Capítulo III: SUCESIÓN TESTADA 172 Concepto.
LOS ALBACEAS O EJECUTORES TESTAMENTARIOS
A nation which maintains and enhances a biodiverse natural environment with healthy functioning ecosystems that support social, economic and ecological resilience and the capacity to adapt to change (for example, climate change).
Criterion:
• BPS helps maintain and enhance a biodiverse natural environment with healthy functioning ecosystems
Summary assessment
C.34 There is a lack of evidence to suggest the BPS is structurally adequate to deliver a more resilient Wales. It has no functioning mechanisms for directing support at specific interventions, or incentivising management to enhance all types of resilience, in particular environmental resilience. This assessment confirms that the BPS does not adequately support the biodiversity improvements sought in the well-being objectives set out above.
Future policy
C.35 Any new scheme therefore needs more effective mechanisms for delivering positive environmental outcomes. The SLM framework has identified the key environmental outcomes needed
136 | Sustainable Farming and our Land
for a resilient Wales, which farming can deliver. By linking support to these outcomes, the proposed Sustainable Farming Scheme would directly target environmental outcomes. Moreover, by making this support conditional on implementation of actions, the scheme can ensure positive management is taking place.
Background
C36 The overall resilience of Wales’ ecosystems and natural resources is under significant challenge from a variety of factors. The State of Natural Resources Report (SoNaRR) concluded:
All ecosystems have problems with one or more
attributes of resilience. This means that their capacity to provide ecosystem services and benefits may be at risk. No ecosystem, on the basis of our assessment, can be said to have all the features needed for resilience.81
Criterion: BPS helps maintain and enhance a biodiverse natural environment with healthy functioning ecosystems
C.37 The BPS payment itself is in not targeted at environmental performance. In their impact assessment of CAP to 2020, the European Commission states that:
The way entitlements have been allocated when decoupling was put in place did not envisage a specific targeting e.g. to farms that operate in more environmentally valuable areas.82
C.38 Other mechanisms of the BPS aim to encourage a level of environmental performance. However, these mechanisms have been assessed as inadequate by the European Court of Auditors.
81 Natural Resources Wales (2016), State of Natural Resources Report
https://naturalresources.wales/evidence-and-data/research-and-reports/the-state-of-natural-resources-report-assessment-of-the-sustainable- management-of-natural-resources/?lang=en
82 European Commission (2019). CAP towards 2020 Impact Assessment
https://ec.europa.eu/agriculture/policy-perspectives/impact-assessment/cap-towards-2020_en
83 European Court of Auditors (2017), Greening, a more complex income support scheme, not yet environmentally effective
https://www.eca.europa.eu/en/Pages/DocItem.aspx?did=44179
C.39 Cross Compliance is a mechanism the BPS uses to ensure minimum environmental standards are met. These are only minimum standards. The European Commission introduced Greening as a way to make up for the shortcomings of Cross Compliance.
C.40 However, the effectiveness of Greening has been called into question by the European Court of Auditors. Their assessment of Greening found: • There was a lack of robust intervention logic for
the green payment.
• Greening was unlikely to provide significant benefits for the climate and environment; it only led to changes on around 5% of EU farmland. • The likely results of the policy do not justify the
significant complexity added to the CAP.83
A Healthier Wales:
A society in which people’s physical and mental well-being is maximised and in which choices and behaviours that benefit future health are understood.
Criteria:
• BPS supports farmer's physical and mental well- being
• BPS supports the physical and mental well-being of society
Summary assessment
C.41 There is insufficient evidence to suggest the BPS provides mechanisms to directly address some of our society’s most pressing health challenges including cleaning our air, cleaning our water and
Sustainable Farming and our Land | 137 providing opportunities for physical recreation.
Management of water is included in the well-being objectives set out above. Clean water is fundamental to people’s health and is a key component of
biodiversity in aquatic environments. Future policy
C.42 We believe farm support should promote the management of land in a way which will contribute to creating a healthier Wales. The SLM framework specifically identifies public health, including the farmer’s health, as an outcome, principally leading to the well-being benefit. The definition of this outcome includes mental and physical health. The framework thus promotes a healthier Wales, and identifies how farming can contribute through managing air and water quality, or providing opportunities for outdoor recreation.
Background
C.43 Agricultural processes have the capability to negatively affect physical health through the emission of pollutants such as ammonia or nitrous oxides.
C.44 One of the ways farmers support physical and mental well-being of society is through their maintenance of the countryside and Rights of Way, over two thirds of which is located on agricultural land. The Welsh countryside provides space for physical activity which contributes to mental well- being.
