RDC(3) FOU3
Inquiry into the Future of the Uplands in Wales
Response from The Country Land and Business Association
The CLA welcomes the opportunity to respond to this consultation. CLA Wales represents some 4,000 members owning and managing a significant number of rural businesses of all types from agriculture and forestry through to tourism and diversified commercial and professional interests. As a result they stand at the heart of a rural economy and are reliant on an adequate infrastructure of communications, public services, recreation facilities and above all suitable and affordable housing.
As owners of land their businesses generate jobs and income, and they have a commitment to the long term health of their communities. A sustainable countryside is one that is not only environmentally thriving but also socially and economically prospering.
What form should future public support for the uplands take (including a consideration of the European Commission’s emerging proposals for the designation of Intermediate Less Favoured Areas)?
Agriculture and forestry remain the major land use of rural Wales, but with 80% of Wales historically defined as Less Favoured Area (LFA), the ability of upland farmers and land managers to compete in domestic and world markets remains tough.
Within the WAG’s ‘2020 Vision’ strategy document in 2008 – “Food, Farming and Countryside: Building a secure future”, updated in March 2009 to include CAP Health Check agenda items particularly climate change issue under the ‘Challenge Agenda’, the objectives are to achieve a more profitable future for farming and its associated industries; sustaining the family farm whilst safeguarding the environment; mitigating climate change and maintaining vital and prosperous rural communities. It emphasizes more effective collaboration to connect effectively with the market, sound farming practices with public support to achieve environmental objectives, and advancing innovation through rejuvenation. All worthy aspirations but the underlying challenge is that few farms, if any, in Wales are economically viable without SFP especially in the LFA.
Global competition, exacerbated by zealous regulation, will leave much of the future in the balance. Farming and the food industry has shown itself ready to adapt and change, but the WAG must make the necessary commitments if the industry is to meet the challenges of delivering a well-managed landscape, mitigating the effects of climate change, ensuring a choice of safe, high quality food at reasonable prices, and promoting thriving rural communities.
More difficult for Wales to deal with are the discussions about moving away from historic based entitlements to simpler, more decoupled, area based payments under Pillar 1. The rationale behind the principles of this move needs to be coherent and consistent if they are to be defended. If they are in return for land management’s supply of non-marketable ‘public goods’, then it is important that support for the Uplands/ LFA reflects this, as the opportunities for expanding agricultural production are limited by comparison to better land, but landscape and environmental values abound.
The current policy debate on the future of CAP post 2013 centres around the evolving concept of Food and Environmental Security (FES), which has yet to form a consensus. The CLA see Food Security as the long term protection of food production capacity, feeding Europe and contributing appropriately to feeding other parts of the world, and the Environmental Security element as achieving this whilst protecting and enhancing the natural environment wherever possible.
The challenge in discussions over the future of Axis 2 and designing WAG’s Glastir scheme should reflect this balance. The CLA are concerned that policy adjustments are necessary for Welsh upland areas if we are not to witness a severe depopulation of the hills of both livestock and farmers with the knowledge and skills to manage these vital areas in order to deliver environmental goods and agricultural products. Any redefinition of LFAs must be based on sound scientific evidence and ensure sufficient flexibility for Member States to direct funding to those areas that need it. We do not believe the suggested biophysical criteria can achieve this.
LFA payments have been vital to those agricultural businesses within LFAs and it is these businesses which already deliver or have the potential to deliver the environmental outputs that society desires.
The CLA suggested in response to the House of Lords Inquiry into LFA redesignation that it would be possible and highly desirable to develop criteria which relate to the second part of Article 50, 3(a) that would focus on the positive side of the concept of LFAs, namely the extensive farming systems which are a vital part of the management of these semi-natural habitats and landscapes, and thus to the environmental and landscape characteristics we wish to maintain. Thus if we were to start from the landscape character and specifically the fact that they arise because of grazing management systems then we may have another way of arriving at an appropriate definition of Less Favoured Area.
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How can the uplands be valued for their contribution to the social and economic future of Wales as well as the environment?
The landscape and countryside of the uplands is what defines Wales, its mountains, rivers, woods, valleys and farmland. It is a man-made landscape that reflects the aspirations and work of human kind in the search of a living over millennia. In addition to the important function of producing food it is also a repository of its language, culture and the many skills that are essential to the maintenance of this special heritage - i.e. stone-walling, ‘hefting’, hedging, shepherding and general land management, as well as the many environmental benefits, such as biodiversity, clean water, access for health and recreation. Without support and active management many of the fragile habitats and species dependent on them would be lost, including a resilient branch of ‘homo sapiens’.
