Natural England: Written evidence submission to the Environment, Food and Rural Affairs Select Committee – Food Security

Natural England is the Government’s statutory adviser on the natural environment established under the Natural Environment and Rural Communities Act 2006 (the NERC Act). Natural England’s purpose is to ensure that the natural environment is conserved, enhanced and managed for the benefit of present and future generations thereby contributing to sustainable development.

We are pleased to submit evidence to the Committee’s important inquiry, which provides a timely opportunity to bring evidence-based scrutiny to a subject that is too often shrouded in unscientific rhetoric. Given our organisational remit, we have focused our response on the particular environmental dimensions covered by the fifth and sixth questions in Committee’s the terms of reference. We have also captured some broad comments in the overview below.

Overview

• The Government’s proposed land use framework should provide the means of enabling effective integration and securing the best value from our land, as well as finding ways to accommodate multiple outcomes in the same landscapes.
• To be fully integrated, the framework needs to be developed in partnership with all relevant bodies, as well as being informed by a comprehensive evidence base.
• Food security is underpinned by functioning natural systems, with research highlighting that the benefits delivered via agri-environment schemes are often sufficient to offset any direct loss of production.
• The farming policy trajectory towards ‘public money for public goods’ is fully justified on the basis of supporting our long-term food security and the relative balance of budgetary priorities seems broadly correct in Defra’s Agricultural Transition Plan and June 2021 progress update.
• Sustainable farming and fisheries rely on a healthy natural environment; food production and supply depends on healthy fish stocks, soils, water, air and natural processes – all of which are vital in underpinning our long-term food security.
• In terms of protein derived from both capture fisheries and marine aquaculture here in the UK, Government should use its financial incentives to see a transition towards more sustainable fishing; a regime that follows an ecosystem approach, does not hinder delivery of Good Environmental Status, and is fully compliant with the eight objectives set out in the Fisheries Act (2020).
• The argument that increased domestic food production or domestic food self-sufficiency would tangibly improve the UK’s food security cannot be sustained by the evidence, as it is more to do with a country’s ability to procure sufficient food on the global market.
• The self-sufficiency ratio provides no measure of the country’s ability to produce food with its own resources and the extremes involved in a policy that completely removed the need for imports are impractical and undesirable.
• None of the problems of household food insecurity will be alleviated by a high degree of UK self-sufficiency in food.
• Increased domestic food production would also not make a significant impact on global food insecurity, as the UK is not a big enough producer to impact global commodity prices at which the most affected countries need to purchase.

Q5. Is the current level and target of food self-sufficiency in England still appropriate?

5.1.            The biggest medium to long term risk to the UK’s domestic production comes from climate change and other environmental pressures.[1] As discussed in more detail in the answer to question 6 below, the proposed land use framework needs to reduce those risks by setting out the choices we must make, as well as finding ways to accommodate multiple outcomes in the same landscapes.

5.2.            Food ‘self-sufficiency’ and ‘food security’ can be unhelpfully conflated, so it is important to clarify the distinction, including delineating the latter’s relevance at the national and household levels.In terms of national food security, as a relatively rich country, the UK is by any objective definition one of the most food secure nations on earth.[2] As a country, we have considerable purchasing power, well-established trade infrastructure, and a modest & stable proportion of food imports in overall imports. There are though other places in the world where there is a chronic shortage of foodstuffs. These are nationally food-insecure countries, often having insufficient foreign exchange and a lack of purchasing power to procure imports of even basic staples. This is commonly due to lack of trade infrastructure, low levels of national income, weak currencies and in some instances military conflict or civil war.

5.3.            The UK situation is very different, allowing us to rely on food imports to ensure our national food security for an incredibly long historical perspective. Even in times of extremis, such as the World Wars, food imports were sufficient in volume to supply roughly half of domestic consumption. Nonetheless, here in the UK, we have households who experience food insecurity due, principally, to poverty and distributional issues.[3] This is important to make clear because it highlights the appropriate policy responses and indeed root causes of food insecurity experienced by those in the country often have very little to do with agricultural or trade policy, and are more about the social protection and safety nets afforded to those at the bottom end of the income distribution.

5.4.            A key part of the Committee’s inquiry will be in distinguishing the extent to which the UK’s food security would be improved by increasing our domestic self-sufficiency. Testing the idea to destruction, Professor Dieter Helm lists the steps that would be required under a full autarky route to genuine self-sufficiency:[4]

• “Step one is to ban exports, diverting production for exports to home consumption. […]
• Step two is to divert land use away from crops produced for other purposes, notably biofuels, solar farms and leisure activities like game shooting, horse riding and so on. […]
• Step three is […] to develop home production (and possible British ownership) of fertilisers, chemicals, pesticides, herbicides and large scale antibiotics – now essential for self-sufficiency.
• Step four is to use taxation and other regulatory measures to reduce meat production and consumption relative to cereals and vegetarian diets, since this would achieve a higher level of self-sufficiency for a given area of land.
• Then finally, draconian import tariffs should be imposed.”

