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Report by the Comptroller and Auditor General Ministry of Agriculture, Fisheries and Food Protecting Environmentally Sensitive Areas

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Page 1: Protecting Environmentally Sensitive Areas€¦ · United Kingdom and Europe to encourage environmentally friendly farming (Appendix 1). These developments aim to promote a more traditional

Report by the

Comptroller and Auditor GeneralMinistry of Agriculture,Fisheries and Food

Protecting

Environmentally

Sensitive Areas

HC 120 Session 1997-98

23 July 1998

Page 2: Protecting Environmentally Sensitive Areas€¦ · United Kingdom and Europe to encourage environmentally friendly farming (Appendix 1). These developments aim to promote a more traditional

Contents

Page

Executive summary 1

Part 1: Introduction 4

Part 2: Designation and take-up 11

Part 3: Monitoring and compliance 21

Part 4: Costs and payments 33

Appendices

1: Developments since 1985 in the United Kingdom and Europe 42

to encourage environmentally friendly farming

2: Environmentally sensitive areas - key data 44

3: Overview of countryside environmental schemes in England 45

4: Tier structure, objectives and prescriptions for selected 47

environmentally sensitive areas

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Executive summary

1 The Ministry of Agriculture, Fisheries and Food launched the Environmentally

Sensitive Areas scheme in 1987. The scheme encourages farmers to safeguard

areas of the countryside under threat from intensive agricultural practices and

where the landscape, wildlife or historic interest is of national importance. It is

the most important of all the countryside environmental schemes in England.

Estimated expenditure on grants to farmers in 1996-97 was £32.5 million.

2 Participation in the scheme is voluntary. A farmer within a designated area who

wishes to take part is obliged to farm in an environmentally friendly way for

ten years. In return, the farmer receives an annual payment. The amount

depends on the original status of the land and the management prescriptions

the farmer has agreed to follow.

3 The Ministry has designated 22 areas in England as environmentally sensitive.

The total land covered – 1.15 million hectares – is roughly 10 per cent of

agricultural land in England. By 31 March 1996, farmers had entered into

7,800 agreements with the Ministry under the scheme, covering 427,000

hectares of land.

4 This report examines how well the Ministry has operated the scheme and the

available evidence on the scheme’s effectiveness in protecting environmentally

sensitive areas.

Main conclusions and recommendations

5 The scheme has been a landmark in the development of policies to promote

environmentally sensitive farming. It continues to perform a useful function and

has been influential in helping to change attitudes amongst farmers. Many

farmers have been persuaded to revert to traditional farming practices or to

eschew intensive methods and this has secured valuable benefits for the

environment.

6 The Ministry has operated the scheme in accordance with the rules governing

it. Its administration of the scheme has been generally well received by farmers

and environmental organisations. Nevertheless, the Ministry could secure

greater environmental benefits in a number of ways. The National Audit Office’s

main findings and recommendations are as follows.

7 Constraints on the scheme’s coverage limit its effectiveness in safeguarding

environmental features of national importance (paragraphs 2.4 to 2.7).

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MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

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8 The Ministry should ensure that it has a complete and accurate record of

eligible land in all environmentally sensitive areas. Accurate information is

important for establishing realistic targets for take-up of the scheme, for

financial forecasting and for monitoring effectiveness (paragraphs 2.8 to 2.10).

9 To maximise the environmental gains the Ministry should identify priority areas

within each environmentally sensitive area and focus its work on these smaller

areas. The Ministry should also re-examine the take-up targets it set in 1994 to

ensure that they are demanding but achievable (paragraphs 2.11 to 2.18).

10 The Ministry should establish criteria for the continued designation of

environmentally sensitive areas. Such criteria are important if the Ministry is to

ensure that it directs its resources towards those areas where the benefits of

designation are likely to be greatest (paragraphs 2.19 and 2.20).

11 The Ministry should consider removing the designation from environmentally

sensitive areas with poor levels of take-up and, instead, using the Countryside

Stewardship scheme to protect the environment (paragraphs 2.21 to 2.23).

12 There is scope for rationalising the environmental monitoring programme and

reducing its costs, for example by concentrating on extensive rather than

intensive botanical surveys. There is also a need to make greater use of

ground-based surveys for assessing land cover, and to focus on identified

priority areas and habitats (paragraphs 3.2 to 3.12).

13 When checking that farmers are complying with the scheme’s management

prescriptions, it would be more effective for the Ministry to target a much larger

proportion of field inspections on those agreement holders who represent the

greatest risk. This would enable the Ministry to reduce the level of checking -

with cost savings - without reducing the effectiveness of compliance monitoring

(paragraphs 3.15 to 3.18).

14 Many of the performance indicators for the scheme do not set out clear criteria

for evaluating success. Some indicators cannot be measured at all by the

present monitoring programme and some can be measured only partially. The

Ministry should refine its performance indicators to address these weaknesses

(paragraphs 3.19 to 3.24).

15 The Ministry should ensure that its five-yearly reviews of each environmentally

sensitive area include an assessment of the effectiveness of each area and of the

scheme as a whole (paragraphs 3.25 and 3.26).

16 There is scope to develop a more effective programme for the work of project

officers by focusing it on the strategic priorities within each environmentally

sensitive area and the extent of risk (paragraphs 4.3 to 4.5).

17 The Ministry should ensure that its revised procedures result in the proper

control and monitoring of research in order to minimise costs and enable

research to be targeted effectively (paragraphs 4.6 and 4.7).

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18 The Ministry should investigate the variations in the efficiency of local regional

service centres so as to identify and promulgate best practice (paragraphs 4.8

to 4.13).

19 The Ministry should set payment rates on an objective basis as at present and

keep under special review those areas where rates are higher than income

foregone by farmers (paragraphs 4.15 to 4.21).

Action proposed by the Ministry

20 In 1996 the Ministry carried out a policy review of the five environmentally

sensitive areas designated in 1987. This took account of the views of farmers

and of the various organisations consulted and the emerging findings of the

National Audit Office examination. In October 1996 the Ministry set out in a

consultation paper options and proposals for each area and invited views

(paragraphs 3.28 and 3.29).

21 If implemented successfully, the changes proposed in the consultation paper

would address many of the concerns identified by the National Audit Office in

this report.

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MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

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1 Part 1: Introduction

1.1 Dramatic changes have taken place in British agriculture over the last 50 years.

Improvements in soil management, pesticides, crop varieties, technology and

machinery have increased productivity and Britain’s self-sufficiency in food.

These changes have led to a shift towards large and increasingly specialised

farm businesses. This agricultural intensification has changed the way land is

managed, dramatically altering the landscape and sometimes putting plant and

animal life at risk (Figure 1).

1.2 To counteract this trend, there have been a number of developments in the

United Kingdom and Europe to encourage environmentally friendly farming

(Appendix 1). These developments aim to promote a more traditional approach

to managing the land, including, for example, maintaining hedgerows and dry

stone walls, promoting traditional grazing patterns to preserve hay meadows

and species-rich grassland, and limiting or avoiding the use of fertilisers and

pesticides.

1.3 One of the most important measures has been the Agriculture Act 1986, which

placed a duty on the Ministry of Agriculture, Fisheries and Food to promote the

co-existence of efficient farming and conservation, and empowered Ministers to

4

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

PROTECTING ENVIRONMENTALLY SENSITIVE AREAS

Figure 1: Loss of habitats, flora and fauna, 1949 to 1984

Studies carried out by the Nature Conservancy Council and the Countryside Commission in 1984 suggested

that since 1949 significant losses in habitats have occurred:

• there has been an 80 per cent loss of chalk and Jurassic limestone grassland andsignificant damage to the remaining 20 per cent;

• 95 per cent of lowland grasslands (including herb-rich hay meadows) now lack anysignificant wildlife interest;

• 40 per cent of lowland heath has been lost;

• 50 per cent of lowland wetlands has been lost;

• 30 to 50 per cent of ancient lowland woods has been lost; and

• 140,000 miles of hedges have been lost.

There have also been significant declines in flora and fauna. For example, of 98 native species of dragonflies

and butterflies four had become extinct in this period, 16 were endangered and a further 18 had declined

substantially.

Subsequent surveys have confirmed that such losses are continuing. About 12,000 miles of hedgerows are

currently being lost each year; and surveys by the British Trust for Ornithology and the Royal Society for the

Protection of Birds show a steep decline in the number of traditional farmland birds such as skylarks and

grey partridges.

Sources: Countryside Commission, Nature Conservancy Council, Royal Society for the Protection of Birds

Over the last 50 years agricultural intensification has had a dramatic effect on the landscape and on plant and

animal life.

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designate environmentally sensitive areas. The European Union has also taken

measures to protect the environment and reduce incentives for intensive

farming. All Member States are now required to operate schemes to promote

environmentally friendly agriculture. Of the countryside environmental schemes

operated by the Ministry, the two largest are the Environmentally Sensitive

Areas scheme and the Countryside Stewardship scheme.

The Environmentally Sensitive Areas scheme

1.4 The Ministry introduced the Environmentally Sensitive Areas scheme in 1987.

The objective of the scheme is to encourage farmers to safeguard areas of the

countryside where the landscape, wildlife or historic interest is of national

importance. Participation in the scheme is voluntary. To date the Ministry has

designated 22 areas in England as environmentally sensitive (Figure 3 on

page 6 and Appendix 2). The total land covered - 1.15 million hectares - is

roughly 10 per cent of agricultural land in England.

1.5 Annual expenditure on grants paid to farmers in the scheme in England rose to

an estimated £32.5 million in 1996-97 (Figure 2). The gross cost of the scheme

in that year, including administrative costs, was estimated at £42.6 million

(Figure 4 on page 7). The Ministry recovers from the European Union up to

5

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

PROTECTING ENVIRONMENTALLY SENSITIVE AREAS

Note: Expenditure in 1996-97 is estimated

Figure 2: Environmentally Sensitive Areas - Grant payments to farmers

Source: National Audit Office analysis of Ministry data

Expenditure on grants has risen significantly as take-up among farmers has increasedand further areas have been designated.

0

5

10

15

20

25

30

35

1987

-88

1988

-89

1989

-90

1990

-91

1991

-92

1992

-93

1993

-94

1994

-95

1995

-96

1996

-97

£m

illio

n

Financial year

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Figure 3: Environmentally sensitive areas, national parks and areas of outstanding natural beauty in England

Lake District

Pennine Dales

South West Peak

North Peak

Clun

Shropshire Hills

WestPenwith

South Downs

Avon Valley

Blackdown Hills

Exmoor

Somerset Levels & Moors

Essex Coast

Suffolk RiverValleys

Breckland The Broads

North KentMarshes

Upper ThamesTributaries

Test Valley

South WessexDowns

Cotswold Hills

Dartmoor

Areas of outstanding natural beautyNational Parks and the Broads Environmentally sensitive areas

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50 per cent of the amounts paid to farmers. Farmers may be entitled to receive

payments under other schemes at the same time as receiving payments under

the Environmentally Sensitive Areas scheme.

1.6 In relation to the main agricultural schemes which the Ministry administers,

total payments on the Environmentally Sensitive Areas scheme are relatively

small, forming only two per cent of the total agricultural policy expenditure in

England (Figure 5 overleaf). However, it is the largest of all the countryside

environmental schemes in England (see Appendix 3).

1.7 Those farmers within a designated environmentally sensitive area who wish to

take part in the scheme enter into a management agreement with the Ministry.

