Written Evidence submitted by The Game & Wildlife Conservation Trust (FS0055)response to EFRA committee inquiry on Food Security

The Game & Wildlife Conservation Trust(www.gwct.org.uk) is a leading, independent UK wildlife conservation charity conducting scientific research into Britain’s game and wildlife to enhance the British countryside for public benefit.  We use our research to provide training and advice on how best to improve the biodiversity of the British countryside.  We employ 22 post-doctoral scientists and 50 other research staff with expertise in areas such as birds, insects, mammals, farming and farmland ecology, fish and statistics. The GWCT’s Allerton Project, our demonstration farm in Leicestershire, undertakes research into the effects of different farming methods on wildlife and the environment, and shares the results of this research through educational activities for practitioners and the public (https://www.allertontrust.org.uk ).     


We have chosen to respond in a ‘holistic’ manner to the inquiry questions and in that regard see the introduction of a Land Use Strategy as a key component in the future of domestic food production and overall food security.  We begin by setting the scene (essentially addressing the short-term pressures identified in Qs 1-3) before discussing our thoughts on the direction policy should be taking (in consideration of Qs 4-6).

Whilst the political focus at the moment is on the cost-of-living crisis what is being missed is that this will only intensify if our domestic food security is undermined.  This is why in the long-term agriculture policy needs to balance ambitions for food production with short term market impacts. In 2022 higher input prices in some of the combinable crops sector will have been cushioned to some extent due to forward buying and increased commodity prices e.g. wheat.  This is unlikely to be the case for 2023.  Based on current input prices, farmers are likely to cut back on inputs to protect margins resulting in lower yields (although this will also relate to other factors such as quality of land, previous cropping etc).  Livestock farmers are facing similar problems; they require nitrogen fertiliser to produce forage for their animals and given their lower volumes they tend to spot buy rather than forward buy.  They are also facing significant feed cost increases as higher commodity prices pass down through the supply chain.  The drought this year will also have exacerbated these two impacts with many farmers already having depleted their forage stocks.  This is causing significant pressure on margins, especially in the dairy, poultry and pig sectors.

Added to this is the impact of reduced access to skilled migrant labour. This has resulted in some 20% of the national pig herd being lost as the sector contracts due to chronic labour shortages, paired with cost increases. Horticultural production in the UK is set to shrink by some 25% this year, as growers decline to plant loss-making crops, coupled with the departure of the Ukrainian workforce and competition from imports produced under looser environmental regimes facilitated by recent trade deals. Despite the extension of SAWs this sector is estimated to be at least 30,000 short in workforce numbers resulting in c£60m of soft fruit ploughed in in 2022 alone.

The higher cost of energy is also severely impacting those sectors with a high requirement, such as housed poultry and indoor horticulture.

These challenges come at a time when the industry is also facing uncertainty relating to the Agricultural Transition to the Environmental Land Management SchemeIn addition, rents continue to rise despite Defra predictions that they would drop with BPS reductions.

Policies which support food production are almost entirely absent. Whilst SFI has some good elements, such as the focus on soil health, and the productivity grants are welcome (but at only 40% still leave many farmers in the cold) there is very little to actively support farmers in the production of food in a global marketplace at current payment rates. In addition, at this point there is no clarity on what the final shape of ELM will be in totalityWhat we do know is that the ‘ringfenced’ CAP monies will have to stretch further than ever before, with much of the money going to non-farming entities for non-food production means.

Multiple models demonstrate the inadequacy of supporting payments, especially with agricultural input inflation running at 30%.  As a result, farmers will be considering whether to de-risk their businesses by seeking to diversify their income (thereby effectively removing the uncertainties of food production) through taking advantage of the monies available through offsetting (be that carbon or biodiversity) and alternative energy sources such as solar and bioenergyThis decision-making process is already being seen in statistics which show significant areas of land are being taken out of production (often put into Countryside Stewardship), lower numbers of livestock taken forward, and a focus on lower-risk, lower yielding crops such as feed and spring wheats over milling wheats (which require a higher nitrogen input to achieve the necessary protein level for bread making)

