Following the UK’s exit from the European Union, the UK governments have each been developing new programmes to replace the Common Agricultural Policy and systems for agri-environment subsidy. This has been heralded as a once in a generation opportunity to improve how we support environmental public goods and deliver sustainable land management across the UK.
CIfA has serious concerns with the current proposals for the new Welsh scheme, which threatens to omit culture and heritage entirely, effectively undoing more than 20 years of positive conservation of archaeological heritage, traditional farm buildings, and landscape features within agri-environment programmes.
Agri-environment schemes are a crucial protection for the historic environment. Over 80% of archaeological heritage assets in Wales are located on agricultural land and the vast majority of these have no statutory protection.
Agri-environment programmes have had a tremendous positive effect on Wales’ rural historic environment. For example, under the previous scheme, Glastir, over 20% of Wales’ scheduled monuments were in active management as part of agri-environment schemes.
What does the consultation say?
The consultation recognises the “cultural importance of landscapes and archaeological or historical features” but does not include heritage assets, archaeology or landscape features among lists of environmental public goods which are to be supported by the proposed Sustainable Farming Scheme.
The impact assessment that accompanies the white paper confirms that “proposals for the future scheme do not specifically target culture and heritage”.
The current white paper consultation is the third public consultation on this subject, but this is the first indication that the historic environment has been excluded from schemes for the first time.
We are also concerned about the approach that the consultation outlines for management of ‘cross-compliance’. At present, heritage assets are subject to rules governing expectations for protections which must be assured for landscape features such as stone walls and archaeological features (GAEC 7). These would be reduced under the proposals.
We are asking Government to reconsider its intention not to include the historic environment within the sustainable farming scheme. We would like Members of the Senedd to raise these concerns with Ministers in future Senedd debates around the Agriculture (Wales) Bill, which is expected to be published later this year.
- The historic environment is an integral part of the Welsh landscape, which provides the backdrop to our farming and forestry industries, drives tourism and underpins the character of our places and community identity. Conserving and enhancing culture, heritage, and the landscape is beneficial both now and for future generations.
- Farmers and other land managers are stewards of the landscape. The new Sustainable Farming Scheme (SFS) should recognise that efforts to improve landscape features including stone walls and archaeological features are environment public goods and should be able to be subsidised under the scheme.
- Cultural heritage is in as precarious a position as other parts of the environment and requires similar protection from market failures as other environmental issues.
- Over 90% of archaeological sites are undesignated and are therefore afforded no statutory protections, with many sites being ‘at risk’ from potentially harmful agricultural or forestry practices, or subject to degradation, erosion, or other issues due to a lack of maintenance.
- The historic environment has been part of agri-environment protections for the rural environment since 1999. Not including it in the new scheme would be a hugely damaging retrograde step, removing one of the most effective means of managing threats to the rural historic environment, which accounts for more than 80% of heritage features in Wales.
- Historic environment protections do not prevent any other environment benefits from being sought. The proportion of funding that cultural heritage has received under previous schemes has been low compared with other elements.
- Tir Gofal & Glastir are broadly perceived to have been successful at raising awareness about the historic environment among land managers and can be credited with improving the condition of archaeological and landscape features.
- Under the previous scheme, Glastir, over 20% of Wales’ scheduled monuments were in active management as part of agri-environment schemes.
- If the Sustainable Farming Scheme does not include the historic environment hundreds of archaeological sites would likely fall out of active management and we would lose the ability to assess management needs in new schemes.
- As such, we believe that the SFS fails to reflect the ambition of the Well Being of Future Generations (WBFG) Act, which recognises a sustainable development principle which is about social, cultural, environmental and economic wellbeing, driven by the five ways of working which include ‘integration’ and ‘collaboration’ to take advantage of opportunities to improve wellbeing across all four areas.
- Existing cross compliance measures for landscape features must also not be weakened. Proposals in the document would effectively diminish cross-compliance minimum standards for all but nationally designated heritage assets, meaning that there would be no protection for undesignated archaeological sites or features.
How to write to your Member of the Senedd
You can find out how to contact your representative in the Senedd here: https://business.senedd.wales/mgFindMember.aspx
There are excellent guides containing tips of how to write to your elected representatives from the Council for British Archaeology and Rescue: The British Trust for Archaeology. Note: These guides are not specific to contacting the Welsh Parliament.