Our views on the farming policy consultation

John Bridges

Please feel free to use any of these points in your own consultation response. The Wildlife Trusts will be commenting in detail on the changes proposed in the draft review of the Agri Command Paper.

This government consultation will help drive the decision on where public money, in the form of payments to farmers and land managers, will be spent in the future. It will also help to establish how the rules and standards for land management should be set and enforced. Overall, we welcome the direction of travel in the consultation on paying farmers and land managers for delivering the benefits they can’t sell but that society needs – also called ‘public money for public goods’. We will outline three key areas which have fundamental implications for the health of our wildlife and wild places, and in doing so highlight three topic areas we think the government should consider.

  1. Reward farmers and land managers for the benefits they provide for society, like clean water, healthy soils and a wildlife-rich countryside
  2. Replace the Common Agricultural Policy with a system that supports public benefits and environmental outcomes for society
  3. Make it easier for farmers to help nature through changing the culture of regulation, including through better use of technology to identify where farmers and land managers are following the rules (which would free up more time for delivery)

(1) Reward farmers and land managers for the benefits they provide for society
Farmers and land managers should be paid to provide public goods, public benefits or outcomes:

1. More, bigger and better natural habitats
2. Thriving wildlife everywhere
3. Abundant pollinators
4. Healthy soils
5.Clean water
6. Clean air and climate change mitigation
7. Flood risk management
8. Healthy people (achieved via access)

Currently, the consultation document doesn’t mention habitat maintenance, connectivity, and expansion; without including this, the government’s stated ambitions for nature’s recovery will not be achieved.

Managing land in a way that benefits nature often gives many amazing outcomes at once; a well-managed, wildlife friendly farm with rich, fertile soils will naturally support more wildlife species, store water more readily and for longer, and help mitigate against climate change. Ranking or separating them, as the consultation paper requests, is unhelpful.

The consultation also fails to mention targets for these areas. Without targets, it will not be possible to know how we are performing, where we can improve, or where to target funding. Public payments for land management should be targeted and allocated at a local level through local environment network plans. These use ecological mapping (a spatial approach to identify societal and environmental needs) to help target resources and investment in land management, having the greatest impact and value for money.

The consultation document says little about the advice that will need to ensure the success of the scheme. Managing land for wildlife can be complicated, and farmers who have access to expertise do better than those who do not. The government needs to recognise the importance of this specialist advice in caring for the environment.

(2) Transitioning away from the Common Agricultural Policy
The consultation document proposes to phase out Direct Payments. These make up over 80% of payments to farmers and are linked to the area of land that is owned or looked after. The Wildlife Trusts collectively receive considerable sums through Direct Payments, but we believe that it is the right thing to move to a system based on rewarding farmers and land managers for the public benefits and environmental outcomes.

This is not without risk. The government must ensure that the transition dovetails with a new environmental land management system, to ensure that there is no ‘cliff edge’ in terms of environmental protection and land management in the interim.

(3) Changing the culture of regulation
It should be easy for farmers and land managers to help nature, without being weighed down by unnecessary bureaucracy and paperwork. Fewer inspections and the better use of technology to identify whether rules are being met (e.g. through remote sensing) could bring environmental benefits, with more time being freed up for landowners to do what they are best at.

However, there are risks. Currently, to receive direct payments, farmers must comply with certain minimum environmental (and animal health and welfare) rules – called cross compliance.

First, under the new system, the incentive to comply will be reduced because there is no threat of fines and/or a withdrawal of payment. This makes the enforcement of the rules even more important. Secondly, there is a risk that certain laws and rules fall between the cracks, as they are not part of domestic legislation. Boundary features like hedges are one such risk – their maintenance is currently part of cross-compliance, bring a range of benefits for wildlife through connecting habitats and providing nesting sites.