Royal Commission on Environmental Pollution

COUNTRYSIDE MANAGEMENT FOR PEOPLE AND NATURE

1.   Agricultural intensification, encouraged by subsidy and permitted by technology, has broken the link assumed in the Scott Report of 1947 between 'producing food' and 'producing countryside'. For several decades, the overwhelmingly dominant theme of farming and its financial support systems has been production - output of agricultural produce. Environmental considerations have been neglected, resulting in significant adverse environmental effects. Farmers are no longer 'unconsciously the nation's landscape gardeners', as envisaged by the Scott Report.

2.   The Royal Commission on Environmental Pollution has commented on many environmental impacts of agriculture in its reports. Our Seventh Report, Agriculture and Pollution, raised many issues that have been acted on, and drew attention to other problems that are still with us. The Government has responded to a key recommendation in our 19th Report, Sustainable Use of Soil, by drawing up a Soil Strategy, an important initiative and we regret that it did not feature in the Consultation Paper.

3.   More recently, the Commission's Twenty-third Report, Environmental Planning (Cm 5459), published in March, included a chapter on Safeguarding Town, Country and Coast. It saw that:

'maintaining or enhancing urban and rural environments are among the priority objectives for environmental policy'

4.   It is our contention that the relationship between environmental protection and production must be revised. The substantial public subsidies have been allocated mainly on the basis that the principal activity in the countryside is agriculture, and the principal purpose of agriculture is food production. We believe there is no justification for continuing to give such primacy to production. Indeed, it is now evident that the countryside itself is an important factor in quality of life, employment and wealth creation for both the people who live there, and the people who visit it. Furthermore, the benefits of the countryside are diverse and derive from many different sources. Agriculture is only one such source, and no longer necessarily the most significant.

5.   Public policy on the countryside as a whole, and not just on agriculture, needs to be rethought. The starting point for such a reappraisal should be countryside's natural environment.

6.   The natural and semi-natural environment is central to the creation of employment and well-being both for those who live in the countryside and for those who come into contact with it. It is the single most important factor in tourism and recreation in country areas that are so characteristic of the British Isles. Indeed, it is a major reason why people want to live in the country. Natural processes in the countryside provide the most important of all resources for humans: potable water. In addition, the land of the countryside can produce not just food but also crops for energy and other non-food uses. Our Twenty-second Report, Energy - The Changing Climate, emphasized the potential of the countryside to assist in tackling climate change through the production of energy crops and through the use of land for wind farms.

7.   The crucially important functions of the country environment for humans always need to be considered together, because sometimes the provision of one function compromises, or even precludes, the provision of another. For example, the pollution of water sources from agricultural causes makes the provision of drinking water much more expensive. And large-scale intensive agriculture has in many places reduced both the landscape interest and the recreational opportunities that the countryside could offer.

8.   This multi-functionality of the countryside environment does not only apply to its provision of goods and services for humans. There are many other functions, where the environment is essential for self-sustaining natural systems. This is in turn at the heart of the environment's ability to continue providing functions for humans in the future. Therefore, environmental sustainability in the countryside entails countryside management that sustains diversity and resilience in ecological terms. Intensive agriculture is inconsistent with rich and diverse semi-natural ecosystems. Management of the countryside needs to sustain its ability to provide well-being, employment and wealth for those who visit it, live in it or run leisure amenities in it.

9.   Reconsideration of the nature of public policy support for the countryside, and subsidies for some of the activities which take place there, needs to proceed on the basis of three underlying principles which presuppose that receipt of public subsidy carries certain obligations:

• Such support should maintain or enhance the biodiversity and ecological integrity and essential functions of countryside habitats and ecosystems.
• Such support should have regard to the full range of possible activities in the countryside, and to the full range of possible crops, and uses of crops, from the land.
• Stewardship of the rural environment should not be regarded as the sole prerogative or responsibility of farmers, given the many other relevant interests, including those of town dwellers.

10.   The process through which these changes are accomplished must take account of the diversification in farm activities, and the profound changes occurring in the rural economy. Protection and enhancement of the rural environment must now be a more conscious affair, requiring both regulation and intelligent incentives, with the latter shifted from the production of food towards the positive environmental effects of particular land management practices. Regulation of agriculture (for example, pollution and planning controls) should be brought more into line with the controls on other sectors.

