Implementation of CAP reform in England

Joint approach from the Ramblers, the British Mountaineering Council, the Outdoor Industries Association, the Open Spaces Society and the Sport and Recreation Alliance

  1. Introduction

1.1 The Ramblers, the British Mountaineering Council (BMC), the Open Spaces Society (OSS), the Outdoor Industries Association (OIA) and the Sport and Recreation Alliance (SRA) welcome the opportunity to respond to this consultation. We are the leading organisations in England representing the interests of people who visit the countryside and green spaces for recreation and have a wealth of expertise and experience on access and recreation management.

1.2 England’s recreational access infrastructure – public rights of way, open access land and other green spaces - enable people to reconnect with nature, exercise, watch wildlife, revisit history or explore rural towns and villages.We recognise that recreational infrastructure comes at a cost to land managers. As such, there is a clear need to effectively support land managers to maintain and enhance recreational access, and to provide opportunities for business diversification around recreation and tourism.

1.3 We believe that the implementation of CAP reform provides an important opportunity to support improvements to recreational access infrastructure, and in so doing to deliver asignificant boost to rural growth and development – one of the primary objectives of reform – as well as deliver a range of benefits including improvements to public health, well-being and an increase in public understanding of and support for the environment and farming. These multiple benefits maximise value for taxpayers’ money and provide demonstrable evidence of public gain from subsidies for land management.

1.4 Increased public access to the countryside directly supports the Government’s ambition, set out in the Natural Choice: the Natural Environment White Paper, to reconnect people with the natural environment and that “everyone should have fair access to a good quality natural environment”.[1] Improved and increased access to the countryside for recreation will also many Government strategies and targets to improve health, well-being and encourage physical activity.

1.5 Access to the countryside and rural tourism is fundamental to the success of Government’s Rural Economy Growth Review. The UK Government’s own National Ecosystem Assessment, asserts that the social benefits of people being able to access and enjoy the countryside should be valued at £484 million per annum.[2]The Foot and Mouth Disease outbreak in 2001 revealed starkly the extent to which our countryside and farmland is used as a recreational amenity; the ‘closure’ of the countryside during the outbreak was estimated to have cost the rural economy and tourism industry £5 billion.[3]

1.6 Our responses to some of the individual questions are below.

2. Section 4 - Cross Compliance

Are there elements within any GAEC that you think should or could be changed, implemented better, or excluded? If so,why?

2.1 Currently, under GAEC 8, landowners in receipt of CAP funds are required as part of their agreement to keep all rights of way on their land holding in good condition and free from obstruction; this is also in keeping with their legal obligations. This requirement must be maintained and strengthened.

2.2 We know from experience that agri-environment funding is rarely, if ever, refused or withheld due to land owners not meeting their legal obligations in respect of rights of way. Whilst ‘cross compliance’ is potentially a useful tool to support the maintenance and accessibility of the existing rights of way network, its effectiveness is limited by the very small inspection sample size adopted by the Rural Payments Agency (RPA), the lack of a defined process for communication between the RPA and Highways Authorities (as the relevant enforcement bodies) and the fact that the RPA won't act on or accept a report about failure to keep paths free from obstructions from a member of the public (including those representing a national organisation).

2.3 For cross compliance to be more effective, more inspections are needed which take into account the condition of rights of way and the condition of other statutory access rights (Countryside and Rights of Way Act, Marine and Coastal Access, village greens etc.) as well as clear procedures for action by the RPA and local authorities.

3.Section 5 – Rural Development Programme

What lessons can be learned from the current RDP? How can we build upon its successes?

3.1 We welcome the intention of a more focused approach to delivery of the RDP and suggest that an attractive and equally balanced complement of measures is once again developed which includes public access. New schemes should be designed to avoid the shortcomings of previous schemes and ensure the public gets maximum value for money from subsidies.

3.2 Until 2010, permissive access was an option within the RDPE Environmental Stewardship, Higher Level Stewardship (HLS) scheme. Farmers and landowners could receive payments to provide permissive access over a ten year period. Between 2005 and 2012 grants to the value of £23 million have been paid for various types of permissive access (including 4,000 ha open access; 1,450km footpath; 1,250 km bridleway/cycle-path; 57km for people with reduced mobility).

3.3 Whilst the creation of permissive routes under HLS gave walkers and horse riders the opportunity of some new routes, the access options on offer were short-term and permissive access was not publicised sufficiently; schemes were not demand-led to provide opportunities where they were most needed (it was only provided where farmers volunteered it); few links were created to connect to open access land or National Trails; and the quality of routes created varied considerably, as did the level of use.