The agreement obliges them to farm their land in an environmentally friendly

way for a period of ten years. In return, they receive an annual payment which

ranges from £12 to £415 per hectare, depending on the original status of their

land and the management prescriptions they have agreed to follow. Such

prescriptions might include maintaining hedgerows and grassland, limiting or

avoiding the use of fertilisers and pesticides, and allowing winter flooding to

occur. Payment rates and management prescriptions are unique to each

environmentally sensitive area.

1.8 Farmers with agreements under the scheme may also apply for small grants

towards the cost of capital works of environmental benefit, such as repairing

walls and barns, planting hedges, restoring ponds, or controlling scrub and

bracken. These payments do not attract any European Union funding but are

approved as aid which Member States may choose to pay to farmers. Recent

changes to regulations have increased to £20,000 the total amount of capital

grants which an agreement holder can receive during the lifetime of the

agreement.

6

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

PROTECTING ENVIRONMENTALLY SENSITIVE AREAS

Figure 4: Expenditure on the Environmentally Sensitive Areas scheme, 1992-93 to

1996-97 (£ million)

1992-93 1993-94 1994-95 1995-96 1996-97

Grants to farmers 10.9 16.5 20.1 29.1 32.5

Administrative costs 11.1 13.9 12.2 13.3 10.1

Gross expenditure 22.0 30.4 32.3 42.4 42.6

Recovered from the

European Union

(2.0) (12.7) (9.6) (13.3) (14.2)

Source: National Audit Office analysis of Ministry data

Note: Expenditure in 1996-97 is estimated

Gross expenditure on the scheme has almost doubled in the period from 1992-93 to 1996-97 as a result of the

designation of new environmentally sensitive areas and increasing uptake by farmers.

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Administration of the scheme

1.9 The scheme is complex and its administration involves many different processes

(Figure 6). The Ministry was assisted in this task by ADAS, until March 1997 an

executive agency of the Ministry and the Welsh Office. In 1995-96 the Ministry

deployed 79 staff years on this work and ADAS 162 staff years. The total cost of

administering the scheme was £13.3 million. On 1 April 1997, ADAS was

privatised. However, certain statutory and regulatory functions remain within

the public sector and are administered by the Farming and Rural Conservation

Agency, a new executive agency of the Ministry and the Welsh Office (Figure 6).

1.10 The Ministry reviews the effectiveness of each environmentally sensitive area

every five years. This involves assessing the results of an environmental

monitoring programme, the extent of take-up and the views of farmers and

relevant organisations. On the basis of the review, the Ministry decides whether

or not to renew each environmentally sensitive area for a further five years and

draws up proposals as necessary to revise boundaries and management

prescriptions. These proposals have to be approved by the Treasury.

8

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

PROTECTING ENVIRONMENTALLY SENSITIVE AREAS

Figure 5: Grants paid to farmers under the Common Agricultural Policy, 1995-96

Source: National Audit Office

Payments under the Environmentally Sensitive Areas scheme form only a small part of total Common Agricultural Policy expenditure

in England.

Hill Livestock Compensatory Allowances

Farm and Conservation Grant Scheme

Environmentally Sensitive Areas

Suckler Cow Premium

Beef Special Premium

Sheep Annual Premium

Arable Area Payments

0 250 500 750 1000 1250 1500

£ million

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9

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

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Figure 6: Administration of the Environmentally Sensitive Areas scheme

Source: National Audit Office. Analysis of staff years relates to 1995-96.

Ministry headquarters

Environmentally Sensitive

Areas policy branch

9 staff years

policy development and advice

case precedents

l

l

Farmers

Ministry regional service

centres

70 staff years

processing applications, payment

claims and changes to agreements

checking that farmers are

complying with the terms of their

agreements

l

l

ADAS regional offices:

work now privatised (note 1)

59 staff years

environmental monitoring of the

scheme

socio-economic monitoring

l

l

ADAS regional offices:

work remaining within the public

sector (note 1)

103 staff years

providing expert advice

promotion of the scheme

liaising with farmers

assessing applications

drawing up agreement maps

assessing requests for derogations

and changes to agreements

payment reviews in the 2nd and

4th years of each 5 year cycle

l

l

l

l

l

l

l

Notes: 1. On 1 April 1997 the Government privatised the commercial operations of ADAS including the monitoring work which it carries

out for the Environmentally Sensitive Areas scheme. Administrative work on environmentally sensitive areas, together with

other statutory and regulatory functions, remains within the public sector, and is now carried out by the Farming and Rural

Conservation Agency.

2. The Ministry�s regional service centres and ADAS carry out a wide range of work on behalf of various Ministry policy divisions.

The diagram above relates only to the Environmentally Sensitive Areas scheme.

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Scope of the National Audit Office examination

1.11 Against this background, the National Audit Office examination focused on:

• how areas are designated and the extent of take-up by farmers (Part 2 of the

Report);

• the monitoring and compliance work undertaken by the Ministry to assess

the effectiveness of the scheme (Part 3); and

• the costs of administering the scheme and the level of payments to farmers

(Part 4).

1.12 The National Audit Office examined four environmentally sensitive areas in

detail (the Somerset Levels and Moors, Breckland, the Lake District and the

Cotswold Hills). The examination included interviews with regional Ministry and

ADAS staff; review of a sample of management agreements and claims;

inspection of Ministry data and files; and consultation with a range of other

organisations for their views (Figure 7). The National Audit Office also employed

Land Use Consultants, a consultancy firm with expertise in agricultural and

environmental issues. The study was restricted to England as the Ministry does

not have responsibility for agricultural schemes in Scotland and Wales.

10

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

PROTECTING ENVIRONMENTALLY SENSITIVE AREAS

Figure 7: Organisations which contribute views to the National Audit Office on the

Environmentally Sensitive Areas scheme

• Association of National Parks

• British Trust for Ornithology

• Council for the Protection of Rural England

• Country Landowners Association

• Countryside Commission(1)

• Department of the Environment(1)

• English Heritage(2)

• English Nature(1)

• Institute for European Environmental Policy

• National Farmers Union

• National Trust

• Royal Society for the Protection of Birds

• Wildlife TrustsSource: (1) statutory advisers to the Ministry on this scheme

(2) statutory adviser since 1995

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2 Part 2: Designation and

take-up

Designation of environmentally sensitive areas

2.1 Before designating an area as environmentally sensitive, the Ministry is

required by the Agriculture Act 1986 and the Environment Act 1995 to consult

the Secretary of State (in practice, the Secretary of State for the Environment,

Transport and the Regions), the Countryside Commission, English Nature and

English Heritage. The consent of the Treasury is also required. The Ministry has

set four criteria for the selection of suitable areas:

• each area must be of national environmental significance;

• conservation must depend on adopting, maintaining or extending particular

farming practices;

• farming practices in the area must have changed or be likely to do so in ways

that pose a threat to the environment, or (since 1993) the adoption of

particular farming practices must be capable of resulting in significant

environmental improvements; and

• each area must represent a discrete and coherent unit of environmental

interest.

2.2 Based on the above criteria, and in consultation with the statutory advisers, the

Ministry has to date designated 22 areas as environmentally sensitive. These

areas cover a wide variety of landscape types and habitats and include most

National Parks and many Areas of Outstanding Natural Beauty (Figure 3 on

page 6 and Appendix 2). The Ministry currently has no plans to add to the

number of designated areas.

2.3 Environmentally sensitive areas varied considerably in the extent to which they

had suffered environmental damage before designation. For example, the

landscape and ecology of the Pennine Dales were relatively undamaged. This

area contains some of the best examples of hay meadows in the country; and

the characteristic pattern of dry stone walls and barns has remained largely

intact. By contrast, other areas - particularly in the south and east of England -

had been more seriously affected by intensification over the last 50 years. In the

Breckland, for example, most of the traditional habitat had already been

destroyed and the few surviving areas of lowland heath represented only

nine per cent of the total area.

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MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

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Scheme structure and management prescriptions

2.4 Farmers enter land into the scheme under a variety of “tiers” which determine

how the land is to be managed and the payments farmers are to receive. The

number of tiers ranges from two to nine depending on the area. In basic tiers,

farmers are required to maintain the land in its present state by preventing

further intensification and maintaining traditional farming systems. Where the

environmental quality of the land is already high, such tiers may represent the

optimum state. In enhancement tiers, farmers are required to revert to more

traditional and less intensive methods of managing the land in return for higher

payments. In 12 areas farmers are obliged to enter all their land in the scheme

(“whole farm” areas) whilst in the remaining ten areas farmers are obliged to

enter only their grassland or can choose which parts of their farms to enter.

2.5 The tier structure and management prescriptions farmers are required to follow

are unique to each area. Appendix 4 sets out the requirements in the four areas

examined by the National Audit Office.

2.6 The National Audit Office and its consultants examined the structure of the

scheme and noted that:

• The scheme is focused predominantly on agricultural land. Other land is not

eligible for grant payments.

• Farmers are required to have regard for environmentally significant features

such as marshes, ponds and woods, though they are not generally required

to maintain them in a particular way.

• In some environmentally sensitive areas, such as the Somerset Levels and

Moors, there is no annual payment available to offset the income lost in

reverting arable land to grassland.

• The scheme contains little provision for encouraging environmentally friendly

arable farming. For example, there are no tiers to encourage the reduced use

of fertilisers and pesticides on arable crops.

• Some areas include tiers to encourage farmers to avoid spraying the margins

of fields containing cereal crops. These tiers are costly and bureaucratic to

administer as the position and length of such margins can vary each year as

crops are rotated.

2.7 The National Audit Office recognises the need to tailor each environmentally

sensitive area to local circumstances. Nevertheless, the above constraints limit

the effectiveness of the scheme in safeguarding environmental features of

national importance.

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MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

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Eligible land areas

2.8 Although environmentally sensitive areas cover 1.15 million hectares of land,

only 936,000 hectares within the designated areas (81 per cent) are eligible to

be entered for management agreements. The remaining hectares consist of

roads, urban areas, water, and non-agricultural land, such as woodland and

reedbeds. Environmentally sensitive areas vary widely in the amount of eligible

land as a percentage of their total area, from 55 per cent in Breckland to

96 per cent in West Penwith.

2.9 The Ministry has had difficulty establishing how much land is eligible for the

scheme within each designated area (Figure 8). Errors have arisen from a

variety of causes, including the difficulty of distinguishing between different

types of land. There have also been inconsistencies between earlier manual

estimates and data produced at a later stage from computerised information

systems.

13

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

PROTECTING ENVIRONMENTALLY SENSITIVE AREAS

The National Audit Office therefore recommends that the Ministry should:

• include in the scheme more detailed requirements for farmers to manageponds, marshes, and woods in a way which maintains and enhancestheircondition;

• include provision in all areas, where appropriate, for reverting arableland to grassland;

• incorporate, on a pilot basis within selected areas, more concertedmeasures to encourage environmentally friendly arable farming; and

• exclude from the scheme, or reduce the costs of administering, those tiersthat relate to spraying the margins of fields containing cereal crops.

Figure 8: Errors in estimating eligible land areas

The following are examples of errors noted by the National Audit Office in the data on eligible land areas:

• the eligible area for the arable and ley grassland tier in Dartmoor has been defined as only2,070 hectares whereas take-up has amounted to 3,313 hectares;

• the sum of all eligible areas for individual tiers in Essex Coast amounts to 19,000 hectareswhereas the total eligible area is recorded as 23,000 hectares; and

• the eligible areas in Breckland of heathland, wet grassland and arable land (8,500, 3,500and 46,000 hectares respectively) exceed the total recorded eligible area of the wholeenvironmentally sensitive area (51,600 hectares).