Rural communities share many of the same needs and aspirations as the urban counterparts, but their circumstances are different and require particular solutions. No one in Wales is far from hills, cultivated farmland or coast. There is a vital interdependence between town and country – each holds the key to the future of the other. Leisure and tourism constitute one of Wales’s biggest income earners and generator of jobs, and is a magnet for inward investment. Tourism will fulfil this role only if the countryside remains an asset attractive to visitors. Management of the countryside needs profits and people, so the economic success of rural upland Wales is as important to the urban majority – who of course themselves want to enjoy the countryside too – as it is to those who live and work there.
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How can government policy work with land managers’ needs to achieve the best use of Welsh uplands?
By working to promote an economic heartbeat through integrated development.
As agriculture and forestry alone will no longer support rural communities, the government must provide a positive framework for local authorities to maximise the scope for enterprise in the countryside through a sympathetic approach to local development.
The key issues that must be dealt with are;
Planning, housing, transport and infrastructure
- Continue the review of the planning system in Wales, in particular ensuring that the needs of rural businesses and communities are met, and monitor the introduction and operation of Local Development Plans. This will involve ensuring an appropriate mechanism exists as well as specific policies.
- WAG’s revision of the guidance given in the Technical Advice Notes (TAN) series, particularly the current consultation on TAN 6 are encouraging steps in the right direction. It is important Local Planning Authorities adopt a more innovative and imaginative approach and that more investment is made in providing a quality planning service that is sensitive to the needs of rural development, allowing opportunities for sensitive local expansion.
- Promote modern, up-to-date broadband communication, transport, and infrastructure services to the rural heartland of Wales to stimulate and widen entrepreneurial activity.
- Recognise that public services, such as health and education, may cost more to provide in rural areas, but that that provision is justified and essential.
- Encourage the use of appropriate measures to mitigate climate change, secure sources of renewable energy and maintain an attractive environment.
Jobs in the countryside also depend on the availability of appropriate housing, often including – particularly affordable housing, the provision of services and adequate communications. Three phase electricity, roads wide enough for deliveries, broadband communications, power installed at economic rates, training opportunities for employees within realistic reach, local schools, health provision, social services – all are prerequisites as to whether starter businesses can become established businesses. Too often, a successful small business meets its first big hurdle when it needs to expand, and runs into planning, labour availability, infrastructure problems then business rates. The current removal of empty property relief is a case in point. Containing EU moves for further regulations and reducing the burden of existing regulation, e.g. by cutting the number and variety of farm inspections, resisting gold-plating EU regulations. Recognising that small or local businesses do not necessarily need the same level of regulation. Also WAG needs to ensure the EU Water Framework Directive does not impose unreasonable or disproportionate restrictions on agricultural development nor inhibits rural regeneration.
Successful development will be as much about keeping growing businesses as starting new ones, and sometimes villages or towns have to be allowed to grow to maintain a critical mass.
Conservation of Wales’s beautiful upland landscape and heritage can best succeed if there is an economic use for land and buildings. Public support for environmental land management is strong, and long-term changes in the CAP offer the opportunity for positive encouragement for environmental enhancement and sympathetic rural development.
Resources currently delivered to rural Wales through Pillar 1 must be maintained through Pillar 2 support. The current spend on agri-environment fails to reflect either the scale of the task, or the extent of public support for stewardship of the countryside. Furthermore the payment principle based on ‘income foregone’ increasingly undermines agri-environment payments as a viable option for land managers. Opportunity costs and incentives should be considered. The CLA believe that income forgone in farming is not a sufficient mechanism to keep people farming in LFAs, as this does not adequately reward farmers for their time or delivery of public goods and is chronically low in the LFAs. Looking at either these earnings in nearby towns or alternatively looking at the monetary value of the public environmental and cultural landscape services would be a more fruitful line which the Commission should be investigating.
Recreation and access is an increasing priority of government policy. It is time for a step change in how government provide public access to the countryside in order that a balance is struck between the provision of access and other concerns e.g. rural business, environment against the needs of the public. It is crucial that access to the Welsh countryside is managed, and in keeping with the needs of local communities, including farmers and landowners.
One example of where this balance wasn’t achieved was the grant of the new public right of access to areas of open country and registered commons. No account was taken of the public need for access, or the effects of access on land management or the environment – land was mapped merely because it happened to have the right vegetation or fall into a particular land type. Sadly, this approach adopted to-date makes land managers think long and hard about agreeing to agri-environment schemes which may result in their land being compulsorily mapped under the CROW legislation. Whilst the administration of the introduction of a ‘Right to Roam’ under CROW was better managed in Wales than England, it is widely recognised that the outcome and the money could have been spent more cost effectively on improving and managing the existing rights of way network. It is imperative that the government provide sufficient funding if the aspirations and economic potential of Wales as an outdoor destination for tourists are to be met.
