Question 1: Do you agree with the Scottish Government’s proposed use of Pillar-to-Pillar budget transfers under the 2014-2020 Common Agricultural Policy? Please give reasons for your position.
We do not support the Government’s position of transferring 9.5% of the Pillar 1 budget to Pillar 2. GWCT’s position on Pillar-to-Pillar transfer was clearly stated to the Cabinet Secretary in our joint letter with RSPB Scotland in September this year. GWCT firmly believes that maximum transfer of 15% is needed to deliver the large number of environmental priorities Scotland is facing which includes climate change mitigation, water quality and species recovery.
Our view is based on GWCT’s 70 years of working with farmers to deliver farmland biodiversity and our key role in designing and researching agri-environment prescriptions within a productive landscape. In our experience our biodiversity goals will only be delivered through:
- Funding which stimulates productive farming alongside active, intensive conservation management based on well researched and targeted agri-environment schemes.
- Avoiding funding patterns which drives land out of productive farming for conservation which is too broad and shallow and which makes active, managed conservation less attractive to farmers.
The need for Pillar 2 funding
Maximising Pillar 2 funding encourages a win-win approach: the maximum area of productive farming alongside active, intensive conservation management which our research and practice shows will support Scotland’s biodiversity aspirations. Pillar 2 funding needs as much transfer as possible because it is being squeezed already in two ways – a low payment per hectare and diversion of Pillar 2 funds into extensive agriculture.
As stated in the consultation’s supporting documents, Scotland will receive one of the lowest Pillar 2 payments per hectare in Europe. This low and now reduced budget concerns GWCT. It will hinder Scotland’s ability to meet our environmental priorities such as Farming For a Better Climate and reversing the declines of the farmland bird index. Pressure on the new SRDP budget to achieve both our domestic and international targets will be increased by the carry-over of existing agreements into the new funding period leaving little funding to increase the number of rural development contracts with land managers and expand environmental delivery. Scotland has already failed to meet a number of biodiversity targets and the 2020 assessment is looming, it is important that we take the right steps now to achieve healthy ecosystems.
The Pillar 2 budget is also constrained by the amount of support allocated to LFASS/ANC payments which currently takes up a significantly large proportion of all rural development funding. ANC payments are aimed at supporting sustainable farming yet there is little data on the actual environmental benefits produced by this funding; the shocking loss of Welsh upland biodiversity in the last 30 years illustrates how High Nature Value Farming characteristics (as used in SAC’s study of HNVF) do not necessarily mean biodiversity benefits. Whilst we recognise the importance of ANC payments to farms and crofts which, due to their remote location and the topography of Scotland face significant limitations on food production, the Trust also recognises that there is inadequate targeting of this funding to maximise environmental output, something better achieved through agri-environment schemes.
The risk of ‘greenwashing’ in other funding streams
As many others are as well, we are deeply concerned that extensive environmental requirements/funding such as Pillar 1 Greening will deliver minimal environmental improvement in Scotland (some instances will be very little more than cross-compliance) and will further undermine the motivation of farmers to actively manage for conservation.
The ‘greenwash’ of Pillar 1 funding adds significant pressure to stewardship schemes to deliver conservation value from public funds. The Trust understands that Greening requirements are still to be finalised by Scottish Government but the fact remains that the three requirements will do little to change or tackle existing Scottish environmental problems and that an alternative certification scheme is likely to increase the complexity of Pillar 1 payments considerably. This top down approach will lead to many farmers doing the absolute minimum to achieve Greening payments and in some cases it will de-incentivise land managers from up taking focussed, effective management.
For the good of Scotland’s farmland biodiversity it is imperative that Pillar 1 greening should be as easily achieved as possible and future agri-environment prescriptions as well funded as possible. In order for this to be accomplished not only should the Cabinet Secretary transfer the full 15% allowed from Pillar 1 but the budget break down within rural development should also be reconsidered with greater financial capabilities given to agri-environment.
Game & Wildlife Conservation Trust