Source: National Audit Office analysis of Ministry and ADAS data

The Ministry does not have a complete and accurate record of eligible land areas.

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2.10 Accurate information on eligible land areas is important for establishing take-up

targets, for financial forecasting and for monitoring the scheme’s effectiveness.

Since 1 April 1997, the Farming and Rural Conservation Agency is responsible

for providing data on eligible land areas to the Ministry and is now

implementing a geographical information system to link with computerised

mapping systems ADAS has been using since 1992. The new system was fully

operational by the end of 1996 and should enable the production of more

accurate and consistent information.

Take-up

2.11 By the end of March 1996, farmers had entered into 7,800 agreements with the

Ministry, covering 427,000 hectares of land. Total take-up amounted to 46 per cent

of the total eligible land area of the 22 environmentally sensitive areas. However,

there were wide variations between different areas in the level of take-up, ranging

from 10 per cent in Essex Coast to 94 per cent in West Penwith (Figure 9 and

Appendix 2). Twelve of the 22 areas had take-up rates below 50 per cent, including

four of the first ten areas, launched in 1987 and 1988.

2.12 The National Audit Office also noted that:

• Most environmentally sensitive areas with poor take-up were located in the

south-east of England (Figure 9).

• The rate of take-up in the six environmentally sensitive areas launched in

1994 has been slower than that in previously designated areas (Figure 10 on

page 16).

• In ten areas, the Ministry required participating farmers to enter all their

land and made small annual payments on arable land under intensive

cultivation in order to encourage farmers to participate in the scheme.

• Take-up of higher enhancement tiers amounted to only 49,000 hectares -

5.2 per cent of the total eligible land area of all environmentally sensitive

areas, and 11 per cent of the area under agreement. Grants paid out for

enhancement tiers accounted for 30 per cent of total payments.

2.13 The presence of intensive arable farming was the main reason for poor take-up.

In the Breckland, South Downs and Suffolk River Valleys, for example, more

than 60 per cent of the eligible land area is under arable cultivation. To bring

such land under agreement was not an objective of the Environmentally

Sensitive Areas scheme. The Ministry has calculated that in some parts of the

country farmers would lose over £650 per hectare if they were to revert

14

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

PROTECTING ENVIRONMENTALLY SENSITIVE AREAS

The National Audit Office recommends that the Ministry should use the new

data from the geographical information system to ensure that it has a

complete and accurate record of eligible land areas in all environmentally

sensitive areas.

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15

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

PROTECTING ENVIRONMENTALLY SENSITIVE AREAS

Figure 9: Take-up within environmentally sensitive areas, March 1996

Source: National Audit Office analysis of Ministry data

Most environmentally sensitive areas in the south-east of England have take-up rates of 40 per cent or less.

WestPenwith94%

Dartmoor19%

Blackdown Hills19%

Exmoor66%

Upper ThamesTributaries

21%

Cotswold Hills57%

Clun77%

Shropshire Hills35%

South West Peak68%

North Peak81%

Pennine Dales68%

Lake District49%

Avon Valley31%

Test Valley40% South Downs

22%

North KentMarshes38%

Essex Coast10%

Suffolk River Valleys36%

Breckland11%

The Broads64%

South WessexDowns54%

Somerset Levels& Moors61%

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intensive arable land to low-intensity grassland. The payments available for

arable reversion under the scheme - between £220 and £310 per hectare -

would be insufficient to compensate farmers for this loss of income (see Part 4).

2.14 Take-up in the river valley, coastal and wetland environmentally sensitive areas

has been low and the scheme has therefore not fully addressed the

management of habitats under threat in these areas. More generally, the low

take-up of enhancement tiers has meant that in many areas the scheme has

protected the status quo: there has been little or no improvement in the

environmental quality of the land.

2.15 The National Audit Office recognises that the environmentally sensitive areas

scheme as a whole is targeted on priority areas; and that within each area the

structure of the scheme is designed to target particular habitats of

environmental importance. However, the limited take-up in some areas would

suggest that a more focused approach might be needed in order to maximise

environmental gains within the resources available. Such an approach would

also help to focus effort into producing more coherent and less fragmented

take-up. Certain habitats and species develop more quickly if they are adjacent

to habitats already existing and are away from intensively farmed land. To date,

the Ministry has not specifically monitored the extent of fragmentation within

environmentally sensitive areas and has little information about the impact of

this on the development of habitats.

16

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

PROTECTING ENVIRONMENTALLY SENSITIVE AREAS

Figure 10: Rate of take-up within environmentally sensitive areas

100

90

80

70

60

50

40

30

20

10

00 1 2 3 4 5

Stage lll (1993)

Stage l (1987)

Stage ll (1988)

Stage lV (1994)

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Take-up targets

2.16 At the outset of the scheme, performance targets were set only for levels of

take-up, which was then considered to be the main criterion for success. In

most areas the target was simply to achieve a take-up of 75 per cent of the

eligible area. In 1994 the Ministry set revised take-up targets for each

environmentally sensitive area and separate targets for individual tiers. The aim

is to achieve the target levels of take-up within five years.

2.17 The National Audit Office compared take-up levels in 1995 with the targets set

in 1994 (Figure 11 overleaf). In 12 areas take-up was some way below the

target level. In the other 10 areas, take-up was already above the target level.

For example, in the Cotswold Hills total take-up amounted to 37,550 hectares

against a target of 25,600 hectares. However, even where targets for the whole

environmentally sensitive area had been reached, take-up for individual tiers

was sometimes considerably below the target. For example, in the Cotswold

Hills only 1,600 hectares of arable land had been entered for reversion to

grassland against a target of 6,000 hectares.

2.18 These variations suggest that in some areas there appears to be scope for

setting more demanding targets subject to environmental priorities: in other

areas the targets appear unlikely to be achieved.

17

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

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The National Audit Office therefore recommends that the Ministry should:

• identify and target priority areas within each environmentally sensitive

area where the environmental benefits from farmers are likely to be

greatest;

• consider changes to the payment structure that would enable resources to

be focussed on the areas of highest priority.

In considering whether to maintain the designation of existing areas, the

Ministry should also take account of the need for clear criteria

(paragraph 2.20) and the availability of other environmental schemes

(paragraphs 2.21 to 2.23).

The National Audit Office therefore recommends that the Ministry should

re-examine the take-up targets it set in 1994. It should determine what can

realistically be achieved in each environmentally sensitive area if the

measures recommended by the National Audit Office in this report are

implemented. It should then introduce revised targets which are demanding

but achievable.

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Removal of designation

2.19 In 1991 and 1992 all ten environmentally sensitive areas designated in

1987 and 1988 were reviewed following the first five years of their operation.

All were designated for a further five years and three were substantially

enlarged, despite levels of take-up in some cases having fallen well below the

75 per cent which the Ministry initially considered to be a measure of the

18

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

PROTECTING ENVIRONMENTALLY SENSITIVE AREAS

Figure 11: Take-up in 1995 compared with target in each environmentally sensitive area

Note: The Broads, Pennine Dales and Test Valley environmentally sensitive areas were substantially enlarged following policy reviewsin 1991 and 1992. The above graph relates to performance targets set in 1994 after the areas were enlarged.

Source: National Audit Office analysis of 1995 scheme data

There are considerable variations between environmentally sensitive areas in the targets set and the take-up actually achieved.

Bro

ads

Pen

nin

eD

ales

Som

erse

tLev

els

&M

oors

South

Dow

ns

Wes

tP

enw

ith

Bre

ckla

nd

Clu

n

Nort

hP

eak

Suff

olk

Riv

erV

alle

ys

Test

Val

ley

Avo

nV

alle

y

Exm

oor

Lak

eD

istr

ict

Nort

hK

ent

Mar

shes

South

Wes

sex

Dow

ns

South

Wes

tP

eak

Bla

ckdow

nH

ills

Cots

wold

Hill

s

Dar

tmoor

Ess

exC

oas

t

Shro

psh

ire

Hill

s

Upper

Tham

esTr

ibuta

ries

Take-up and target as a percentage of eligible area

0

20

40

60

80

100

Targ

et

Take

-up

Stage 1 (1987) Stage 2 (1988) Stage 3 (1993) Stage 4 (1994)

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success of the scheme. Removal of the designation was considered in only one

area - the Test valley - but was rejected because the Ministry considered that

the benefits of keeping open and extending the environmentally sensitive area

would outweigh the savings to be made by closing it.

2.20 The Ministry has not set clear criteria for deciding whether or not to continue

with the designation of existing areas. Such criteria are important if the

Ministry is to ensure that it continues to target resources in those areas where

the benefits of designation are likely to be greatest.

The Countryside Stewardship scheme

2.21 In April 1996 the Ministry took over from the Countryside Commission

responsibility for the administration of the Countryside Stewardship scheme.

This scheme, which was introduced in 1991, has similar objectives to the

Environmentally Sensitive Areas scheme. It aims to encourage farmers and

other land managers outside environmentally sensitive areas to conserve and

enhance the landscape, its wildlife and historic features and to improve

opportunities for public access. The main characteristics of the two schemes are

set out in Figure 12 overleaf.

2.22 The Environmentally Sensitive Areas scheme is targeted on those areas of the

country which are of national environmental importance; and it is designed to

achieve high levels of take-up and widespread environmental gains in such

areas. It is complemented by the Countryside Stewardship scheme. The latter is

available on all types of land outside environmentally sensitive areas, subject to

annually determined environmental priorities and the financial resources

available. As a result, it can be targeted at farms or groups of farms which

provide the greatest environmental benefit. It therefore provides a flexible

alternative to the Environmentally Sensitive Areas scheme, particularly in areas

where it is not possible to achieve high levels of take-up amongst farmers.

2.23 Now that the Ministry has responsibility for both schemes it is in a position to

ensure that resources are allocated to each cost-effectively.

19

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

PROTECTING ENVIRONMENTALLY SENSITIVE AREAS

The National Audit Office therefore recommends that the Ministry should

establish clear criteria for continued designation. The criteria should include

an assessment of the extent to which the environmentally sensitive area

continues to be successful in meeting the original selection criteria, in

achieving take-up targets and in securing environmental benefits.

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20

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

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The National Audit Office therefore recommends that the Ministry should

review whether existing environmentally sensitive areas meet the criteria

for continued designation. If it decides to remove the designation from an

area, it could:

• on the expiry of Environmentally Sensitive Area agreements with

farmers, replace them with Countryside Stewardship agreements; and

• use the Countryside Stewardship scheme to enhance and regenerate

within the area particular habitats and species of environmental

importance.

This would enable environmental benefits to be maintained without losing

the goodwill of farmers with existing agreements.

Figure 12: Main characteristics of the Environmentally Sensitive Areas and Countryside

Stewardship schemes

Environmentally Sensitive Areas scheme Countryside Stewardship scheme

• available only in designated areas wherethe landscape, ecological and historicfeatures are of national importance.

• available throughout England except inareas designated under theEnvironmentally Sensitive Areas scheme.

• payments apply only to agricultural landthough farmers may be required tomaintain other features where significant.

• payments apply to agricultural andnon-agricultural land. The scheme isfocused on defined target habitats,features and landscapes.