11.   Many of the activities in the countryside do not require direct public policy support or subsidy. But many of them will depend on the countryside being maintained in good heart, in terms of the beauty and wildlife, which encourage many people to visit and spend their money there, and the access that enables them to enjoy it. Increasingly, the food production aspects of agriculture will be less important than its role in the delivery of these broader aspects of the countryside environment. Some land may come out of agricultural production altogether; its environmental qualities will then need to be nurtured and sustained in other ways.

12.   While farmers cannot be considered the sole stewards of the rural environment, they are likely to continue to have the major role. In its report on Environmental Planning, the Commission concluded that:

'Farmers should maintain a basic level of environmental protection on the land they manage in return for receiving production subsidies under CAP, so long as production subsidies of various kinds remain part of the CAP. But, production subsidies should be phased out entirely as soon as possible. While agri-environment schemes can bring about valuable improvements, there is also a need for a strategic view of trends and the options for change.'

13.   We welcome the opportunity to respond to the government's consultation document. This response addresses ten key questions raised on which the Commission has already made recommendations in its recent reports.

RESPONSES TO INDIVIDUAL QUESTIONS

4.35   What additional measures (e.g. advice and guidance, incentive mechanisms, regulation, economic instruments) are needed to improve resource protection by agriculture ? How should these instruments be used together to achieve the scale of improvement to the environment needed, both in the short and long term ?

14.   Apart from initiatives covered in answers to subsequent questions, there are four others through which significant environmental improvements can be achieved. They are withdrawal of permitted development rights, effective application of the Environmental Impact Assessment Directive, encouragement of rural diversification and spatial planning.

Permitted development rights

15.   We argued above that the regulation of agriculture should be brought more into line with the controls on other sectors. Permitted development rights for agricultural works provide an example of the need for change. In our 23rd Report, Environmental Planning, we noted that even where activities of farmers (erecting buildings, creating new roads, excavating land) fall within the definition of 'development' they are subject to only limited coverage by town and country planning legislation. They are covered by 'permitted development rights' for agriculture. Over the years these have allowed thousands of large, essentially industrial buildings to appear in the open countryside without the community having any influence on their appearance or location. As we argued above, the wider community has a legitimate interest in such rural development and it is important that there are appropriate mechanisms for handling this.

16.   These permitted development rights have been reduced in recent years, in response to rising concern about the changing appearance of the countryside. In England new agricultural buildings over a certain height and/or within a certain distance of a road, dwelling or school now require planning permission. In National Parks and Areas of Outstanding Natural Beauty permitted development rights have been withdrawn. Elsewhere in England, local authorities can ask the Secretary of State to withdraw permitted development rights for farming and forestry if they believe there is a real and specific threat to the rural landscape.

17.   The Performance and Innovation Unit recommended withdrawal of these development rights in its report on rural economies, but this did not appear in the government's Rural White Paper. In our Report Environmental Planning, we recommended the withdrawal of such rights that currently apply to building conversions, and the construction of new buildings, roads and vehicle tracks when these activities are associated with agriculture or forestry.

Environmental Impact Assessment

18.   Another area where the regulation of agriculture needs to be brought more into line with the controls on other sectors is in the use of environmental impact assessment. The EC Environmental Impact Assessment (EIA) Directive is an important means for achieving resource protection. One of the provisions of EIA is that an assessment needs to be prepared before uncultivated land or semi-natural areas are converted to intensive agriculture, if this is likely to cause significant impact on the environmental. The new consent procedure for these areas will be an important backstop for preventing further loss of valued habitats and landscapes and other forms of environmental damage. DEFRA and the devolved administrations should ensure that the rural environment enjoys the best possible protection under the EIA Directive. In particular, they should not hesitate to refuse consent to schemes that would cause significant environmental damage, nor miss such schemes at the initial screening stage. Screening should be carried out by staff with appropriate environmental training using rigorous criteria. Local planning authorities should be added to the list of statutory consultees for environmental impact assessment of intensive agriculture.

19.   To ensure the success of the EIA scheme, effective publicity should be used to bring the regulations to the attention of every farmer, rural land owner and rural land manager. The government and the devolved administrations should publish an annual report on the operation of EIA in agriculture, which could be combined with reporting on the operation of the EIA schemes for forestry projects and types of development covered by the town and country planning system. The report should show the number of applications for initial screening, the number of projects for which an assessment has been required, the decisions on those projects, the findings from independent assessment of the screening process, monitoring, the number of breaches of the regulations and the number and outcome of prosecutions. This report should also give an overall assessment of the contribution the regulations are making to conserving semi-natural habitats and curbing environmental damage.

