment and underpin tourism; to foster a sense of national, regional and local identity and to promote social cohesion. Landscape management and conservation also creates skilled employment. Our cultural landscapes should therefore be recognised as an important public good, and a powerful force to promote successful rural development.