C.45 As well as general societal health, the mental and physical health of farmers is also important. Farming has some of the highest incidents of
84 National Atmospheric Emissions Inventory, Ammonia emissions from agriculture
http://naei.beis.gov.uk/reports/reports?section_id=2
85 See above, ’A Resilient Wales’ and: Welsh Government(2019) Agriculture in Wales; European Commission (2019), CAP towards 2020 Impact
Assessment; National Atmospheric Emissions Inventory; European Court of Auditors (2017). Greening, a more complex income support scheme, not yet environmentally effective
Agriculture in Wales - https://gov.wales/agriculture-wales
European Commission - https://www.eca.europa.eu/en/Pages/DocItem.aspx?did=44179
National Atmospheric Emissions Inventory - http://naei.beis.gov.uk/reports/reports?section_id=2
European Court of Auditors - https://www.eca.europa.eu/en/Pages/DocItem.aspx?did=44179
loneliness and suicide. The effect of payments schemes on the farmers themselves must also be considered.
Criterion: BPS supports farmer's physical and mental well-being
C.46 Historically, direct payments have been an important source of funding to farm businesses, contributing to their financial viability. This has been the case for the BPS in Wales. Providing this support may help alleviate stress in the farming population, as it can lessen anxiety associated with the risk of financial failure. This is particularly important for mental well-being. It is possible the decision in Wales to adopt a redistributive approach to the BPS has helped in this regard (relevant statistics are set out below in the background section of A More Equal Wales).
Criterion: BPS supports the physical and mental well-being of society
C.47 The maintenance of Rights of Way is mandated by regulation not related to the BPS. However there are no provisions in the BPS for enhancing or changing Rights of Way to increase their value to the public.
C.48 Pollution from agriculture has the potential to severely impact physical health. Ammonia emissions from the sector have not seen significant reductions from 2005.84 The few protections to the environment from Cross Compliance and Greening, as previously discussed, are not effective.85
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A More Equal Wales:
A society that enables people to fulfil their potential no matter what their background or circumstances (including their socio-economic background and circumstances)
Criterion:
• BPS promotes a more equal farming sector Summary assessment
C.49 Income support has historically been based on entitlement rather than need. While this is due to cease when the change to universal area-based payments is complete, there will still be no link between the level of support and the need, effort or performance of a farmer.
Future policy
C.50 The distribution of funding in any new scheme should be accessible fairly and should link levels of payment to farmers' efforts on the ground, promoting a more equal Wales. The SLM framework offers a structure to base such support on. Using the framework should ensure the proposed scheme is accessible to all types of farm and money is spent on supporting those who are delivering specific economic, environmental and social outcomes. Background
C.51 Across the whole EU, the smallest 80% of farms in receipt of the BPS receive 20% of the total payments, while the largest 0.5% of farms receive 16% of the total payments.86 In Wales, the Redistributive payments mechanism means the effect is less pronounced: 84% of claimants received 56% of total payments, while the top 3% of claimants received 16% of the total.87
86 European Commission (2019). CAP towards 2020 Impact Assessment
https://www.eca.europa.eu/en/Pages/DocItem.aspx?did=44179
87 Welsh Government (2019), Agriculture in Wales
https://gov.wales/agriculture-wales
88 European Commission (2019). CAP towards 2020 Impact Assessment
https://www.eca.europa.eu/en/Pages/DocItem.aspx?did=44179
Criterion: BPS promotes a more equal farming sector
C.52 The distribution of payments is not linked to the efforts of a farmer, their financial or business needs, or their environmental performance. It is solely linked to the size of the eligible area which they have entitlements for. In some circumstances this may mean the BPS is promoting structural inequality by providing the most financial support to those who need it the least.
C.53 The European Commission summarises potential problems with this system:
The high level of aid received by some beneficiaries (despite the modulation mechanism introduced in the 2003 reform) is seen as too high to be justified as income support as it can be reasonably assumed that large farms benefit from economies of scale and therefore their income support needs may not be proportional to the farm size. At the same time, small farmers who can make a very important
contribution to the vitality of many rural areas and may have higher needs for income support often face a disproportionately high administrative burden for access to support in relation to the payment amount they receive.88
C.54 The conclusions of the European Commission are just as applicable to Wales as to the EU as a whole. Agriculture in Wales provides a detailed breakdown of distribution of the BPS, and while the trends are not as pronounced as they are for the EU as a whole, they do exist.