20.   It is essential that agricultural operations that can cause significant air, water and soil pollution are adequately regulated. The health of the natural environment is central to the countryside's ability to support a high quality of life. There should be a thorough review of controls on environmental impacts of agriculture, including measures for protecting the conservation value of the countryside and for controlling agricultural pollution. The specialist environmental agencies should co-operate to conduct an independent assessment of the efficacy of the new EIA regulations and the other measures mentioned above in five years' time. If this review indicates that the arrangements have failed to prevent further deterioration of the rural environment, then we would recommend extending town and country planning control to damaging agricultural operations for the reasons given above. Commensurate with this extended remit, there would need to be a major increase in resources and training for officers working for local planning authorities.

Rural diversification

21.   We have already emphasised that public policy on the countryside as a whole, and not just on agriculture, needs to be rethought. At the core of a revised approach must be an acknowledgement that the natural environment is at the heart of the countryside's ability to create wealth. There is general support for a more diverse rural economy in which tourism and leisure, on-farm food processing and retailing and other industries grow to help protect rural areas from economic decline. Diversification is increasingly being encouraged through advice and subsidy schemes such as the England Rural Development Plan, the proposed Rural Development Programme for Northern Ireland, the Rural Development Plan for Wales 2000-2006 and the Farm Business Development Scheme in Scotland. Welcome though these initiatives are, the multi-functionality of the countryside environment needs to be fully recognised and put at the heart of policy. The great majority of diversification projects are related to tourism or nearby urban economies rather than adding value to land based products or taking advantage of their rural locations in ways unrelated to tourism. Diversification must not be used as a pretext for approving inappropriate development, which could be environmentally damaging.

22.   The town and country planning system can influence the diversification process because some of the changes involve conversions of buildings, or construction of new buildings. The government has expressed concern that planning authorities may have prevented some well founded diversification projects from going ahead by refusing planning permission, and has made recent changes to Planning Policy Guidance on the Countryside and Transport to address this. In Scotland, new National Planning Policy Guidance on Rural Development was published in 1999 and is currently being reviewed for its effectiveness. Broadly, however, it seems that town and country planning controls have not been a major obstacle to diversification, although some farmers have complained that the process for dealing with planning applications is cumbersome. In our 23rd Report on Environmental Planning, we recommended that the impact of new planning guidance on rural diversification should be monitored for its effectiveness in protecting the environment and to ensure that it does not block beneficial diversification projects. Information should be collected on the rate at which diversification is proceeding in rural areas, the quantity and type of employment created and maintained, and the overall environmental impact of diversification, including its effect on travel patterns.

Integrated Spatial Strategies

23.   We have already noted that protection and enhancement of the rural environment must become a more conscious affair. Appropriate planning helps to achieve this. In our 23rd Report, Environmental Planning, we recommended comprehensive spatial planning. The environmental purpose of spatial planning can be defined as bringing about a spatial distribution of activities which will safeguard sustainability by protecting and enhancing the environment. To achieve its potential in that respect, it must be carried out at a strategic level, and cover all activities and policies which have significant spatial implications for the environment. Alongside economic and social objectives, it must take full account of all aspects of the environment, and the constraints they impose. In our report, we use the term 'integrated spatial strategy' to describe a spatial planning document which has those characteristics.

24.   Land use for agriculture is heavily influenced by European and national grant schemes and is increasingly being regulated to limit its impact on the environment, especially in the form of water pollution. With three-quarters of UK land being used for agriculture, it is essential that agricultural methods, policies and regulation should be considered at a strategic level and on a spatial basis alongside other relevant factors. In our report on Environmental Planning, we recommended that the use of land for agriculture, forestry and countryside recreation should be issues covered in all spatial planning in future. This should help to ensure that public policy on agriculture is seen as just one aspect, albeit an important one, of policy on the countryside as a whole.

25.   An Integrated Spatial Strategy should be the dominant plan in each area and be statutory. It would cover all uses of land and all other spatially related aspects of the environment, and incorporate appropriate contributions towards national environmental targets. Because town and country are interdependent, the area covered by an integrated spatial strategy would normally include both significant urban areas and significant rural areas. The plans should be four-dimensional, covering the atmosphere and underground aquifers as well as the land surface, and look at least 25 years ahead.