• participation by farmers is voluntary. • participation by farmers is voluntary.

• non-discretionary (all applications whichsatisfy the entry criteria are accepted),although the criteria for someenhancement tiers in certain areas are sostrict as to have a discretionary effect.

• discretionary (applications are consideredin the light of the likely environmentalbenefits and the availability of financialresources).

• relatively static. No new areas have beendesignated since 1994 and none areproposed. Major reviews of existing areasare undertaken only every five years,although these may lead to significantalterations to individual schemes.

• flexible and responsive. National targetsand resource allocations are set annuallyto reflect current priorities and progressachieved to date. They are refined atregional level in consultation with localinterest groups.

• prescriptions, tiers and payment levels areunique to each area. All possible options ineach area may not be available to allfarmers in that area.

• all standard options are availablenationally. Payment rates for each optionare standard and farmers can choosewhich options they wish to include in theirapplications. Additional options can beincluded on an ad hoc basis to addressconservation needs in particular areas.

Source: National Audit Office analysis of Ministry information

Note: The Countryside Stewardship scheme provides a flexible alternative to the Environmentally

Sensitive Areas scheme

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3 Part 3: Monitoring and

compliance

Introduction

3.1 Under the terms of the 1986 Agriculture Act, the Ministry of Agriculture,

Fisheries and Food is required to monitor the effectiveness of each designated

environmentally sensitive area (Figure 13).

Environmental monitoring

3.2 ADAS devised the environmental monitoring programme in 1987 and has since

been responsible for implementing it (Figure 6 on page 9). Four elements are

monitored within each environmentally sensitive area: land cover; landscape;

plant and bird life; and historical and archaeological features. Monitoring is

tailored to the characteristics of each area and carried out periodically. The

results are brought together every five years in individual reports on each area.

3.3 The latest review of the first five environmentally sensitive areas was completed

in 1996 (Figure 14 overleaf). Reviews of the remaining areas are due to be

completed between 1997 and 1999.

3.4 The 1996 review concluded that in the five areas examined the scheme had

been generally successful in maintaining the traditional character of the

landscape and arresting environmental decline. In particular, the ploughing up

of traditional grasslands had been halted. It was too soon, however, to see

statistically significant evidence of animal and plant life being restored and

enhanced, although there were some indications of this in certain areas.

The review noted a number of areas of concern including continued scrub

encroachment on the South Downs and the management of hedges and dykes in

the Broads. Also, four per cent of grassland in the Somerset Levels and Moors

21

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

PROTECTING ENVIRONMENTALLY SENSITIVE AREAS

Figure 13: Monitoring of the Environmentally Sensitive Areas scheme

Type of monitoring Objective Cost (1995-96)

£000

environmental monitoring to assess changes in the landscape, ecology and

historical features of each area

3,300

socio-economic surveys to examine the attitudes of farmers to the scheme and

the adequacy of its financial incentives

80

compliance checks to assess whether farmers are abiding by the

management prescriptions they have agreed to follow

180

Source: Ministry of Agriculture, Fisheries and Food

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had been ploughed up, although this was partly offset by the conversion of

three per cent of arable land to grassland, resulting in a net increase of

one per cent in arable land.

3.5 The National Audit Office’s consultants reviewed the environmental monitoring

framework which ADAS had devised. They noted that few large-scale

monitoring programmes of this kind had been attempted before. There was

therefore little in the way of comparable approaches for ADAS to draw upon,

and ADAS had been required to pioneer new monitoring and analytical

methodologies as the programme had been taken forward. The consultants

raised a number of issues for consideration, as set out in paragraphs 3.6 to 3.10

below.

3.6 Considerable resources are devoted to botanical monitoring. ADAS monitors a

few sites in great detail to distinguish different classes of plant and to measure

small changes over a short time-scale. The results so far are tentative, because

of the time needed to regenerate habitats. In addition, the selection of

22

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

PROTECTING ENVIRONMENTALLY SENSITIVE AREAS

Figure 14: Main conclusions of the 1996 monitoring review of the five environmentally

sensitive areas established in 1987

• Broads: The environmentally sensitive area has been successful in halting the loss toarable farming of permanent grassland in grazing marshes. However, there has been asignificant deterioration in the management of dykes and hedgerows across the area as awhole. The ecological value of grassland and dykes has generally been maintained.Historical features have been maintained and protected as a result of the increase in thearea of permanent grassland.

• Pennine Dales: The wildlife and historical value of the environmentally sensitive area isbeing maintained, and there are suggestions of enhancement in the species diversity ofmeadows and pastures through beneficial agricultural practices. There has been someweakening of landscape characteristics through deterioration in the condition of drystonewalls and field barns.

• Somerset Levels and Moors: The environmentally sensitive area has slowed down theloss of grassland, although an increase in the amount of arable farms on non-agreementland has led to localised fragmentation of the landscape and some damage to historicalfeatures. The length of wet and clear ditches has increased substantially and there isevidence that higher water levels are enhancing the species diversity of wet grassland.

• South Downs: Whist overall take-up has been low, the environmentally sensitive areahas been highly successful in the conversion of over 5,100 hectares of arable land tograssland which has brought about distinct benefits to the landscape. However, scrubencroachment continues to be a problem on existing chalk grassland. Prescriptionsrelating to sheep grazing and scrub control measures need to be strengthened to preventfurther losses of this rare and internationally important habitat.

• West Penwith: The very high proportion of land which has come into agreement hasconferred significant protection and has almost halted the loss of traditional fieldboundaries. The scheme is maintaining the ecological value of rough grassland andarchaeological features.

Source: National Audit Office analysis of Ministry information

In the five areas designated in 1987 the Environmentally Sensitive Areas scheme has been generally

successful in maintaining the traditional character of the landscape and arresting environmental decline.

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monitoring sites was generally based on a stratified, rather than random,

approach. Hence, the results obtained are not statistically representative though

they are nevertheless meaningful and obtained more cost-effectively than from

random sampling.

3.7 Other organisations, including the Countryside Commission and English Nature,

favour “extensive” surveys. Extensive surveys do not provide the same amount

of detailed information as the “intensive” approach adopted by ADAS but are

much cheaper and enable larger areas to be covered relatively quickly. English

Nature has developed “extensive” methods that can be used by its staff as part

of routine work on Sites of Special Scientific Interest. These are underpinned by

more detailed monitoring to validate the “extensive” methods and demonstrate

that the inferences drawn from them are accurate. This ensures that general

trends in the way land is managed can be more easily identified and that the

significance of trends is properly interpreted.

3.8 The National Audit Office considers that in addition to the identification of

trends, the results from “extensive” surveys can be compared with data

collected by other organisations using a similar approach. However, the

National Audit Office also recognises that there are grounds for continuing with

a limited amount of intensive monitoring of ecologically important communities,

where simple indicators would provide insufficient information to establish

trends - for example, where ecological changes are slow.

3.9 Accurate classification of land cover is important. It provides information on the

types of eligible land within each environmentally sensitive area; it helps in the

formulation of targets and the assessment of take-up; and it assists the

monitoring of landscape, biological and archaeological features. ADAS relies

heavily on aerial photography to assess land cover. This is a relatively cheap

method, but it is not always able to distinguish between the range of grassland

types found within an environmentally sensitive area (Figure 15 overleaf).

Ground surveys would address this problem but they are more expensive and

cannot be conducted with accuracy in areas such as open moorland, without the

assistance of aerial photography to delineate the area being surveyed.

3.10 Similarly, baseline land cover surveys provide no indication of the extent or

condition of linear features, such as hedges and walls, either across the whole

environmentally sensitive area or within particular landscape types. This greatly

limits the conclusions which can be drawn from the linear feature targets and

from the sample monitoring of their condition. At the outset of the scheme, the

Ministry considered using aerial photographic surveys to derive information on

linear features, but tests showed that it was not possible to classify these

features reliably or to describe their condition. This element of the monitoring

programme was therefore dropped.

3.11 The 1996 monitoring reports did not include maps to show the geographical

distribution of take-up within each area. Nor was there any consideration of the

extent to which take-up was fragmented or in continuous tracts of land; or was

occurring in the most environmentally valuable areas and complementing other

designations such as Sites of Special Scientific Interest. This reflected more

23

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

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generally the absence of a strategic approach to targeting priority areas within

each environmentally sensitive area and monitoring performance against such

targets.

3.12 As the number of environmental schemes has increased, there has been a

corresponding growth in monitoring activity and the data produced. It is important

that this data should be comparable in order to assess the benefits of different

schemes and their suitability to different circumstances. The Ministry should

therefore adopt, where possible, an approach and methodology in relation to the

monitoring of landscape, nature conservation and cultural heritage which is

consistent across all the agri-environmental schemes it administers (Appendix 3).

24

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

PROTECTING ENVIRONMENTALLY SENSITIVE AREAS

Figure 15: Examples of difficulties in using aerial photography for land cover mapping

• Lake District: Aerial photography has enabled the Ministry to distinguish betweenimproved or semi-improved grasslands which are generally enclosed and unimprovedgrasslands which are mainly the rougher grasses of the fells. But it cannot distinguishbetween meadows and pasture, or separately identify enclosed wetland. Performanceindicators relating to these categories of land cannot therefore be measured accurately.

• Somerset Levels and Moors: The Ministry has invested considerable effort into trying todistinguish between traditional, semi-improved and improved grasslands, recognising thatshifts between these different grassland types would be fundamental to assessing theeffectiveness of the environmentally sensitive area. However, following three successiveaerial photographic surveys, ADAS has concluded that no accurate distinction can bedrawn. This has meant that an important performance indicator (that 75 per cent oftraditional grassland is under agreement) cannot be measured with any degree ofaccuracy.

• Cotswold Hills: By contrast to the above, the nature of the grassland and the availabilityof good ground-survey information from English Nature has resulted in a relativelydetailed classification of the grasslands.

Source: National Audit Office

Note: Aerial photography cannot generally distinguish between the different types of grassland found

within environmentally sensitive areas

In the light of the above findings, the National Audit Office recommends

that:

• the Ministry should consider whether an extensive rather than intensive

approach to botanical monitoring might be more cost effective;

• where there are serious deficiencies in baseline land cover surveys

because of the reliance on aerial photography, the Ministry should

consider the use of ground based surveys for new environmentally

sensitive areas or additional land included within existing areas;

• the Ministry should look for ways of improving baseline information on

linear features, including the scope for generating estimates from

information it already holds as a result of aerial photographic surveys,

ground survey work in sample areas, and agreement mapping;

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Socio-economic surveys

3.13 As part of the 1996 review of the first five environmentally sensitive areas, the

Ministry employed ADAS to conduct socio-economic reviews. The aim was to

determine trends in income, output and employment by means of questionnaire

surveys and interviews with participating and non-participating farmers within

each environmentally sensitive area. The results are set out in Figure 16.

25

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

PROTECTING ENVIRONMENTALLY SENSITIVE AREAS

• the Ministry should ensure that there is a consistent approach and

methodology for monitoring the agri-environment schemes it administers

in order to allow cross-comparisons between the success of different

schemes;

• monitoring reports should include analyses of the geographical

distribution of take-up within each area; and

• the Ministry should focus monitoring on those areas and habitats

identified as a priority for each environmentally sensitive area.

Changes to the monitoring programme recommended above would improveits effectiveness as well as reduce its costs.

Figure 16: Main conclusions of the 1996 socio-economic reviews of the five

environmentally sensitive areas established in 1987

• The level of payments was the main consideration for farmers in deciding whether or notto join the scheme.