Against this background it is vital that long-term ambitions for improving sustainability are not compromised; however clearly short-term measures are needed too.  Whilst the perfect storm of impacts that we are experiencing could not have been anticipated, the single focus initiatives that have dominated policy approaches for the last 50 or so years have resulted in the maximisation of outputs from our land rather than their optimisation.  The first phase of this was post the second world war when the focus was on food production.  This resulted in the unintended consequences of over-reliance on inorganic fertilisers and pesticides and the consequent impacts of biodiversity which are now widely documented and evidenced.  However, this has arguably resulted in the second phase which is the focus on the environment and the extensification of management.  What is needed is a balance between the two – and a balance with the various other demands on our land such as housing, energy (biofuels/solar), transport, warehousing etc.  A Land Use Strategy needs to encompass all these elements – as is being discussed in the House of Lords committee on this - to ensure that short-term fluctuations driven by the market are considered against long-term trends in land use and policy ambitions.  We were therefore delighted by Lord Benyon’s response on 20th September to a question in the House of Lords (UIN HL2273) which confirmed that this is the approach being taken - “We are seeking to deliver as much as we can on our limited supply of land, to meet the whole range of Government commitments on food, housing, climate, and the environment. To help achieve this, we will publish a Land Use Framework in 2023 which will set out land-use change principles to balance these outcomes.”


In addition to a Land Use Strategy there needs to be clearer policy direction on our strategy for food security and self-sufficiency.  Food production is one part of the food security equation.  The 2021 Food Security Review stated that “the UK is around 75% self-sufficient in foodstuffs that can be produced domestically…” and “About 54% of food on plates is produced in the UK, including the majority of grains, meat, dairy, and eggs.”  Earlier this year Government acknowledged that food security is a public good (UK Food Security debate 26th April 2022).  But with more land likely to be taken out of production or put into more extensive production to support biodiversity and area-based conservation ambitions, a distinction needs to be made between domestic self-sufficiency and food security otherwise our ability to continue our current levels of self-sufficiency will become an increasing challenge in the face of global supply or input price shocks

Consequently we are concerned that the Food Strategy did not specify the targeted level of domestic food production desired (only a commitment to keep self-sufficiency at “broadly the same level in the future”), despite referring to the need to support domestic food production and to reduce off-shoring our environmental footprint. 

Policy emphasis remains on our position within a global food system.  But how sensible is this?  The recent FTAs with Australia and New Zealand have been detrimental to domestic food production through differences in production systems that undermine UK standards.  Trade can provide resilience and additionality to our food supply, but if it serves to primarily harm food sectors where we are able to support demand through domestic production, it is only a net negativeConsequently, given the recent evidence of the fragility of our food system, we believe that not supporting domestic food production would be an unwise trajectory to follow; and that is even before accounting for the lower environmental and climate impact of domestic production (in some sectors) versus global averages.

The lack of domestic production policy direction creates further uncertainty.  In the UK, no action has yet been taken to assist with the current price pressures, short of a partial advance on 2022 BPS payments, which will be on average 25% reduced from 2020 levels. In comparison the EU has announced a temporary derogation from rules on crop rotation and maintenance of non-productive features on arable land for the claim year 2023.  In addition, the EU has provided >3bn Euro of additional direct support on top of the normal levels of BPS and Pillar 2 funding.

We believe Government needs to consider short-term initiatives that will support domestic food production. That is not to say we should abandon moves to improve the environmental sustainability of domestic food production; we discuss the longer-term initiatives below.  However, for the 2023 season, Government should consider following the EU’s example and remove some cross-compliance obligations on land growing key crops such as cereals as well as balancing fertiliser usage with individual crop needs.  Another could be to allow farmers who have entered land into tree planting schemes, re-wilding initiatives, or whole field pollen & nectar mixes (under Countryside Stewardship) to delay by a year.  A carefully thought through support package for farmers could improve domestic food security in 2023 without compromising longer term ambitions.

In the long-term any focus on domestic food production must take account of its sustainability.  Policy therefore needs to support our farmers in improving their resource use efficiency including alternative sources of nitrogen.  Improving nitrogen use efficiency will benefit the environment through reducing losses from the system and reducing inorganic N use (with its associated carbon footprint).   Government must also work with industry to look at alternative sources of hydrogen to make ammonium nitrate, for instance by using solar, hydro or wind generated electricity to electrolyse water.  This would also address concerns about CF’s monopoly on domestic fertiliser production. 