4.36   The Policy Commission put particular weight on the case for a new 'broad and shallow' agri-environmental scheme. What contribution might this be expected to play in reducing negative environmental impacts from farming ?

26.   It follows, from our conviction that the natural environment is central to the countryside's ability to create employment and wealth, that effective action needs to be taken to ensure this. In our 23rd Report, Environmental Planning, we concluded that farmers receiving production subsidies should be required to maintain a defined level of environmental protection on the land they manage, while such subsidies continue. In addition, there is a clear justification for the state to continue payments to rural land managers, including arable and livestock farmers, for achieving well-defined, measurable environmental and social objectives. Such support should maintain or enhance the biological and ecological integrity of countryside habitats and ecosystems. Support for owners and managers of rural land should be rationalised through the introduction of schemes that serve environmental and, where appropriate, other objectives.

27.   The Policy Commission saw its broad and shallow scheme as the right approach to achieving environmental improvements at a landscape scale, with lower payment rates and lesser prescriptions than existing agri-environment schemes. This new scheme would be targeted on paying farmers for positive management over and above their legal obligations and linked to production of a whole farm plan. We agree that such a scheme would be an effective way of extending such payments to a much wider range of farmers, with consequent benefits to the environment. We also support the introduction of farm plans, as we make clear below.

4.37   What contribution can food consumers and retailers make to encourage resource protection, for example through labelling ? How far are incentives needed to promote a stronger focus on the environment by consumers ? How can assurance best play a role in this area ?

28.   We agree with the implication of this question, that stewardship of the rural environment cannot solely be a matter for farmers. In our 21st Report Setting Environmental Standards, we commended food labelling schemes which, rather than publicising or selecting existing features of products or the ways in which they are produced, aim to use market power to bring about changes in methods of production. We welcome the emphasis which the Policy Commission has placed on such schemes. It is, however, critical that the schemes are effective and be seen to be so. Otherwise consumers get muddled and cynical about labelling.

29.   As our Report Environmental Standards made clear, people's values are central to their decisions on environmental matters. It is important to find means of articulating those values that are potentially relevant to the environmental dimension of people's food choices. Our Report described the various ways in which this can achieved. These included both conventional approaches such as public opinion surveys and newer methods including focus groups, citizens' juries, consensus conferences and deliberative polls.

4.42   What steps should be taken to ensure significant reform of CAP (particularly shifting resources from the CAP's first to second pillars) in the 2002/3 mid-term reviews?

30.   A reconstructed Common Agricultural Policy must recognise a healthy natural environment as fundamental and have regard to the full range of activities in the countryside, and the full range of crops including energy crops, which can be produced from the land. As we argued above, the relationship between production and environmental protection must be revised. In our 23rd Report, Environmental Planning, we recommended that production subsidies to agriculture should be phased out as soon as possible.

31.   Under the current CAP rules, countries can apply their own set of conditions, including environmental ones, to the payment of production subsides. We have heard no persuasive arguments against introducing such 'cross-compliance' and, in our view, recipients of public subsidy ought as a matter of principle to accept certain obligations. While they remain part of the CAP, we recommend that farmers receiving such subsidies should be required to maintain a defined level of environmental protection on the land they manage. We urge the government to take full advantage of the existing scope for cross-compliance under the CAP to support the protection and enhancement of the environment.

32.   Currently support schemes for the owners and managers of rural land have to be drawn up within the constraints imposed by European law. The government should press for changes to European law that will remove obstacles to a more unified and comprehensive approach.

33.   We also raised this issue in our 19th Report, Sustainable Use of Soil, where we argued that arable area payments should be conditional on compliance with guidelines or codes aimed at protecting soil. The government has effectively rejected this recommendation, claiming that practical environmental conditions had not yet been identified. Recent research has not identified any special standards in the EU but has found a cross-compliance standard in the USA requiring soil conservation plans on all farms with erosion-vulnerable soils. We urge the government to reconsider this issue.

4.43   Other than CAP reform and modulation, what other mechanisms could you suggest to deliver the land management benefits that society expects ?