- The CLA’s view is that access must work for Wales; not against it. Tourism and recreation in the uplands can provide an essential opportunity for land managers to diversify and bring much needed economic benefit to the communities of rural Wales. However, a balance between the different interests can only be achieved with sensible approaches for delivery and funding, which allow access to be considered on a case-by-case basis, where the current public need and the effects on management of the land and the environment can be balanced.
- As an example, the Welsh Assembly Government’s policy for the delivery of improved coastal access by negotiation and through existing legal mechanisms is to be applauded. It is equally important that a similar principle is maintained for a voluntary approach to canoeing. Capitulating to unreasonable demands and giving primacy to one use over all others, contrary to the grain of long established principles of English law, will destroy the riparian heritage of Wales’ magnificent rivers and all that they have to offer.
-How can a value be put on the natural, ecosystem services provided by the uplands, such as carbon storage and flood management?
The CLA consider that there is scope for the creation of new private markets for the delivery of environmental goods and services and believe the Commission should encourage market systems which would complement the support payments available. These could be particularly relevant to LFAs, especially with regard to water and carbon management services.
Market mechanisms for Ecosystems services are in their infancy in other parts of the world. (USA and Australia). Carbon has a monetary value and is technically tradable, with growing interest in investment vehicles that recognise this potential. If carbon storage is a valuable asset then markets need to develop an incentive to farmers and landowners to manage the area for this purpose. Similarly the costs and practicalities of hard engineering solutions to flood defences could be evaluated against the environmental costs and benefits of alternative ‘soft’ engineering solutions and timely management of surplus water which rewards land managers, as well as upland land management practices that reduce the cost to Water Companies of expensive treatment to remove impurities and discolouration from public water supplies.
America and many other countries are developing such markets which see substantial values attached to these specialist land uses. Enthusiasm and support for the creation of similar markets in Europe and the UK could be to the benefit of upland Wales. (See link/reference to CLA discussion document at end of following paragraph).
- How can climate change and the potential impacts of climate change be built into the planning for the future of the uplands?
The higher level option 2 of the proposed Glastir scheme is scheduled to address the potential of the uplands to adopt the EU’s climate change agenda. However the WAG need to recognise the uniquely positive role land management can play in the adaptation and mitigation of the effects of climate change. The encouragement by government of policies to stimulate the growth and use of renewable sources for localised energy, through micro-hydro, bio-energy and wood crops for both fuel, and combined heat and power generation, as well as recognising the role of and encouraging scientific research and development to help the welsh uplands adapt, without prejudicing their productive capacity in the face of a doubling of global food production by 2050. Imaginative and innovative policies by local authorities when replacing their infrastructure and planning presumptions in favour of more sustainable technologies can help engender a positive force for change.
Equally the CLA have been at the forefront of thinking that the ‘status quo’ cannot necessarily deliver all the benefits of bio-diversity that the public desires and that environmental markets might have a role to play, offsetting development in one area with the purchase of environmental goods provided in another area, through a market mechanism. Upland Wales may have much to offer in this regard should such an innovative approach gain momentum. CLA published a discussion paper ‘Private solutions to Public problems’ in May 2009.
http://www.cla.org.uk/Policy_Work/Environmental_Markets/ .
- What are the roles of farming and forestry in the future of the uplands
Land based industries are invariably the key stone of upland economies. This is not only due to the economic impact of farming, and forestry, but of the wider impact such as environmental and landscape management. These factors underpin the other elements of the upland economy, such as tourism and sporting activities.
The uplands may not be the most productive agricultural area by hectare but their place in the agricultural hierarchy should not be overlooked. Much of the lowland sheep industry will rely on the uplands for breeding stock. Furthermore, the uplands rely on low input farming, producing a very “natural” product, so finding favour with many consumers and opportunities for market ‘branding’.
Mineral extraction is of course one of the most traditional of upland activities in parts of Wales and should continue to be viewed as an appropriate activity.
Farm Business Survey figures, as highlighted in the Annex to WAG’s ‘Food, Farming and the Countryside – Building a Secure Future’ indicate the fragility of extensive upland livestock farms, showing them to be wholly dependent on subsidy as Net Farm Income without EU support would be profoundly negative.
Thus the continuation of a critical mass of the basic delivery units of upland public benefits that comes from extensive pastoral agriculture, i.e. livestock farm businesses, is severely threatened.
If upland farming was to continue to decline, with the associated removal of livestock from the hills, then landscape change would occur which may very well be detrimental to recreation and visitor enjoyment in the uplands. Furthermore, the resultant build up of vegetation would present an increased fire risk which may well have significant climate change implications given that this fuel source will often be located on top of or adjacent to deep peat.
