The Foundation responds to the CAP consultation

The Foundation has responded to the Defra consultation on the future CAP. Below are some of the main points we made.

Direct payments

The Foundation for Common Land supports the increase in Direct Payments to the SDA and Moorland regions. Direct Payments should recognise the contribution farmers make to the delivery of public goods to society to enable them to continue to farm in a manner that protects and enhances these public goods. Common Land is well know for the extensive public goods it provides for instance 58% of common land is designated for biodiversity and over 80% is in designated landscapes such as AONBs and National Parks. Unless commoners receive proper payments for actively managing common land then these public benefits will decline as farmers seek to maximise direct financial benefits. This is not in the nation's interest.

The challenge on commons is to ensure payments are made on the whole common as the whole common is available to the commoners. Under the current scheme approximately 20% of commons are not paid on for SPS while under UELS payment is received on the whole area. The Foundation for Common Land supports the total area of the common being divided on an annual basis among all the claimants in that year to ensure commoners are not disadvantaged compared with other farmers.

The Foundation believes that:

1. Commoners should not have a higher burden of proof on showing availability of land compared with other types of land
2. Commons must be properly mapped as the Biological Survey data currently used is inaccurate
3. The commons maps are out of date - a straightforward method for resolving these differences is required so that there is no unnecessary withdrawal ofpayments particularly of land that is farmed by a sole occupant but may be mistakenly registered as common land
4. Proper mapping of commons is essential to achieve this and this can only be achieved through the implementation of Part 1 of the Commons Act 2006 followedby digitisation of the correct commons maps.

Rural Development Programme

Some lessons learnt on common land:

1. The scheme architecture of HLS and UELS was well designed and successful for commons in that take up was high and a clear differentiation between the two schemes both in payments and prescriptions.
2. Stronger and clearer advice is required from Natural England on the principles of governance of commons associations and the management of public money for the delivery of public goods. These funds are in some instances used by people in positions of power to lever outcomes unrelated to the objectives of the stewardship scheme. This is not an acceptable use of public money.
3. Multi-partite schemes are time consuming to negotiate and will not happen without facilitation. More effective partnership can be achieved by working with farmers and instigating change in a measured way rather than demanding significant reductions that there is little scientific evidence for. Recovery may be slower but it will be more sustainable conserving the whole suite of ecosystems from the site.
4. Without tailored schemes the cultural landscape of these highly valued areas is at risk and farmers are unlikely to engage with the environmental outcomes. This is in line with the recommendations from the EFRA committee.

New environmental land management scheme and the new “mid- tier” approach

• We are disappointed there is only limited information in this consultation on how NELMS will be implemented and request a full consultation on NELMS as soon as is practical.
• We recommend an outcome based approach as in Farming Futures in Dartmoor or as a minimum flexibility within stocking calendars through the use of summer and winter averages
• We have concerns that the conservation of cultural landscapes as protected under the European Landscape Convention are not adequately specified as asecondary objective. We support the inclusion of an additional secondary objective;
  • To prioritise cultural landscapes that reflect unique land management techniques e.g. a. where really ancient field patterns occur at the local scale and b. thetraditional practices on many areas of common land.
• We have concerns how the Landscape Scale approach will work in practice.

You can read our full submission