34.   In our 22nd Report, Energy - The Changing Climate we stressed the crucial importance of strong measures to tackle the threat of climate change and the potential value of energy crops as a substitute for fossil fuels. The currently favoured crop under northern European conditions is willow grown as short rotation coppice. Techniques for cultivating energy crops have received little attention up to now, and it is reasonable to assume that yields could be increased considerably over the next few decades.

35.   For energy crops to be available as fuel, farmers and landowners have to be willing to devote land to their production in preference to other possible uses. They cannot readily be grown in the uplands because the ground conditions are unsuitable for mechanical harvesting, which normally takes place in winter. Short rotation coppice can be grown on arable land or grassland, or on reclaimed colliery spoil or sand and gravel workings. The general assumption has been that it would not be grown on land that could be used for food production. Under present conditions the areas most likely to be used are those withdrawn from food production under schemes to cut agricultural surpluses and less productive stretches of land within farm estates. Some imaginative small-scale schemes have been undertaken, and may have an important role in familiarising farmers with this relatively novel concept.

36.   Planting energy crops on a large scale would change both the appearance and the ecology of the countryside. While concern over this has been expressed, we believe it has been largely misplaced. Except in areas where the existing landscape is of high value, cultivation of short rotation coppice would not be visually intrusive, provided plantations are sensitively sited and designed. The impact on wildlife will depend on the type of land use being displaced and the vegetation in adjoining areas. Research by the Game Conservancy Trust indicates that it can benefit biodiversity through the creation of wildlife habitats in carefully designed plantations and headlands, where song birds and warblers are found in large numbers. Although there would be less diversity overall than in permanent woodlands or other species-rich habitats, short rotation coppice supports the highest number of invertebrates of all types of woodland. Concern has been expressed that the planting of monoculture energy crops may lead to a reduction in biodiversity, particularly on land formerly under set-aside. However, biodiversity may be enhanced if energy crops are grown in place of monoculture arable crops or pasture, with the additional benefit of providing wildlife corridors between woodland habitats. The impact of energy crops on biodiversity has not been a topic of significant research effort in the UK, partly due to the absence of large scale plantations.

37.   On previously arable land the result of planting energy crops is likely to be less soil erosion, smaller inputs of pesticides and herbicides, and less leaching of nitrate than on arable land. On what was previously grassland, these advantages would be less clear cut. Because they are faster growing, energy crops need more water than arable crops, and that could cause difficulty in the drier parts of the UK. This type of fuel has a large volume, so transporting it would require large numbers of vehicle movements, with associated fuel costs.

38.   Although we were satisfied that this type of scheme could be developed without undue environmental impacts (and indeed could increase biodiversity compared to the growing of arable crops), we recognise that increased commercial attractiveness could lead to environmental short-cuts. In our Energy Report, we recommended that in co-operation with representatives of the farming community and bodies such as English Nature (and their equivalents in Scotland and Wales) the government should produce a Code of Good Environmental Practice for small-scale biomass schemes. The Code (which might have regional variations) should be expressly linked to NFFO scheme or its successor by making compliance a condition of award. We welcome the £100m funding which the government has recently allocated to renewable energy schemes.

39.   Clearly, we recognise that there are a host of other measures available, some related to farming and some to the rural economy as a whole. These include integrated crop management, better use of pesticides, whole farm plans, and improved land use planning across the UK including rural areas, which have all been mentioned above. We believe that the key is promoting a shift away from the assumption that permeates through both policy and much of the rural culture, namely that the countryside is there just for farming in. Recognition that agriculture is no longer the most significant source of the economic and quality of life benefits, which the countryside can provide, is a vital first step.

4.44   What negative impacts do you consider might result from increasing the rate of modulation to 10%, from 2004 and how could they be mitigated ?

40.   We consider that the results of such a move would be almost entirely positive. In our 23rd Report, Environmental Planning, we recommended that production subsidies to agriculture should be phased out as soon as possible. We also argued that there is a clear justification for the state to continue payments to rural land managers, including arable and livestock farmers, for achieving well-defined, measurable environmental and social objectives.

4.52   What changes, if any, should we make to the objectives of the current agri-environment schemes ?

41.   The EU Rural Development Regulations allow agri-environment schemes to address a wider range of objectives, which include the 'promotion of ways of using agricultural land which are compatible with the protection and improvement of the environment, the landscape and its features, natural resources, the soil and genetic diversity'. Current UK agri-environment schemes, however, address a narrower range of objectives covering wildlife conservation, the protection of the historic environment, the maintenance and enhancement of landscape quality and improving public access. The objectives of these schemes should be broadened to cover all relevant aspects of the environment.