Professor Helm notes that the main industry lobby “does not advocate any of these policies, and instead goes for increasing production generally through subsidies”.[5]

5.5.            The weakness of the self-sufficiency argument has played out in recent months, with our high level of self-sufficiency in wheat and barley not preventing general grumbles about the high price of imported fertiliser and the risk to domestic production. This demonstrates that the self-sufficiency figures are no indicator of self-reliance, as they provide a weak indicator of the ability of a country to produce food with its own resources.

5.6.            Increased domestic food production in the UK would not make a significant impact on global food insecurity. The UK is simply not a big enough producer to be able to impact global commodity prices,[6] which is the major determinant of the problems facing the most food insecure countries in the world, rather than the availability of foodstuffs.

5.7.            We question the suggested link between food and energy security, which may be a parallel potentially drawn in other submissions to this inquiry. Food and oil prices often spike together, meaning that concerns around energy and food security can get conflated. However, there is more scope for substitution on the demand and supply sides between different foodstuffs than between sources of energy, especially in the short term. The supply of energy involves single large physical networks (e.g. gas and electricity), and there are little alternative means of sourcing energy if these networks become interrupted. Overall, energy market policies can have a significant impact on security of supply whereas for food security – at national level – the chief determinant is a country’s income level alone, rather than agricultural or food policy itself. As long as a country is rich enough, it will be able to procure sufficient food on the global market. In the energy market, recent experience suggests this might not necessarily be true in the short run because of infrastructure issues. This creates a fundamental difference between what might be deemed appropriate policy in the spheres of energy and food security at the national level.

5.8.            Producing more at home does not necessarily make a country less exposed to price shocks and volatility on global markets. The UK is essentially a price-taker and changes in UK production levels and net-trade will not have much impact on the price-levels we face as a country. For instance, being a net-exporter of barley does not make us more secure nor change the fact that UK prices will follow global prices. Modest increases in UK food self-sufficiency, and indeed decreases, play little to no role in determining the food prices we experience as a country. Irrespective of our level of self-sufficiency, the price shocks and volatility caused by the war in Ukraine and wider global market issues would still have hit the UK. That is because it is the level of trade barriers that determine the degree to which global price shocks are transmitted to domestic markets, not the level of domestic production.

5.9.            The security of a nation’s food supplies is clearly of upmost importance to a government. However, it should be reassuring that no major changes in policy direction are required in a domestic context. During the coronavirus lockdowns in 2020/21, it was remarkable how resilient food supply chains proved to be. As Professor Helm observes, “if food security could survive the greatest shock since the Second World War with only a few items missing in supermarkets in the short term, then the system can be regarded as incredibly robust”.[7]

5.10.        Domestic food self-sufficiency is not required to improve food security, so it begs the question of what the policy rationale would be for a domestic production target. UK net food imports are not currently at unusual levels and certainly not in a long-run historical context.[8] The often-quoted decline since the late 1980s is actually a fall from a distorted peak, from when Common Agricultural Policy (CAP) support was at its most market distorting. Nations that set domestic production targets for agricultural production tend to be poor countries who want to reduce food import bills and save foreign exchange, where food imports make up a major proportion of their imports. Those factors are just not relevant for the UK.

5.11.        Some organisations were obviously not satisfied with the cited aim to maintain current levels of domestic food production in the Government’s Food Strategy White Paper, with them pushing further for food security to have the same statutory underpinning as the government ambition for nature, species and trees.[9] This demand has expanded more recently to now involve all government departments having a duty to consider food production when bringing forward new policy initiatives.[10] Clearly, if serious consideration was to be given to such proposals, to avoid the inadvertent creation of a hostage to fortune, it would be necessary to scope out fully the implications and the policy interventions involved.

5.12.        If Defra felt it necessary in future to deploy policy interventions to boost domestic production, the options available include deficiency payments, market price intervention, coupled support and input subsidies. All of these run counter to the more market-oriented vision of post-CAP domestic policy, with their previous use proving both economically and environmentally damaging. The proposed duty to consider the impact of food production might limit Defra’s ability to fund schemes with higher environmental ambition, which seek to incentivise land managers to ‘make space for nature’, such as the Landscape Recovery component of Environmental Land Management (ELM), and also Local Nature Recovery.

Q6. How could the Government’s proposed land use strategy for England improve food security? What balance should be stuck between land use for food production and other goals – such as environmental benefit?

6.1.            If it is to fulfil its potential, the land use framework, promised for publication in 2023,[11] needs to be developed in partnership with all relevant government departments, key national bodies and stakeholders to ensure it is fully integrated and considers all land use pressures. These include housing, food and commodity production, transport and other infrastructure, alongside health and wellbeing benefits to local communities.  The land use framework should provide the means of enabling effective integration and securing the best value from our land, as well as finding ways to accommodate multiple outcomes in the same landscapes. It must, therefore, be underpinned by evidence that will inform choices about the utilisation of land in a way that addresses the climate change and nature emergencies. This will mean the way some land is used, including for agriculture, will need to be reconsidered to help ensure food security.