• Other reasons for participation included care for the environment and security of income,but these were generally less important. In many cases, joining the scheme had beenassisted by the fact that little change was required to existing farming practices.

• Difficulty in complying with the prescriptions was often a reason for non-participation,together with an expectation that there would be a loss of control and flexibility inmanaging the business.

• Farmers were strongly in favour of the scheme’s continuation despite varying levels ofconcern about the adequacy of the payments and the consequent reduction in theirincomes.

• Most farmers were reluctant to move to higher tiers, either because of perceiveddifficulties in complying with the more demanding or restrictive prescriptions, or becauseof the impression that payment levels offered inadequate compensation.

• Participation in the scheme had increased awareness of environmental issues. Opinionsabout the effect of the scheme on the local environment varied, agreement holdersgenerally being more positive about the environmental benefits than non-participants.

• Even small reductions in payments would be likely to result in a significant loss of farmersfrom the scheme. A substantial increase in payments would be required to improveparticipation.

• If farmers were to leave the scheme or the scheme were to be withdrawn, significantchanges to farming systems and practices would be likely, with adverse environmentaleffects. In extreme cases, for example in the South Downs and Broads, much of the landwould be returned to arable production.

Source: National Audit Office analysis of ADAS information

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3.14 The National Audit Office’s own discussions confirmed the main findings of

ADAS’s socio-economic reviews. In particular, the National Audit Office noted

that the continuing promotion of the scheme and the availability of financial

incentives were significant factors in influencing farmers not to adopt or revert

to more intensive farming methods.

Compliance checks

3.15 Field inspectors in the Ministry’s nine regional service centres visit a sample of

agreement holders each year to check that they are complying with the scheme’s

management prescriptions. Ministry guidance requires each centre to check

20 per cent of agreements each year. This target was originally set to enable every

agreement holder to be visited during the lifetime of the scheme. It is much higher

than the five per cent level of checking required by European Union regulations.

3.16 The National Audit Office examined the level of compliance monitoring

undertaken by each regional service centre and the action taken in cases of

non-compliance. The examination showed that:

• In 1995, all regional service centres except Nottingham achieved the 20 per cent

target for compliance inspections (Figure 17). This was a big improvement on

the position in 1994 when no regional service centres achieved the target.

26

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

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Figure 17: Levels of compliance monitoring by regional service centres

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• 1,586 compliance visits were carried out in 1995, of which 142 (9 per cent)

revealed suspicions of non-compliance. Further investigation confirmed

non-compliance in 86 cases (Figure 18). Grants paid in 1995-96 on these

86 agreements totalled £310,000.

27

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

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Figure 18: Action taken in cases of non-compliance by agreement holders in 1995

Environmentally

Sensitive Area

Number of

inspections

revealing

non-compliance

Nature of non-compliance Action taken

Reason Number

of cases

Action Number of

cases

Avon Valley 1 Various 1 Warning letter 1

Broads 36 Injurious weeds 21 No action 1

Ungrazed area 6 Further visit 1

Ineligible area/area in

doubt

4 Warning letter 22

Unauthorised buildings 3 Revised agreement and money recovered 12

Poor ditch maintenance 2

Cotswold Hills 3 Land sold 2 Warning letter 1

Fertiliser use 1 Agreement revised 2

Lake District 16 Cutting of rushes 4 No action 1

Walling not maintained 4 Further visit 1

Mapping error 2 Warning letter 9

Dumping of rubbish 1 Revised agreement 2

Inbye field cultivated 1 Revised agreement and money recovered 2

Installation of land

drainage

1 Money recovered 1

Poaching, and fertiliser

use

1

Thistle infestation 1

Filling of natural

depressions

1

North peak 1 Overgrazing 1 Warning letter 1

Pennine Dales 9 Meadows not cut 7 Warning letter 2

Poor maintenance of

walls

2 Recovery of money sought 1

Payment withheld 6

Somerset levels

and Moors

11 Poor ditch maintenance 4 No action 1

Dumping of rubbish 2 Further visit 3

Poor scrub control 1 Warning letter 4

Poaching 1 Agreement revised 1

Grazing of tier 2 land 2 Warning letter and payment withheld 2

Unauthorised works 1

South Wessex

Downs

1 Overgrazing 1 Warning letter 1

South West Peak 2 Overgrazing 1 Warning letter 1

Overclaiming of walling 1 Warning letter and money recovered 1

Suffolk River

Valleys

6 Ineligible/ungrazed area

Unauthorised

5

1

Revised agreement

Revised agreement and money recovered

5

1

Source: National Audit Office analysis of regional office records

Note: No cases of non-compliance were found in the remaining twelve environmentally sensitive areas

In 1995, 86 field inspections revealed evidence of non-compliance by agreement holders. Action taken ranged from warning letters to revising

agreements and recovering or withholding payments.

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• Action taken against the 86 non-compliant agreement holders included

sending warning letters only (42 cases); revising the agreement and/or

recovering monies (28 cases); and withholding payment (8 cases). Five cases

were scheduled for further visits by a project officer to examine the problem

and discuss it with the farmer. In three cases no action was taken because

the farmer had remedied the problem.

3.17 In 1995, 98 per cent of field inspections under the Environmentally Sensitive

Areas scheme were selected at random: the rest were chosen either on the basis

of assessed risk or as a result of information received from project officers or

members of the public. However, the National Audit Office considers that it

would be more effective for the Ministry to target a much larger proportion of

inspections on those agreement holders who represent the greatest risk.

3.18 Figure 19 sets out suggested risk factors to be taken into account in the

selection of field inspections based on risk analysis. The National Audit Office

estimates that this approach should lead to administrative cost savings of the

order of £100,000 a year without reducing the effectiveness of compliance

monitoring.

Performance measures

3.19 In 1994 the Ministry introduced a set of performance indicators to help to

measure the scheme’s effectiveness. For each area, the Ministry identified a

number of environmental objectives based on the statutory requirement to

maintain and enhance the characteristic landscape, wildlife and historical

features of the area. Under each objective it specified various performance

indicators and targets which would enable it to assess how far these objectives had been

achieved. The indicators and targets are unique to each area and are of two kinds:

28

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

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The National Audit Office therefore recommends that the Ministry should

adopt a risk-based approach to the selection of field inspections. This would

enable the level of checking to be reduced to the European Union minimum

of 5 per cent.

Figure 19: Suggested risk factors to be used in selecting claims for compliance checking

• whether the claimant is new to the scheme;

• the size of the claim;

• the amount of the claim relating to enhancement tiers;

• any change to the agreement;

• the level of previous errors or queries;

• the number of years since the last compliance inspection;

• the results of previous inspections;

• whether claims have been made under other schemes; and

• particular risks identified from analysis of the results of field inspections.

Source: National Audit Office

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• take-up targets, usually expressed as a percentage of eligible land that should

be under agreement - for example, that 75 per cent of heathland in

Breckland should be under tier 1 agreement; and

• environmental impact indicators, describing the desired result of designating

the area as environmentally sensitive - for example, that there is no loss of

pollarded willows in the Somerset Levels and Moors.

3.20 However, many performance indicators do not set out clearly the criteria for

evaluating success. For example, one of the indicators for the Somerset Levels

and Moors is that the “vegetation characteristic of wet grassland increases on

land under tier 3 agreement”. Monitoring reports completed by ADAS did,

however, set out a complex and detailed methodology for assessing the extent of

changes though no targets as such were included. And ADAS considered that

assessments of the extent of changes were capable of being related to the

performance indicators.

3.21 The performance indicators were introduced seven years after the start of the

scheme and after the environmental monitoring programme had already been

designed. Partly because of this, and partly because of the difficulties

encountered in land cover mapping, some indicators cannot be measured at all

by the present monitoring programme (see Figure 15 on page 24 which cites

several important examples). In addition, some indicators can only be partially

measured. For example, one indicator in the Somerset Levels and Moors is that

“there is no increase in the risk of damage to archaeological and historic

features from agricultural operations”. It was not possible to confirm changes in

the condition of historical features resulting from changes in land cover and the

changes detected were recorded from sample areas.

3.22 The performance indicators relate only to the environmentally sensitive area as

a whole; there are no separate indicators to address particular target areas. In

the South Downs, for example, there is no specific measure of the extent to

which traditional chalk grassland on the scarp face, probably the most

important feature in the area, is being maintained.

3.23 In addition, the take-up targets frequently convey no impression of the

environmental benefits to the area if they are achieved. One of the targets in the

Cotswolds, for example is that five per cent of non-stockproof dry stone walls

should be restored. It is unclear how many metres of wall this represents and

how this relates to the total length of walls requiring repair.

3.24 The National Audit Office considers that the Ministry’s performance indicators

need to provide a better basis for evaluating the scheme’s effectiveness.

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Assessing the effectiveness of the EnvironmentallySensitive Areas scheme

3.25 The Ministry has separate programmes for assessing take-up, environmental

benefits, socio-economic factors, the extent of compliance and the costs and

benefits to farmers. However, as these various matters are not brought together

in a single report, there is no evaluation of the effectiveness of each

environmentally sensitive area or of the scheme as a whole.

3.26 Nor is there any assessment of the overall implications for typical farms within

individual environmentally sensitive areas, as currently no farm case studies

are included within the monitoring programme. Whole farm case studies have

been used as part of monitoring programmes for other schemes to provide

practical demonstrations of the inter-relationship between the different

environmental aspects of a scheme and between these and socio-economic

considerations, including the perceived benefits of the scheme to the farming

community.

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MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

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The National Audit Office therefore recommends that:

• each performance indicator should set out the criteria for evaluating

success;

• these criteria should be capable of being measured;

• performance indicators should address priority areas within each

environmentally sensitive area, as well as the area as a whole; and

• take-up targets should clearly reflect what is needed to achieve defined

levels of environmental benefits.

The National Audit Office recommends that the Ministry’s periodic reviews

of each environmentally sensitive area should include an assessment of the

effectiveness of each environmentally sensitive area and of the scheme as a

whole. The Ministry should ensure that the reviews address and report on

all aspects of the scheme, including the extent of take-up, the results of

environmental monitoring, socio-economic surveys and compliance checks,

and a comparison of payment rates with income foregone. The Ministry

should consider whether the inter-relationship between the various aspects

of the scheme could be usefully demonstrated at a practical level by the use

of farm case studies which would be monitored within each environmentally

sensitive area.

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Views of other organisations on the effectiveness of theEnvironmentally Sensitive Areas scheme

3.27 The National Audit Office consulted a range of organisations for their views on

the scheme. The main points which emerged are set out in Figure 20.

The Ministry’s 1996 consultation paper

3.28 Following the completion by ADAS of the 1996 environmental monitoring

reports, the Ministry carried out a policy review of the five environmentally

sensitive areas designated in 1987. This took account of the views of farmers

and the various organisations consulted and the findings of the National Audit

Office. In October 1996 the Ministry set out in a consultation paper options and

proposals for each area and invited views. After the consultation period the

Ministry intends to submit recommendations to Ministers and the Treasury for

approval and arrange for Statutory Instruments to be laid which will set out the

detailed prescriptions and payment levels for each area.

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MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

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Figure 20: Views of other organisations on the effectiveness of the Environmentally

Sensitive Areas scheme

• There was a broad consensus that the scheme represented a landmark, and had beeninfluential in helping to change the attitudes of farmers. It had acted as a model for otherschemes and was still fulfilling a useful role.

