Dear Secretary of State,
Re: A new proposal for ELMs
Congratulations on the new job. This is a challenging moment for food and farming in our country and we need your leadership. I wanted to write to you and set out our proposals for a ‘third’ way on ELMs and to ask if we could meet to discuss them.
The current conversation feels extremely polarised. Whilst we and many farmers have continued to support the overall direction of the government’s plans to redesign support packages for UK agriculture over the last 4 years, in particular the principle of moving to a public money for public goods approach, it’s clear the current ELM proposals are not good enough. We therefore feel this moment of upset represents an important opportunity to step back, review progress, and assess whether there’s a better plan of action.
We strongly believe there is a ‘third’ way, which, if designed correctly, could help build food security and advance our environmental aims.
One of the most contentious points of discussion over the last few years has been over area-based payments – a conversation which has arisen again more recently with rumours suggesting Defra may revert back to this approach. Of course, in the early days we recognised the logic associated with the proposal to phase out Pillar I area-based payments, due mainly to the fact that current eligibility for such support requires little more than adherence to minimum environmental standards. However, one of our core concerns has always been that by taking this action, the ‘baby’ of area-based payments would be thrown out with the ‘bath water’ of the social security element of the existing scheme.
We believe the current proposal for ELM and its three pillars – the Sustainable Farming Incentive, Local Nature Recovery and Landscape Nature Recovery – is at risk of perpetuating the separation of food production from nature conservation. This is something which has been both a feature and a consequence of most of the existing stewardship schemes which currently lie under Pillar II, with the unintended consequence of confining nature conservation to the margins of otherwise intensively farmed land. While there are clearly some necessary and beneficial habitat protection measures which should find a place in this new farm support package, if they are not linked to whole farm adoption following the principle of ‘do no harm’, our concern is that the desired nature and decarbonisation targets for agriculture will not be realised.
We are also concerned about the possibility of significant areas of land being taken out of food production and given over entirely to nature conservation. Inevitably this would either result in further increases in intensification on the areas remaining in production, or increased imports of food from countries with lower environmental and public health standards. Our recent Feeding Britain from the Ground Up report found that current food security could be maintained if we transitioned UK agriculture to ‘regenerative’ systems – farming in harmony with nature and recycling nutrients naturally through rotations, thus reducing our reliance on external inputs. This model also included allocating some current agricultural land for nature restoration and woodland creation, but largely put farming at the heart of our future land management strategy.
ELMs – the third way
This would take the form of a whole farm support package, much of which would be based on land area, but with strong conditions attached. Such a scheme could include a number of options – some applicable on a field scale, some on a whole farm scale, and some more tailored to stewardship, which together would ensure a systemic, rather than piecemeal, adoption of more sustainable farming practices.
Such activities could include:
- Adopting/maintaining practices which build soil carbon, such as crop rotations with a soil fertility building phase, usually with clover/grass
- A reduction in the use of chemical inputs
- Farming practices which promote high agricultural and natural biodiversity
- High standards of animal welfare
- Increased employment and staff skills development
- A larger percentage of sales to local processing facilities and markets
These area-based payments would be linked to strong, measurable conditions. To monitor this and the impact of the scheme more generally, Defra should require all farmers to submit an annual sustainability assessment using a framework of common, harmonised metrics. This framework should focus on measuring outcomes, so that in time, farmers can be rewarded on this basis rather than for practices, allowing for greater flexibility on how best to deliver impact.
We have always felt that if designed in the right way, such a future support package has the potential to correct the economic distortions which currently exist within food and farming, therefore facilitating a nationwide transition towards production systems which are sustainable, profitable, climate friendly, biodiverse and produce high-quality food which maintains and promotes public health.
Yours sincerely,