Tourism is often seen as the great saviour for upland economies. This may well be true but it should not be regarded as the remedy in all areas. Tourism in upland areas tends to be seasonal, at a low wage and with little scope for advancement. Also it is not always possible for holdings in the most remote areas to participate in this industry.
Conversely, shooting enterprises may well only provide recreational activity for a relatively small number of people, but they do leave a significant economic footprint as well as year round employment. It is increasingly important to much of upland mid-Wales. Much of the expenditure occurs in the winter months when other visitors are scarce. Game keeping is a young man’s activity and so attracts young families.
It remains the case that there are a lack of alternatives, both for land based and other businesses. Upland beef and sheep farmers do not have the same options to change their systems or to diversify as their lowland counterparts. Businesses may also be very weather dependant. Where change does occur, it can be negative. The mix of enterprises have changed with a move away from dairying, and suckler cows, to a mono culture of sheep production as economies of scale dictate, and costly investment in buildings and EU regulation make some enterprises less viable. This results in a change in grazing regime, often causing bracken and scrub encroachment and under-grazing.
While the pressures of economies of scale and amalgamation will continue, the challenge will be to widen the economic base of the upland economy and enable families to maximise household income from other employments, so remaining on their farms or in their localities, retaining the skills to maintain the environment, and thriving communities which sustain the cultural heritage. This requires more imaginative planning, particularly in designated areas, provision of affordable housing and effective services such as broadband capacity. Often as a consequence of the environmental value of the uplands, there is a proliferation of government agencies and regulators exercising influence. The result is to stifle innovation, development and progress in areas where they are most needed.
Forestry:
The Welsh climate is ideally suited to timber production and offers an alternative land use to agriculture. Woodland Strategies for Wales have emphasised the sustainable management of Welsh woodlands and the delivery of public benefits.
The acknowledgement of the need for a vibrant timber industry in Wales is paramount. Private woodlands account for about 60% of the total woodland area and if woods are to deliver environmental and recreational benefits it is essential that private owners can make an economic return. The CLA are pleased that the Assembly recognise that woods which are managed for timber production can also deliver the other important public benefits.
The Wales Forest Business Partnership is seen as a positive move towards promoting wood based products manufactured in Wales, and it is hoped that an increase in demand for wood products will lead to a greater demand for timber grown in Wales, especially as part of a campaign to mitigate the effects of climate change. There is also potential to encourage outlets for thinnings to support local heating systems for hospitals schools etc which would contribute to sustainable energy production.
The role of the Forest Enterprise (FE) however, remains an area of concern. The FE loses money and although there are moves to improve its financial position the drain on Assembly resources must not divert financial support from the private sector.
The new Better Woodlands for Wales grant scheme is in its infancy but still has administrative and process problems. However the CLA welcomes its ambitions to improve the management of private sector woods.
- Woodland management is often a marginal enterprise and without support will lead to continuing long term decline of the existing resource. The Assembly must recognise that consistent support is required if private owners are to deliver the desired public benefits.
- The Assembly should continue to support investment in local processing, as well as bio-energy alternatives, to complement existing large scale timber enterprises, and to encourage wider economic activity.
- CLA believes that the management of woodland, as part of a rural business, should be treated as one business for tax purposes. This will help support and benefit the long-term maintenance of private woodlands. Recognition of this by the Assembly can add weight to the lobby in Westminster.
What role does common land have in the future of the uplands?
Common land covers large parts of upland Wales and is often designated SSSI, being highly valued for its habitats and species. The problem is that common land is often in multiple occupancy making management by agreement difficult, and is increasingly costly to manage. If a heft is lost from common land, then the remaining hefts spread out to take their place which makes it more difficult for the shepherds to look after their stock and routine activities and gatherings take considerably more time and sometimes are dependant on additional labour. This extra cost can be the difference in the business making a profit or not and starts to undermine the traditional practice of ‘hafod and hendre’. The consequences of this can be more intensive management on the lower land resulting in environmental problems with undergrazing and scrub encroachment on the common, leading to a loss of biodiversity (habitats and species), and potentially access (linked to a decrease in tourism) etc.
Glastir’s proposal that if 80% of the graziers on a common can agree then they can qualify to apply to the scheme, should improve this situation. As water quality and catchment schemes, carbon sequestration and soil management etc become more important, so will the management of upland commons, and the role of the owner (Lord of the Manor) as being different to that of the commoners, will need to be considered
Country Land & Business Association Ltd
Hoddell Farm
Kinnerton
Presteigne
Powys,
LD8 2PD.
FJES/VT
29 September 2009