• There had been a general shift over the last ten years in environmental thinking awayfrom preventive approaches aimed at halting further degradation towards approachesfocused on enhancing the environment. The Ministry had attempted to mirror this. Butthere remained a feeling amongst some organisations that still more could be done toprovide a positive system of rewards for clearly defined environmental outputs.

• There was general concern that the prescriptions made no provision for encouraging moreenvironmentally friendly arable farming.

• There was some concern that basic tier prescriptions were too loose and were notsufficient to prevent further degradation.

• Some organisations were concerned at the Ministry’s apparent concentration on achievingtake-up. This was not seen to be as important as the need to target priority areas withineach environmentally sensitive area to achieve coherent blocks of enhanced land andproduce much greater environmental gains.

• Reference was made to the need to ensure that performance indicators for the schemeare consistent with national and local biodiversity targets.

• Some organisations considered that there was no further need to have boundarydelineated schemes; and that the Countryside Stewardship scheme offered the possibilityof extending environmental incentives to farmers more widely.

Source: Organisations which contributed views to the National Audit Office (see Figure 7)

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3.29 The changes proposed in the consultation paper include:

• revisions to performance objectives and the development of new targets in

1997 as a basis for managing the scheme and evaluating its effectiveness -

local interest groups would be invited to advise on priorities and suggest

targets;

• reductions in the environmental monitoring programme to contain its costs;

• more fundamental incentives to encourage environmentally friendly arable

farming, with the introduction of a winter stubble tier in West Penwith and

the South Downs;

• flexibility in management prescriptions: to target certain areas and types of

habitats within each environmentally sensitive area and to achieve

appropriate management of specific sites; and

• greater discretion in accepting land into certain tiers so as to target those

areas and habitats where the input of resources is most likely to be

successful.

3.30 If implemented successfully, such changes would address many of the concerns

identified by the National Audit Office in this report.

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4 Part 4: Costs and payments

The costs of the scheme

4.1 The Environmentally Sensitive Areas scheme is one of the most expensive

administered by the Ministry in terms of the ratio of administrative costs to

grant payments. Total administrative costs in 1995-96 were £13.3 million -

some 46 per cent of grants paid to farmers, although this percentage has fallen

with the rise in take-up (Figure 21). Estimated figures for 1996-97 indicate a

further drop in administration costs.

4.2 A breakdown of administrative costs is shown in Figure 22 overleaf. These fall

into two groups: management costs totalling £8 million; and environmental

monitoring and research costing £5 million.

33

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

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Figure 21: Environmentally Sensitive Areas scheme - Grant payments andadministrative costs, 1991-92 to 1996-97

0

5

10

15

20

25

30

35

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4.3 The high costs of managing the scheme arise from a variety of factors:

• the use of project officers to provide expert advice and assistance with all

aspects of the scheme;

• the promotion and set-up costs relating to environmentally sensitive areas

designated in 1993 and to a lesser extent those designated in 1994;

• the work involved in managing well-established environmentally sensitive

areas. These are costly to administer since many amendments are made to

agreements as land is bought and sold.

4.4 Some £3.5 million (60 per cent) of ADAS management costs (functions now

carried out by the Farming and Rural Conservation Agency - see paragraph 1.9)

relates to the use of project officers. These staff are key to the running of the

scheme: they liaise with farmers and the Ministry to promote the scheme, draw

up agreements, and advise from day to day on any problems which might

subsequently arise. The success and effectiveness of the scheme depend on their

credibility and expertise.

4.5 Observation and analysis by the National Audit Office of the tasks undertaken by

project officers suggest that their work could be linked more closely to key

priorities and environmental risks. In particular:

34

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

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Figure 22: Administrative costs of the Environmentally Sensitive Areas scheme, 1995-96

ADASenvironmental

monitoring£3.3 m

Ministry researchand development

£2.0 m

Ministry regionalservice centres

£1.6 m

Ministryheadquarters

£0.5 m

ADASmanagement

£5.9 m

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• a greater proportion of visits to farmers could be initiated by project officers

themselves, based on the strategic priorities within each environmentally

sensitive area and the extent of risk;

• project officers could undertake a more systematic collection of information

about management practices and environmental risks within each area; and

• the Ministry could undertake better monitoring of the use and effectiveness of

project officer time.

Research

4.6 The Ministry has a separate research programme to support the

Environmentally Sensitive Areas scheme. This cost some £2 million in 1995-96.

The main objective is to investigate the environmental effects of agricultural

practices and provide better information on which to determine policy and the

practical arrangements for policy implementation.

4.7 In 1990 the Ministry introduced a more formal method of commissioning and

monitoring research involving greater responsibility for policy divisions in

specifying the objectives, and monitoring the progress of, individual research

projects. The National Audit Office found that these procedures had not been

fully implemented in respect of environmentally sensitive areas. The

requirement to complete annual monitoring reports on research projects carried

out by contractors was considered by the Ministry to be bureaucratic and an

inefficient use of resources. Instead, in conjunction with its scientific advisers

the policy division had carried out major reviews in 1992-93 and 1995-96, as it

felt that this represented a more effective way of evaluating its research

programme. In 1996, the Ministry carried out further reviews of its research

procedures and removed the requirement for policy groups to be routinely involved

in the annual monitoring of projects, though detailed guidance has yet to be issued.

35

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

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The National Audit Office therefore recommends that the Ministry should

consider adopting the measures set out above. The development of such a

programme would increase the accountability of project officers to the

Ministry. It would also enable the Ministry to reduce the current levels of

compliance checking and environmental monitoring, whilst providing

additional feedback on the effectiveness of the scheme within each

environmentally sensitive area.

The National Audit Office recommends that the Ministry should ensure that

its revised procedures result in the proper control and monitoring of

research. This would help to minimise costs and ensure that research is

targeted effectively and the results included in policy reviews of the scheme.

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Local variations in costs

4.8 Little comparative analysis is carried out of the efficiency of the Ministry’s regional

service centres or ADAS regional offices (now those of the Farming and Rural

Conservation Agency) in administering the Environmentally Sensitive Areas scheme.

Annual management reports compiled by ADAS include data on budgets and staff

resources used but there are few performance indicators relating staff resources to

the workload, such as the number of new applications, changes to existing

agreements, or claims for payment. The Ministry considers that administrative

performance measures are less appropriate for this scheme since environmentally

sensitive areas vary widely in their complexity and the issues which arise.

4.9 The National Audit Office analysed the time taken by the Ministry’s regional service

centres in 1995-96 to process new applications for agreements and claims on

existing agreements. This analysis included the calculation of a composite

performance indicator for each regional service centre, taking into account the

difference in staff time required to process applications and claims. The results

identified substantial differences in processing efficiency between local offices

(Figure 23). Within the underlying figures, the time taken to process an

application ranged from 53 minutes to 7.5 hours and the time taken to process

a payment claim ranged from 7 to 24 minutes.

36

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

PROTECTING ENVIRONMENTALLY SENSITIVE AREAS

Figure 23: Time taken by the Ministry’s regional service centres to process applicationsand claims

0.0 0.5 1.0 1.5 2.0 2.5 3.0 3.5

Northallerton

Bristol

Carlisle

Cambridge

Reading

Worcester

Exeter

Crewe

Hours per weighted application/claim

Notes: 1. Applications require significantly greater staff resources to process than payment claims.As the number of each can vary significantly between different regional service centres,applications and payment claims have been weighted in order to enable comparisonsto be made.

2. Nottingham regional service centre has been excluded due to the very small number ofagreements it administers and its position until 1995-96 as lead region for the scheme.As lead region it was responsible for responding to policy queries from other regionaloffices, liaising with headquarters, and monitoring the operation of the scheme. Thesefactors explain its high figure of 10.5 hours per weighted application/claim.

The time taken to process applications and claims varies widely between regional service centres.

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4.10 The analysis of 1995-96 data revealed similar variations within ADAS regional

offices:

• the time taken to process an application ranged from 8.6 hours (West

Penwith) to almost 48 hours (North Peak);

• total staff resources per agreement ranged from 8.1 hours (Somerset Levels

and Moors) to 38.9 hours (Essex Coast);

• the number of project officer visits per agreement holder ranged from 0.37

(Somerset Levels and Moors) to 2.58 (Blackdown Hills).

4.11 The National Audit Office also compared staff resources used to process new

applications by ADAS regional offices and the Ministry’s regional service

centres. The work of ADAS project officers (now those of the Farming and Rural

Conservation Agency) links directly with that of staff in the Ministry’s regional

service centres. For example, difficulties in mapping agreements accurately

would be reflected not only in increased project officer time but also in

increased staff time within regional service centres on administration. If

variations in regional service centre performance were related to the complexity

of environmentally sensitive areas, then there would have been a similar

distribution of ADAS and Ministry staff resources. However, the National Audit

Office’s analysis showed little if any correlation between the time taken by ADAS

regional offices and the Ministry’s regional service centres in processing new

applications in 1995-96 (Figure 24 overleaf).

4.12 The National Audit Office noted that local variations in processing times

between regional service centres did not appear to be explained by differences

in the complexity of environmentally sensitive areas and the length of time they

had been established.

4.13 There is no system at headquarters or lead regions for establishing key data at

the end of each scheme year. Some information, such as the number of

amendments to existing agreements, is not collected at all; other information,

such as the number of approved applications, is constantly being updated and is

difficult to extract by scheme year.

37

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

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The National Audit Office recommends that the Ministry should investigatethe variations in the efficiency of regional service centres in dealing withapplications and claims. The aim should be to identify good practice so thatall local offices can seek to achieve the standards of the best.

The National Audit Office recommends that the Ministry should defineclearly the processing and resource information it requires and ensure thatit is collected accurately and promptly. The new computerised informationsystems at headquarters should help here. This information should be usedby the Ministry and ADAS (now the Farming and Rural ConservationAgency) to undertake regular analyses of the comparative efficiency of theirlocal offices.

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Budgeting and forecasting

4.14 Since 1992-93 the Ministry has considerably underspent its budget for the

Environmentally Sensitive Areas scheme (Figure 25 opposite). In 1995-96, for

example, grants to farmers less recoveries from the European Union amounted

to £15.8 million, against an estimate of £37.2 million. The very large budgetary

underspends resulted from inaccuracies in forecasting in two areas:

• the level of grants paid to farmers, as a result of over-estimates of likely

take-up and delays in launching Stage III and IV environmentally sensitive

areas in 1993 and 1994; and

• European Union receipts, mainly arising from the Ministry’s failure to take

account of an increase from 25 to 50 per cent in the level of European Union

support.

Payment reviews

4.15 The payment rates to farmers are set down in regulations and are based on

estimates of the income farmers would forego by adopting environmentally

friendly but less efficient farming methods. Prior to 1 April 1997, the Ministry

required ADAS to carry out reviews of payment rates in each environmentally

38

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

PROTECTING ENVIRONMENTALLY SENSITIVE AREAS

Figure 24: Comparison of the time taken by ADAS and the Ministry’s regional service centres to process newapplications

Source: National Audit Office analysis of Ministry and ADAS data

Note: Regional service centres do not record staff time on each environmentally sensitive area. ADAS local offices are structureddifferently in their number, location, and the areas they administer. However, as they record time on administering each area,the National Audit Office was able to analyse their work on a similar basis. From April 1997, the Farming and RuralConservation Agency took over responsibility from ADAS for assisting the Ministry with the management of theEnvironmentally Sensitive Areas scheme.