42.   The government, in its separate consultation on agri-environment schemes said that widening the scope of such schemes might spread resources more thinly. We do not consider this a valid objection to broadening their scope - removal of production subsidies should release the necessary funds.

4.65   Would a whole farm plan be a useful tool for land managers and regulators ? How should it be funded ? How should it tie in to a system of whole farm certification to ensure that farmers can seek a market reward for good practice ?

43.   There are now a plethora of grant schemes, production subsidies and voluntary and mandatory measures in the agricultural sector, with over-lapping objectives. The multi-functionality of the countryside, which we stressed earlier in our response, requires that a more integrated view should be taken. As we recommended in our 23rd Report, Environmental Planning, the support schemes can sensibly be rationalised by bringing together all their requirements in a single farm plan. The aims should be to obtain the maximum environmental benefit in return for the expenditure involved, reduce the bureaucratic burden on farmers and landowners, and achieve outcomes that are sensitive to the characteristics of particular areas and the views of the people who live in them. In future each agricultural holding in the UK receiving public subsidy should be required to prepare a farm plan containing actions to improve the environment which can be readily monitored. In order to simplify the existing arrangements, all bodies giving grants, exercising regulatory functions or requiring certification of environmental performance should accept the plan as meeting their requirements for information.

44.   The Commission's 19th Report, Sustainable Use of Soil, emphasised the importance of advice to farmers on pollution prevention, conservation and the sustainable use of soils. It recommended that at least the initial visit from advisers should be free. The first visit to explain the format, content and process for preparing the farm plan and its use in securing grants should likewise be free. If subsequent visits and assistance are required, the costs could be recouped against future grants and spread over several years.

45.   The Countryside Council for Wales already successfully operates the Tir Gofal scheme under which farmers enter into a ten-year agreement to implement a whole farm management plan for maintaining and enhancing areas of conservation and landscape value.

4.66   What should be covered by the whole farm plan ? Give the potential complexity of the project, what are the priority areas for implementation ?

46.   We would expect all plans to indicate the broad aims of farm management and state the measures to be adopted to conserve soil, minimise erosion and prevent pollution; indicate how any scheduled sites (for example, SSSIs, ancient monuments, limestone pavements, and access land) will be safeguarded. They should also cover any plans to convert uncultivated land and semi-natural habitats to intensive agriculture (in which case the farm plan could serve as the preliminary statement required under the new measures relating to environmental impact assessment). Should there be proposals to establish farm woodlands, or apply for membership of an agri-environment scheme, details would be given in the farm plan.

47.   Farm plans, despite their broad coverage, should not be voluminous. They must simplify, not complicate, life for farmers and landowners. They should indicate the limits within which the farm will be managed but leave the farmer as much flexibility as possible to operate within those limits. They will need to be updated at suitable intervals. To keep costs down, farm plans could be based on a standard template available electronically, for example via the Internet.

4.68   How could we overcome farmers' legitimate concerns about confidentiality ?

48.   We consider that many concerns on the commercial confidentiality of data held by public bodies are inappropriate and ill-founded. This is particularly true of much agricultural data held by these bodies. There are many different interest groups legitimately concerned with the condition of land used for agriculture and their views must all be taken into account in deciding what data should be made publicly available.

49.   Much publicly held data is not made publicly available for reasons of commercial confidentiality, but the fact that data apply to a commercial enterprise does not in itself justify withholding them. After all, applications under integrated pollution prevention and control (IPPC) are placed in the public domain. Prime examples of such withheld data are the reports which farmers submit to agriculture departments in order to win subsidy under the Common Agricultural Policy and agri-environment schemes. This information could give invaluable data on trends in land use at the local, regional and national levels, but is currently regarded as commercially confidential even though it relates to the distribution of public funds. To justify withholding a useful data set of this type, there must be some prospect of commercial interests being significantly injured by its release. Even where there is such a risk, this can often be minimised by removing key identifying data. In our 23rd Report, Environmental Planning, we urged the government and the devolved administrations to review all categories of data withheld on grounds on commercial confidentiality, to see which can be safely released. In particular, we recommend that agriculture departments place agricultural returns in the public domain.

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