Organic
Aberystwyth
SY23 3AL
CF10 3NQ
21st July 2006
Dear Ms Harris
OCW response to the consultation on Strategy Environmental Assessment of the RURAL DEVELOPMENT PLAN FOR WALES 2007 – 2013 on behalf of the Organic Strategy Group.
Please find attached our brief response to the above consultation.
Yours sincerely
Susan Fowler
Policy Officer
Organic Centre
This brief response
focuses on some key issues involving organic farming, and does not attempt to
comment on the entire SEA.
Conflicting
objectives:
We are surprised
at the purported conflict between halting the loss of biodiversity and the
objectives to increase access and wellbeing of the population. The effect is more likely to be synergistic,
as increased access will usually enhance understanding and engagement with the
countryside, which is more likely to result in increased awareness of
biodiversity issues.
Environmental
baseline:
Biodiversity:
the impacts of agricultural systems should be considered. Most of the biodiversity of the countryside is
the heritage from agricultural systems; therefore farm management and farm type
will clearly impact on within field and field margin effects, not necessarily
negatively. Biodiversity should not be
regarded as starting at the farm gate or only existing on protected areas.
Table 2: SEA
Objectives and Indicators
An Indicator
relating to land under organic management would serve various themes:
Biodiversity; water; soil; animal welfare and climate factors.
We note the
indicator for human health and wellbeing relating to the percentage of organic
food produced; however, a more appropriate (although more complex) indicator may
be access to organic food.
Organic land
area is an accessible indicator, however, a more refined indicator relating to
the proportion of organic food consumed that is produced in the
As well as
access to forests and woodland, we would like indicators relating to school
visits to farms, and the number of open farms.
Table 7:
Generally,
we are concerned about the basis for the judgements of the impacts of the
Organic Farming Scheme, which seem somewhat arbitrary. Many studies exist on the impact of organic
farming, which could have served to inform the matrix, and there is expertise
at Organic Centre Wales that could have assisted in the production of this
table.
Biodiversity
For the
reasons given above (under baseline), Organic farming is likely to have a major
positive effect on halting the loss of biodiversity and promoting recovery and
meeting the targets of biodiversity and habitat action plans, and at least a
positive effect on protected species and their overall population.
Water
Due to the
non-use of soluble N & P fertilisers, organic farming will also have a
positive effect on water quality standards, particularly in Wales with the
majority of pastures being permanent, therefore reducing potential leaching
following ploughing.
Conserve
agricultural land:
We do not
see that there can be a sensible objective to reduce the use of organic manure,
since the use of organic manure, particularly if composted, helps build carbon
and organic matter in the soil, and reduces waste disposal. Organic farming clearly offers a major impact
on reducing the use of N fertiliser.
Air
As organic
farming severely restricts the use of pesticides, and is concerned to reduce N
losses from any means, the contribution to improved air quality must be
positive.
Contributions
to Climate Change
As organic
farming does not allow N fertilisers, which are such major contributors to the
energy use in agriculture, the impact of organic farming will be positive.
Adapt to
Climate Change
Studies have
demonstrated that water percolation and holding is higher on soils under
organic farming, and soils under organic management are less prone to drought,
therefore Organic farming is likely to have a positive impact on reducing flood
risk and the effects of drought.