There was little correlation between the time taken by ADAS and the Ministry’s regional service centres in processing new applications.

Regional Service Centres ADAS

0

1

2

3

4

0

10

20

30

40

50

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sensitive area in the second and fourth year of each scheme (Figure 6 on

page 9), including estimates of the annual income foregone by agreement

holders in complying with the laid down prescriptions. The Ministry then

considered future payment rates for each area in the light of the income

foregone figures and other factors, such as the extent to which existing payment

rates are attracting farmers to participate in the scheme. With effect from 1

April 1997, the payment reviews are the responsibility of the Farming and

Rural Conservation Agency.

4.16 Any proposed changes to rates are submitted to the European Commission for

approval. If approved, the changes are implemented through individual

Statutory Instruments setting out the terms and conditions of the management

agreements for each designated area.

4.17 The National Audit Office compared current payment rates with ADAS’s latest

estimates of income foregone in the 110 main tiers of the 22 environmentally

sensitive areas (Figure 26 overleaf).

4.18 The National Audit Office calculated that, if payment rates were reduced to

income foregone levels in the 19 tiers where they are currently higher, the

saving would be £1.4 million a year. On the other hand, if payment rates were

increased to income foregone levels in the 84 tiers where they are currently

39

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

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Figure 25: Net costs of the Environmentally Sensitive Areas scheme: estimates andoutturns, 1987-88 to 1995-96

Source: Ministry of Agriculture, Fisheries and Food

Note: Net costs represent total grant payments to farmers less European Union reimbursements

Since 1992-93, the Ministry has consistently over-estimated the net costs of the Environmentally

Sensitive Areas scheme.

0

5

10

15

20

25

30

35

40

Financial year

£m

illi

on

Net cost (estimate)

Net cost (outturn)

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lower, the additional cost would be £8.1 million a year. For the purposes of

these calculations the National Audit Office assumed that changes in payment

rates would not affect the number of farmers in the scheme. In practice the

savings from reducing and the costs of increasing rates would be higher

because in the former case some farmers would leave the scheme and in the

latter case more farmers would join the scheme.

4.19 Where payment rates are higher than income foregone levels, the Ministry’s policy

is to reduce tier payments only if there are balancing increases on other tiers for

most agreement holders, or if it is confident that significant withdrawals from the

scheme would be unlikely. In 1993, the Treasury sought assurance that tier

payments would be reduced should income foregone fall below payment levels.

However, some tier payments have been retained at levels considerably higher

than income foregone estimates (for example, see Figure 27).

40

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

PROTECTING ENVIRONMENTALLY SENSITIVE AREAS

Figure 26: Comparison of payment rates with estimates of income foregone for the

110 main tiers in the 22 environmentally sensitive areas

Comparison of payment rate with

income foregone estimate

Number

of tiers

Eligible land

area

hectares

Area under

agreement

hectares

Percentage of

eligible land

under

agreement

Payment rate more than 20% higher

than income foregone

13 213,500 71,000 33

%

Payment rate up to 20% higher than

income foregone

6 68,900 35,700 52

%

Payment rate within plus or minus 2%

of income foregone

7 116,000 26,400 23

%

Payment rate up to 20% lower than

income foregone

21 255,100 107,800 42

%

Payment rate more than 20% lower

than income foregone

63 862,600 186,000 22

%

Source: National Audit Office analysis of ADAS data

Notes: (i) The analysis excludes tiers covering supplementaryprovisions for restoringhedgesandwalls.

(ii) Landmaybeeligible formore thanone tier. The figures in the third column therefore sumto

a higher figure than the total eligible land area for all environmentally sensitive areas.

Figure 27: River valley payments in Breckland

In 1994 ADAS estimated the income foregone for farmers in Breckland entering river valley grassland into

the scheme at £44 per hectare, compared with a payment rate of £125 per hectare. The Ministry originally

considered a token cut of £10 in the payment rate to £115 but the impact, even when compensated by an

increase of £10 for heathland, would have been to reduce average payments for over 80 of the

110 agreement holders. As a result, no reduction was made. A reduction in the payment for river valley

grassland to, say, £50 would have saved £180,000.

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4.20 Where payment rates are less than income foregone, it is not always sensible or

feasible for the Ministry to raise payment levels. In some tiers take-up is high

even though payment levels are considerably lower than income foregone. In

such cases, the Ministry considers that it is generally unnecessary to raise

payment levels. In tiers where the Ministry is seeking to encourage farmers to

revert arable land to grassland, the annual income foregone can be substantial -

reaching nearly £400 per hectare in some areas. The large difference arises

because of the continuing profitability of intensive arable farming and the large

subsidies available under the Arable Area Payments scheme. In such

circumstances the Ministry considers that it is not worth attempting to set

payment levels to match income foregone.

4.21 The National Audit Office noted that income foregone figures involve complex

calculations and assumptions based on the notion of a typical efficient farmer.

However, other factors will frequently affect the behaviour of farmers, and it is

therefore important to take into account the level of payment that they will

accept. For example where levels of take-up are high even though payment

levels may be below income foregone, there may be no need to increase the

financial incentives available. Conversely, even a small reduction in payments

where they are greater than income foregone may in some cases result in

considerable numbers of farmers leaving the scheme. Because of the difficulty of

matching payments to income foregone on a tier basis, the Ministry has

therefore sought to ensure that payments are not excessive by monitoring the

level of take-up and payments in each Environmentally Sensitive Area as a

whole.

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MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

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The National Audit Office therefore recommends that:

• as at present, payment rates should be set on an objective basis, taking

account of income foregone and the sensitivity of take-up to changes in

payment levels and the environmental objectives and scheme targets; and

• where payment rates are significantly higher than income foregone, the

Ministry should keep under review whether those rates remain in line

with the objective assessment of the targets for those areas

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5 Appendix 1

Developments since 1985 in the United Kingdomand Europe to encourage environmentally friendlyfarming

1985 Development by the Ministry of Agriculture, Fisheries and Food and the

Countryside Commission of an experimental agri-environmental scheme in the

Norfolk Broads (Halvergate Marshes) in response to acute public concern about

the continuing pressure to drain and plough marshland for the production of

arable crops.

1985 Member States of the European Community allowed to make payments to

farmers in environmentally sensitive areas.

1986 The Agriculture Act (section 18) empowers Ministers to create environmentally

sensitive areas.

1987 European Regulation makes national agri-environment schemes eligible for

European Community funding at the rate of 25 per cent of grants paid.

1987 Launch of the first five environmentally sensitive areas (Stage I).

1988 Launch of five more environmentally sensitive areas (Stage II).

1991 The Countryside Commission launches the Countryside Stewardship scheme.

1991-92 Policy review and re-designation for a further 5 years of Stage I environmentally

sensitive areas.

1992 Inter-governmental agreement to promote the preservation of endangered

habitats and species (the Rio Biodiversity Accord).

1992 Major reform of the Common Agricultural Policy to reduce over-production and

fulfil commitments arising from the 1992 GATT world trade agreement.

Measures include a regulation requiring Member States to implement

agri-environment schemes. Schemes approved under this regulation are eligible

for European Community contributions at the rate of 50 per cent of grants paid

(or 75 per cent in disadvantaged areas).

1992-93 Policy review and re-designation for a further 5 years of Stage II

environmentally sensitive areas.

1993 Launch of a further six environmentally sensitive areas (Stage III).

1994 Launch of the final six environmentally sensitive areas (Stage IV).

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1994 Setting of detailed performance indicators for all environmentally sensitive

areas.

1995 Rural White Paper proposes some rationalisation of agri-environment schemes,

and the creation of an Agri-Environment Steering Group to coordinate policy in

this area.

1995 National Agri-Environment Steering Group established to advise the Ministry on

the objectives, management and monitoring of all the Ministry’s environmental

land and management schemes. Membership includes the Department of the

Environment (now the Department of the Environment, Transport and the

Regions), English Nature, the Countryside Commission and English Heritage.

1995 The United Kingdom Biodiversity Action Plan Working Group, set up following

the Rio Biodiversity Accord, recommends a wide range of detailed targets for

the United Kingdom.

1996 Transfer of Countryside Stewardship scheme from the Countryside Commission

to the Ministry of Agriculture, Fisheries and Food.

1996 Second five yearly policy review of Stage I environmentally sensitive areas.

Source: National Audit Office

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6 Appendix 2

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Environmentally sensitive areas - key data

Name Total Area

(hectares)

Eligible

Area

(hectares)

National

Park?

Area of

Outstanding

Natural

Beauty?

Whole

Farm?

(2)

Take-up

(% Eligible

Area) (5)

Arable Land

(% Eligible

Area) (6)

Description

Stage I (1987)

Broads 36,100 24,000 Yes (1) No No 64% 27% Lowland wetland

Pennine Dales 46,600 39,100 Yes Yes Yes (3) 68% 0% Upland

Somerset Levels and Moors 27,700 25,900 No No No 61% 9% Lowland wetland

South Downs 69,000 51,700 No Yes No 22% 60% Chalk downland

West Penwith 7,200 6,900 No Yes Yes (3) 94% 0% Grassland

Stage II (1988)

Breckland 94,000 51,600 No No No 11% 89% Lowland, heath

Clun 21,400 18,900 No Yes Yes 77% 13% Upland

North Peak 54,900 50,500 Yes No Yes 81% 0% Moorland

Suffolk River Valleys 43,600 32,600 No No No (4) 36% 67% River valley

Test Valley 4,800 3,300 No No No (4) 40% 27% River valley

Stage III (1993)

Avon Valley 5,200 3,800 No No No 31% 15% River valley

Exmoor 80,700 67,700 Yes No Yes 66% 24% Moorland

Lake District 245,400 219,300 Yes No Yes 49% 3% Upland, moorland

North Kent Marshes 13,700 11,600 No No No 38% 42% Lowland wetland

South Wessex Downs 44,900 38,300 No Yes Yes 54% 81% Chalk downland

South West Peak 33,900 27,000 Yes No Yes 68% 7% Upland, moorland

Stage IV (1994)

Blackdown Hills 39,900 32,000 No Yes Yes 19% 8% Upland

Cotswold Hills 84,700 66,100 No Yes Yes 57% 61% Upland

Dartmoor 100,500 84,500 Yes No Yes 19% 10% Upland, moorland

Essex Coast 27,500 23,000 No No No (4) 10% 27% Coastal wetland

Shropshire Hills 38,500 34,900 No Yes Yes 35% 32% Upland

Upper Thames Tributaries 27,700 23,200 No No No (4) 21% 54% River valley

Source: National Audit Office analysis of Ministry data

Notes: (1) The Broads Authority performs a similar function to National Parks.

(2) Some environmentally sensitive areas require all the farmer�s land to be entered in the scheme.

(3) In Pennine Dales and West Penwith farmers are obliged to enter all their land, but the prescriptions apply only to grassland

as there is little arable land in these areas.

(4) In these areas the farmer�s permanent grassland (including previous arable reversion) must be entered.

(5) Take-up shows land under agreement as a percentage of total eligible area.

(6) Arable land shows total arable land within the environmentally sensitive area as a percentage of the total eligible area.

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7 Appendix 3

45

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

PROTECTING ENVIRONMENTALLY SENSITIVE AREAS

Overview of countryside environmental schemes In England

Scheme Payments

1995-96

£m

Objectives

Ministry of Agriculture, Fisheries and Food

Environmentally Sensitive Areas 29.1 Aims to protect and enhance the environment by encouraging environmentally

beneficial agricultural practices in parts of the country where the landscape,

wildlife or historical interest is of national importance.