Resource use efficiency policy should also address sustainable pesticide use and regulation to ensure that resource use is seen within its full policy context i.e. food production, 25YEP and net zero ambitions.  Policies that support reduced yields or inputs result in an increase in the carbon footprint of a crop, as the process for producing the crop (cultivations, fertiliser applications, harvesting etc) remains largely unchanged whilst a pest damaged crop will take up less fertiliser than that applied (which will have assumed ‘normal’ yields) and so there is the potential for the excess fertiliser not taken up by the crop to be leached from the soil, negatively impacting on water quality.  What is needed are evidence-led policies that optimise inputs and outputs.

Another element to long-term policy must be R&D.  Providing the balance between maintaining domestic food and supporting farmland biodiversity will require specific management approaches that are grounded in science.    The GWCT’s Allerton Project (https://www.allertontrust.org.uk/ ) is an example of how of food, carbon, biodiversity, water and wild areas can be delivered on a single farm through the development of scientifically researched management approaches to optimise outcomes.  For example, the farm has introduced short-term legume rich leys to the already diverse rotation of wheat, oats, barley, oil seed rape and beans to improve soil structure and health and to reduce use of inorganic nitrogen and plant protection products and when the leys flower, they provide food for insect pollinators. The other key element is the need for an adaptive approach.  As our scientific understanding improves, policy needs to adjust. 

Scientific developments in food production are also vital to support access to affordable nutritious food whilst protecting the environment.  The focus on producing cheap food has resulted in the emphasis on inputs.  Now the focus on producing affordable food must encompass how we can improve our resource efficiency as well as looking at how crops can be evolved to be more climate resistant and more efficient users of the available nutrients.  This involves not only improving crop management but also plant pathology, pest management and soil health. 

Whilst we would generally support initiatives that improve the competitiveness of the farming sector (such as R&D) we are concerned by Governments plans for deregulation to achieve this. The concern is that through reducing regulation Government is seeking to facilitate a level playing field with foreign producers in support of future FTAs allowing imports of lower environmental and welfare standards.  This is unlikely to support food security as it removes the opportunity for our farmers to export and compete on the provision of a higher standard product and merely encourages a race to the bottom which, given scale restraints, our farmers are unlikely to win.  Only some of our high costs are regulatory; deregulation could therefore throw away our competitive advantage.

Public procurement is an important policy tool which can be used in support of domestic producers.  The recent government Food Strategy goal of 50% locally produced or higher standard food in the public sector is therefore welcomed.  The GWCT’s Allerton Project is hosting a sustainable food and procurement summit with Good Food Leicestershire to showcase the benefits for the environment, health and economy of increasing the amount of locally produced, sustainable and healthy food in the county’s schools, hospitals and other public services settings.

In addition, there needs to be better communication and policy connectivity across departments.  Currently this is almost entirely absent, with links between environment, global food production and health pretty much absent. Food waste (some 25% of food produced) is endemic and a big ‘cost’ to both the consumer and the environment. Policy to encourage the more widespread production of fruit and vegetables is absent whilst current production is not supported by the supermarkets who refuse to move the retail price in response to higher input costs (witness the reduced area of potato production). 

There is also little sight of support for the industry to help mitigate the worst impacts of climate change (as seen this year in particular). Climate change is starting to exert an increasing influence on food production. Drought, flooding and intense heat are all impacting on yields and causing increasing risk to food supply. Different patterns of weather confound each other, for example wet autumns prevent the sowing of winter crops, forcing the farmer to delay drilling until spring; summer droughts effect spring sown crops more severely because their root systems are less well developed.  We still await the Soil Health Action Plan for England and as part of the land use strategy a national water infrastructure plan would be welcomed (including facilitating planning approvals for on-farm reservoirs etc). 

We would also suggest that as BPS provided some protection against market volatility, Government should consider crop insurance as part of the intervention measures in the Agriculture Act.


Game & Wildlife Conservation Trust

30th September 2022


For further information please contact:   

Dr Alastair Leake   

Director of Policy & Allerton Project   

Game & Wildlife Conservation Trust   

E: aleake@gwct.org.ukSeptember 2022