Upland Reward Structure
May 2006
The National Gamekeepers’ Organisation (NGO) was pleased to be consulted by Defra officials working on the new Uplands Reward Structure.
For the record, the NGO was founded in 1997 and now has over 9,000 members. It represents the gamekeeping profession in England and Wales. Nearly all the gamekeepers working in upland areas of England are members. More details about the organisation can be found on our website: www.nationalgamekeepers.org.uk
Our Key Points:
Gamekeepers managing wildlife on estates in upland areas have a major role in conserving their open landscapes, rare habitats, and unique flora and fauna.
Defra’s consultation states (page 3) that, “Agricultural activity has largely shaped the upland landscapes that we value.” In fact, within large parts of the English uplands management for grouse shooting has played a vital role in retaining this World-scare resource.
English Nature and others recognize grouse moor management as being fundamental to the maintenance of the landscape and wildlife of the uplands. It is therefore vitally important that gamekeepers’ views are taken into account when planning a new upland rewards structure to replace the Hill Farm Allowance (HFA).
What is needed, as the Government’s consultation paper recognizes, is a scheme that delivers maximum public benefits in terms of landscape and wildlife whilst making best use of taxpayers’ money.
These twin objectives will be ensured by a reward scheme that encourages – in fact that requires – farmers in the LFA’s to farm in harmony with the environment and consequently with the sporting and conservation interests.
We make the distinction between ‘encouraging’ and ‘requiring’ because throughout the history of the HFA, whilst the scheme gradually improved towards encouraging the right things to be done, it very seldom required them, let alone enforced them.
This review must therefore end up delivering a reward structure that is fair to farmers, good value for the taxpayer and which cannot be circumvented to the detriment of the environment. There have been just too many examples in the past of unacceptable damage resulting from abuse of the rules.
Three Specific Issues:
- Heather Loss, Burning and Peat Loss
Section 2.18 of the consultation document flags up peat loss as being of concern and section 2.17 talks about the risk of uncontrolled fires that might result from land abandonment. These are important points. The conservation of peat is essential to the maintenance of the uplands and uncontrolled wildfires are indeed a menace. The best way to avoid them, however, is through regular heather burning conducted by appropriately qualified people in accordance with the best practices currently being established by the Heather Burning Review Group. Wildfires seldom occur on ground where gamekeepers keep the heather in good condition through a regular programme of burning. The new reward structure must encourage good burning and make land abandonment and bad burning practices things of the past. However, anything that makes good heather burning more difficult will be counter-productive.
- Enforcement
To quote from you consultation letter: “Defra’s objective has been to design a new reward structure for upland farmers that contributes to sustainable land management and the provision of public benefits.” Our point is: It won’t unless it is enforced.
Current and past schemes have all fallen down through lack of enforcement. For example, there is peat loss caused by serious localized overgrazing leading to erosion (eg around supplementary feed areas). That should not happen even under the existing HFA arrangements but it does, because the rules are not kept. They are so rarely enforced that some, even many, hill farmers regularly flout them.
The same point could be made in relation to illegal drainage, harrowing and rolling during nesting season and inappropriate use of machinery during the breeding season. All these things are currently going on and the damage they do to the wildlife and the landscape is not only against the law but against the public interest too. It does much to undermine the achievement of the good objectives of the HFA. We know, because our members see it happening on the ground. The replacement scheme must have proper enforcement or it too will fail to deliver.
- Heather Loss
There is still a loss of heather cover on some moorland through agricultural activity. Winter feed sites, big bale ring feeders, lime and farmyard manure application, rutting and the associated run off are all problems still seen on many moors despite the fact some of these sites are SSSI’s, SPA’s and SAC’s. The British Government has a legal obligation to protect the upland habitat under the EU Habitat Directive. This is an issue any future funding of hill farming must address.
Our Conclusions:
The National Gamekeepers’ Organisation believes that Option 1 in the consultation paper might work best in producing better habitat on the moorland fringe and even on the surrounding meadow and pastureland.
The big question is how tough the requirements for additional options within any new upland scheme might be. Or for that matter what the requirements for a specific Upland EL scheme might be if some of the other options were used instead.
One of the snags we can see with an income-forgone scheme is potential lack of take up. The income from existing livestock numbers is poor, therefore there is no real incentive to enter such a scheme.
There must be compulsion to manage the land within an ESA catchment exactly in accordance with the rules in order to get any payment. The land has been classified as being environmentally sensitive, so why should anyone be able to do with it what they wish, with all the probable downsides such as water pollution?
The bottom line is that ‘yes’, there needs to be some control on livestock numbers via environmental schemes, but for the sake of the wildlife there needs to be far, far more.