Countryside Stewardship Scheme 11.9 Targets the conservation and enhancement of some key English landscapes,

features and habitats and, where appropriate, improvements in public access.

The scheme offers 10 year management agreements and a wide ranges of

capital grants.

Nitrate Sensitive Areas 2.4 Compensates farmers with land in designated nitrate sensitive areas for

voluntarily changing their farming practices in ways which significantly reduce

nitrate leaching into selected public drinking water sources.

Countryside Access Scheme 0.1 Aims to encourage farmers who are entering suitable land into the five-year

guaranteed set-aside option of the Arable Area Payments scheme to open it up

for new public access.

Farm and Conservation Grant Scheme 11.0 Aims to encourage agricultural businesses to adopt conservation-based farming

practices through grant aided capital investments. Closed to new applicants.

Farm Woodland Premium Scheme 1.9 Aims to encourage the afforestation of agricultural land through payments to

help offset farming income foregone from converting productive land to

woodland.

Habitat Scheme 0.1 Aims to create, protect or enhance valuable wildlife habitats. In England the

targeted habitats are waterside areas, saltmarsh and land which were formerly in

the Five-year Set-aside scheme.

Moorland Scheme 0.0 Available to upland farmers outside environmentally sensitive areas who are

willing to reduce their stocking densities and manage their land in order to

improve the condition of heather and other moorland shrub.

Organic Aid Scheme 0.3 Available throughout England to farmers who wish to convert to organic

production.

Countryside CommissionCountryside Premium Scheme 0.2 Provides incentives for the positive environmental management in seven

counties of Eastern England of land entered into the Five-year Set-aside scheme,

for the benefit of wildlife, the landscape and the local community. Closed to new

applicants and final payments on existing agreements were made in 1996-97.

Land Acquisition 0.7 Aims to bring threatened land of high landscape quality or recreational value into

protective ownership.

Landscape Conservation Grants 0.3 Schemes part-funded by the Countryside Commission in partnership with local

authorities; providing incentives for individuals to undertake small scale, priority

landscape enhancement or improvement works appropriate to the local area.

Countryside Commission support for these schemes is expected to cease in

1997-98, but many will continue with local authority funding beyond that date.

Conservation Action Grants 0.5 Mainly offered as part of ongoing programmes of work with local authorities or

voluntary groups; funds to support small scale conservation works and

woodland and visitor management project activities (not generally for individual

farmers or land managers).

continued ...

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8

46

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

PROTECTING ENVIRONMENTALLY SENSITIVE AREAS

Overview of countryside environmental schemes in England continued

Scheme Payments

1995-96

£m

Objectives

English HeritageManagement Agreements and 0.2 May be offered to farmers with archaeological sites on farmland.

Farm Survey Grants

English NatureSites of Special Scientific Interest 5.6 Payments may be available for management which will safeguard and enhance

the wildlife interest.

Conservation grants, national and local 1.0 To support projects of benefit to nature conservation.

Wildlife Enhancement Scheme 1.0 Aims to foster positive management to encourage wildlife on specified Sites of

Special Scientific Interest and adjacent land.

Reserves Enhancement Scheme 0.7 Aims to provide support and assistance to trusts within the Wildlife Trust

Partnership and to some other Voluntary Conservation Organisations to manage

their Sites of Special Scientific Interest.

Forestry CommissionWoodland Grant Scheme 14.1 Grants for the creation and management of new woodlands.

National Parks 3.5 A variety of schemes specific to each National Park.

Total 84.6

Source: National Audit Office

Note: Some schemes may include payments which are for non-agricultural purposes

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Appendix 4

47

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

PROTECTING ENVIRONMENTALLY SENSITIVE AREAS

Tier structure, objectives and prescriptions for selected environmentally sensitive areas

Somerset Levels and Moors

Tier 1: To maintain the landscape and grassland in the Somerset Levels and Moors.

Any grassland is eligible to be entered into this tier. The prescriptions involve limiting fertiliser levels and maintaining

minimum water levels in ditches. Farmers must also maintain traditional landscape features such as gates, hedges

and pollarded willows; seek advice on new tree planting, building and engineering works; and not destroy features of

historic interest.

Tier 2: To enhance the ecological interest of grassland.

All grassland with significant ecological interest or potential is eligible. Farmers must comply with all tier 1

prescriptions and further prescriptions which include more stringent fertiliser levels and maintaining higher water

levels.

Tier 3: To enhance the ecological interest of grassland by the creation of wet winter and spring conditions.

Only blocks of grassland where the specified water levels can be achieved and which have significant ecological

interest or potential can be entered. As well as tier 1 prescriptions, farmers must follow low input grassland

management not using any fertiliser other than farm-yard manure and restricting grazing. They can also opt for

maintaining higher water levels

Breckland

Tier 1: To maintain the ecological, landscape and archaeological value of heathland in Breckland.

Any areas of heathland are eligible to be entered into this tier. In addition to following the �all land� prescriptions (see

below), farmers must refrain from using fertiliser, lime or pesticides. They must also hard graze the sward; agree a

stock management programme to protect ground nesting birds; and control bracken and scrub.

Tier 2: To revert arable or improved grassland to heather or grass heath.

Any land which was managed as arable land or improved grassland in August 1992 may be entered. Priority is given

to land in close proximity to existing heaths and land which was in recent times heathland. In addition to the �all land�

prescriptions, farmers must begin the agreed programme of reversion within 12 months, and on completion follow

tier 1 prescriptions.

Tier 3: To maintain the ecological, landscape and archaeological value of river valley and spring line grassland.

Any river valley or spring line grassland may be entered. As well as �all land� prescriptions, farmers must not

physically disturb the grassland or apply any form of fertiliser other than farm-yard manure. They may graze the land

with livestock other than pigs or poultry but must not cut the sward before 1 July. They must also maintain existing

water levels in farm ditches.

Tier 4A: To introduce an uncropped wildlife strip to the edges of arable fields.

Any land in arable rotation since August 1992 may be entered. Farmers must cease arable production on a strip 6 or

12 metres wide, and cultivate this area only once a year or once every two years. They must not sow any grass or

crop, and should not use any form of fertiliser, fungicide, or herbicide.

Tier 4B: To introduce conservation headlands on the edges of cereal fields to support a variety of attractive plants without

seriously affecting the quality of the crop.

The edge of any arable field growing cereals may be entered. Crops may be grown on the area, but farmers must not

apply herbicides other than those named.

All land: To maintain the landscape, wildlife and historical features of Breckland.

Farmers must comply with a range of other prescriptions on any land they enter. These include maintaining hedges,

ponds and reedbeds, and not damaging any historical, archaeological or natural features. They must also obtain

written advice on building and engineering works and on the management of woodland and pine belts.

continued ...

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48

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

PROTECTING ENVIRONMENTALLY SENSITIVE AREAS

Tier structure, objectives and prescriptions for selected environmentally sensitive areas continued

Lake District

Tier 1: To maintain the landscape and wildlife interest of the Lake District, particularly areas of heather and other

semi-natural upland habitats, grasslands and characteristic stone walls.

Tier 1(all land) All land, including arable land, within the boundary of the environmentally sensitive area must be entered.

Prescriptions specify a wide range of management practices in relation to grazing, the control of bracken and rushes,

and the protection of natural features and traditional landscape elements such as walls, hedges and woodland.

Tier 1(inbye) Only enclosed grassland that has not been ploughed or reseeded for at least ten years, is used for pasture, hay or

silage production and is subject to regular inputs of fertiliser may be entered. In addition to the �all land�

prescriptions, farmers must not cultivate the ground or add lime or herbicides. Fertiliser use and harrowing is also

restricted.

Tier 1(intake) Only enclosed land used exclusively for grazing of which the majority is unimproved may be entered. Farmers must

not increase stocking levels.

Tier 1 (fell without

heather)

Land covered by semi-natural upland vegetation which is generally unenclosed may be entered. Farmers must not

use fertiliser, fungicide or herbicide other than to control noxious weeds. Prescriptions also specify a maximum

stocking level and the avoidance of over-grazing.

Tier 1 (heather fell) Any grazing unit where the area of heather is greater than 25 per cent may be entered. Prescriptions specify a

maximum stocking level and various other stock management measures to prevent over-grazing of the fell. The

farmer must also agree a programme of heather cutting or burning within two years of the start of the agreement.

Tier 2.1: (meadows) To increase the area and improve the quality of species-rich meadows.

Any meadow land may be entered. Prescriptions are designed to prevent meadow land being grazed or cut during the

period from May to July. Hay and silage must be removed and the aftermath grazed. Fertiliser is restricted to

farm-yard manure.

Tier 2.2: (pasture) To increase the area and improve the nature conservation quality of species-rich pasture.

Any pasture may be entered. There are restrictions on fertiliser use (only farm-yard manure may be used) and

stocking levels. Farmers must agree a grazing regime where pasture adjoins water.

Tier 2.3: (wetland) To increase the area and improve the nature conservation quality of wetland.

Any wetland may be entered. Farmers must not add fertilisers or lime or increase stocking levels. They must also

agree a grazing regime.

Tier 2.4: (heather fell) To increase the area and improve the quality of heather and associated semi-natural vegetation on the fell.

Heather fell or other fell land of exceptional conservation value may be entered. Prescriptions involve stringent

restrictions on stocking levels.

Cotswold Hills

Tier 1 : To maintain the landscape and wildlife interest of the Cotswold Hills, particularly the area of permanent grassland;

to increase the length of characteristic stockproof drystone walls and traditionally managed hedges; and to conserve

and protect the range of archaeological and historic features.

Tier 1 (all land) All land within the boundary of the environmentally sensitive area must be entered. Farmers must not increase the

existing area of arable land or applications of fertiliser. Prescriptions also specify a wide range of management

practices for the control of bracken and shrub, and the protection of natural features and traditional landscape

elements, such as walls, hedges and woodland. Farmers must not erect new fencing and must obtain written advice

on the management of historical features of importance or on any building or engineering works.

continued ...

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49

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD:

PROTECTING ENVIRONMENTALLY SENSITIVE AREAS

Tier structure, objectives and prescriptions for selected environmentally sensitive areas continued

Cotswold Hills continued

Tier 1B (improved

permanent grassland)

Only grassland which has not been ploughed or reseeded for at least 5 years but is receiving regular inputs of

fertiliser may be entered. Prescriptions restrict the use of herbicides, fungicides and insecticides. Farmers must not

level or reseed the land and the land must be grazed, but not by pigs or poultry.

Tier 1C (extensive

permanent grassland)

Only grassland which has not been ploughed or reseeded for at least 5 years and which is receiving no or only

minimal inputs of fertiliser or pesticides may be entered. However, grassland which has the potential to be managed

in this way may also be entered. Prescriptions enforce the requirement to graze the land (though not with pigs,

poultry or horses), and prevent the use of fertilisers except for farm-yard manure. In some areas, stocking densities

are also restricted.

Tier 2: To revert arable land to extensive permanent grassland for the benefit of wildlife and the landscape.

Land under arable cropping or in arable rotation may be entered. Prescriptions aim to re-establish a permanent grass

sward and oblige farmers to follow initially tier 1 (all land) prescriptions and thereafter tier 1B or tier 1C prescriptions.