3.4 The permissive access option was funded by the UK Government (rather than co-funded with European funds) and was subject to cuts in the 2010 spending review. The scheme continued to pay existing agreement holders until their agreements come to an end but there is no longer an option to receive payment for new permissive access.

3.5 To maximise rural growth and help fulfill the focus identified under some or all of the 6 RDP priority areas, it is essential that tourism and recreation are considered as an integral part of the socio-economic benefits of CAP reform and money once more be allocated to help develop this.

3.6 Financial support should be made available for land managers and communities to both complement the statutory opportunities already available (exceeding any basic legal requirements) and, at the least, be available to help finance access capital items under the new environmental land management scheme to support the provision of access and/or to help support improvements to existing access.

Are there any key areas we have missed in our assessment of need to support the new Rural Development Programme? Are there any further sources of evidence of social, economic and environmental need in rural areas for England that have not been captured?

3.7 We are pleased to see the inclusion of Priority 6 (particularly points 6A and 6B) in Annex C and that this priority allows funding of measures which support the development of rural areas, including the provision of tourism infrastructure.

3.8 A major new independent study has concluded that spending CAP funds on improving access to attractive countryside, protecting wildlife and cutting greenhouse gases could produce annual benefits of over £18bn, for a loss of less than £0.5bn in UK agricultural production.[4]

3.9Economic activity relating to tourism is dependent on both the maintenance of high quality natural assets, and on the provision of means by which the public can access these assets. These include our public rights of way network, areas of open access land, National Parks, National Trails and other publicly accessible green space. For tourism to happen, we need both wonderful places to visit and the means to do so.

3.10A strong recreational / tourism / leisure based element of the new RDP is important because although local authorities have duties to protect, record and maintain public rights of way and the open access network, they don’t have a duty or the budgetary requirements to create new routes, make all the improvements that are required for a functioning, valuable network or identify and promote new recreational opportunities. We believe this could form an important aspect of the new RDP and be developed in conjunction with the LEPs and LEADER structure.

3.11Greater financial support could be provided to enable land managers to exceed their responsibilities under the current legislation governing access (through the public rights of way network, the Countryside and Rights of Way Act 2000 (CROW) and the Marine and Coastal Access Act 2009 (MCAA)). For example, by creating and maintaining outdoor access infrastructure, such as gates, bridges, and waymarkers, particularly where use by the public is high and encouraged.

Are the areas we outline for support under the new RDP set out above the right ones? How can we best target investment under the new RDP to help gain maximum value for money for UK taxpayers?

3.12There is no better way to meet the first priority for investment in the RDP – ‘delivering rural economic growth’ – than by supporting recreation and tourism. According to the Outdoor Industry Association, the ‘Outdoor Economy’ is worth 1.2% + of the UK’s GDP. The consultation document mentions that in 2000, UK habitats received 3.2 billion visits, generating over £10 billion. As mentioned previously, the Foot and Mouth Disease outbreak in 2001 revealed starkly the extent to which our countryside and farmland is used as a recreational amenity; the ‘closure’ of the countryside during the outbreak was estimated to have cost the rural economy and tourism industry £5 billion.[5]

3.13 It often takes only a small investment – a gate, path clearance or simply waymarking of a route – to make it attractive to visitors and so to increase visitor spend. There is good evidence that clear, easy to use, well-promoted path and trail networks influence more people to make day trips to an area or stay for longer periods – thereby increasing visitor spend. This directly supports vital local services and businesses such as shops, pubs, hotels, and bed and breakfast businesses. For example, Hadrian’s Wall path has brought in £19 million into the communities around it since it was created in 2003 and in 2010 £7.2 billion was spent visiting the countryside.[6] It is estimated that the whole South West Coast Path National Trail, running along 630 miles of the coast from Somerset's Minehead to Poole Harbour in Dorset is worth £307 million to the regional economy.[7]

3.14 Where there are benefits of joining up scheme expenditure with other interventions under Pillar 2 and across areas of support, in particular those aimed at delivering economic growth, these links should be made.

3.15 Support for recreation and tourism should be designed to ensure the public gets maximum value for money and long lasting economic benefits from public subsidies. This must include:

  • Directing funding towards areas where there is clear demand. National and local authorities have already identified strategic priorities for improving access through, for example, the development of Rights of Way Improvement Plans (ROWIPs) or Local Community Plans.
  • Investing in existing rights of way and open access network. This could provide more public benefit than providing new routes, particularly as budget cuts impact on existing access.
  • Favouring long-standing access agreements over temporary. This provides the best value for money; it provides clarity about where people can walk; spending on infrastructure such as gates is not wasted when the access agreement ends; access can be shown on OS maps; and the benefits to rural businesses can continue indefinitely. Access ‘taster periods’ could be created to allow landowners to become familiar with the requirements of access.
  • Directing payments to individual landowners for permanent improvements to the rights of way network, but also to public bodies and community groups as this would enable the creation of strategic routes which cover different land holdings. It is important to recognise that organisations / conservation bodies and land owners are also actively managing land for conservation and recreation benefit.

3.16 Improved access will not only boost rural growth and development, but has potential to bring an enormous range of benefits to public health, well-being and local communities.These benefits are increasingly well documented: Physical inactivity currently costs the NHS in England between £1billion and £1.8billion a year. Costs to the wider economy are conservatively estimated at £5.5billion in sickness absence and £1billion in premature deaths – a total of£8.3billion.[8]

3.17 Better opportunities for recreation and visiting rural areas will also have the benefit of increasing public understanding of and support for the environment and farming. These multiple benefits maximise value for taxpayers’ money and provide demonstrable evidence of public gain from subsidies for land management.

3.18 Annual and capital works payments for access can target network improvements and lead to permanent access where land owners / managers may have had initial concerns.

3.19 In order to best target investment under the new RDP, there is a need for improved promotion of access opportunities through the relationship with Local Access Forums (LAFs), Local Nature Partnerships (LNPs, Local Action Groups (through LEADER) and Local Enterprise Partnerships (LEPs).

3.20 The merger of the English Woodland Grant Scheme with the Environmental Stewardship is also cause for concern as it risks diluting measures which increase access. The Independent Panel on Forestry recommended that the RDPE should continue to include grant schemes such as the EWGS which incentivise woodland expansion and management and other outcomes which are “good for people, nature and the economy”. There is no evidence, however, that access to woodland will be promoted through the new grant structure.

How might we make the process for applying for Rural Development funding simpler or less bureaucratic? How might this be balanced against the need to ensure clear accountability for public funds?

3.21 We support a simpler process for applying for RDP funding but it is essential that this does not translate into a reduction in the quality or deliverables of the schemes themselves. In order to ensure the process of applying for and balance of using public funding is less bureaucratic and fair, more organisations should be involved in the decision making through the LEADER process. Currently it is difficult for organisations like ours to engage with the work of LEPs.

What are your views on the structure of the proposed new environmental land management scheme, in particular the new “landscape scale” approach?

3.22 We agree that a landscape scale, coordinated approach would help to maximise opportunities to achieve multiple benefits from CAP spending. We believe that it should be possible for a group of landowners or a community to apply for funding to support improvements to recreational infrastructure which takes in different land holdings, as this would enable the delivery of strategic routes.

3.23 It is important that site-specific arrangements don’t simply focus on designated sites (such as SSSIs). Other ecological networks with important key species as well as those areas of high recreational value often lie outside of these designated areas.

Should we offer a capital only grant as part of the proposed new environmental land management scheme?

3.24We believe that a grant scheme should be developed to support the provision of access or to help support improvements to existing access. Capital items such as stiles, way markers and gates could help support improved recreational as well as environmental objectives and taken together across a broad area could be used to link up areas of open access, national trails and public green spaces.

3.25Grant funding should favour investments in the existing rights of way and open access network. Priority should be given to improvements to recreational infrastructure which meet local demand, as demonstrated by support in strategic plans such as ROWIPs or Local Community Plans.

3.26By adding value to the site specific and area specific agreements will ensure that gaps in public services can be plugged. For instance, currently the extent and quality of public access opportunities is patchy. Good quality access exists in some areas but in others the recreational infrastructure is fragmented, in poor condition or access is not signposted. The last national survey on the condition of public rights of way was undertaken in 2000 and revealed that on average users were likely to come across a serious obstruction every 2 kilometres.

3.27 Similarly, no official assessment of the extent to which rights of way provide adequate access to land which is open for recreation under the CROW Act 2000 has been conducted. However, we know anecdotally that there is a need for additional paths to enable the public to reach areas which are currently difficult or impossible to reach. Small capital grants could be used to help improve the existing network and compliment the targeted approach by other farmers under NELMS.

Do you agree with the principle that five year agreements should be the norm under the new environmental land management scheme? What approach should we take to targeting the new environmental land management scheme?

3.28In order to ensure the longevity of the scheme and the successful delivery of public benefits, we believe that 5 years is too short a time frame. In particular, it is our experience that short term permissive access rights do not work.

3.29There is good evidence that clear, easy to use, long standing, well-promoted path and trail networks influence more people to make day trips to an area or stay for longer periods – thereby increasing visitor spend. This directly supports vital local services and businesses such as shops, pubs, hotels, and bed and breakfast businesses.