6.2.            Natural England can help develop and deliver a policy framework and approach that emphasises working with the environment, looking to deliver sustainable solutions across multiple interests, setting priorities and helping to manage competing pressures on land. Planning and integration of economic, social and environmental drivers together enables comparisons of costs and benefits and the layering of outcomes on top of each other.

6.3.            The UK Food Security Report,[12] published in December 2021, outlined that the biggest medium to long term risk to the UK’s domestic production comes from climate change and other environmental pressures like soil degradation, water quality and biodiversity loss. The proposed land use framework needs to reduce those risks by setting out the choices we must make to manage a changing environment to sustain a viable modern agricultural industry and help ensure food security. This management must:

• Ensure water availability and water quality and address nutrient enrichment in water courses;
• Manage our soils sustainably to maintain important carbon stores and the ability of our land to grow crops;
• Address sea level rise by realigning flood defences in coastal areas that are vulnerable to erosion and/or sea level rise, and the associated re-creation of natural habitats;
• Restore and connect habitats, encouraging natural ecosystem processes, reducing the spread and release of pollutants to land, water and air, protecting and buffering key areas for nature; and
• Target those areas that will benefit climate change mitigation and adaptation.

Without this we will continue to witness declines in species, habitats, water and air quality, loss of soils and increases in the devastating impacts on agricultural production caused by flooding, drought and seasonal change.

6.4.            When striking the balance between land use for food production and environmental objectives, there can be a risk of overstating the tension between the two, as there is considerable potential for them to work together synergistically. Food security is underpinned by functioning natural systems. Healthy soils, natural pest control, pollination, sufficient water and predictable seasons are among the services supplied by nature that help determine our food supply. The more we disrupt those services, the more farmers must resort to expensive fertilisers and pesticides, and the more consumers must pay for food driven into shorter supply because of environmental disruption.[13] In future, if climate change translates into more frequent adverse weather events, then it will be global trade – not self-sufficiency – that will be even more important in mitigating the price effects of supply shocks by transferring food from unaffected to affected areas.

6.5.            Recent long-term research has highlighted that the benefits delivered via agri-environment schemes are often sufficient to offset any short-term direct loss in production.[14] Indeed, the Sustainable Farming Incentive is being designed specifically by Defra, as a universally accessible scheme, to pay for environmental benefits that can be produced alongside food production. Through initiatives such as these, it should be possible to ensure the longer-term productive capacity of our domestic farming industry, sustainable in the truest sense of the word.

6.6.            The relative balance of budgetary prioritisation seems broadly correct in both Defra’s Agricultural Transition Plan[15] and the ELM funding split commitment made in June 2021.[16] To ensure a smooth and just transition, Defra is allocating a proportion of the budget to investments aimed at boosting food productivity, at the same time as direct income supports are being wound down and environmental delivery is ramped up. After the end of the Agricultural Transition period, the justification for devoting public monies for the private activity of producing food will diminish, with the vast majority of the Future Farming and Countryside Programme budget then rightly devoted to the environmental public goods that will be vital to support our long-term food security. To ensure that an ambitious budget focused on this objective can be legitimised into the future, it will be imperative that Defra maximises the environmental delivery from the resources available to it by avoiding overcompensation in payments and stripping out any policy ‘deadweight’.

6.7.            There are many parallels to be drawn in terms of how UK fishing can address supposed ‘food security’ as described for agriculture above. The first, and the most important, being that in general the domestic consumer market eats fish that largely have been imported (81%), with those fish caught by the UK fleet (70%) largely being exported. Thus, based on current eating trends, having more fish caught at home will do nothing in terms of bolstering domestic food security, and indeed if current methods are retained is likely to lead to an increase in environmental damage done to our already degraded marine environment. As fish and shellfish are generally seen as healthy foods, if steps are taken to increase domestic production to specifically meet the domestic market (i.e. not for export) then it is key that the resulting environmental footprint is both assessed and addressed. This means much more than ensuring exploited stocks are harvested at levels that can sustain production year-on-year, as commercial fishing is currently the key anthropogenic pressure hindering delivery of Good Environmental Status (GES, as set out in the Marine Strategy Regulations). Commercial fishing has been identified as the primary anthropogenic pressure hindering delivery of GES, most notably, but not exclusively, by those fishing gears that are towed over the seabed. Although certification under the auspices of the likes of the Marine Stewardship Council represents a progressive step towards sustainability it does not yet have any link to the Marine Strategy Regulations, thus certified fisheries can still be causing environmental damage.

6.8.            Derivation of sustainable seafood here in the UK should take account of the new legislation within the 2020 Fisheries Act, which has eight specific objectives that the UK’s new fisheries regime, now outside the Common Fisheries Policy, should adopt. These include the Ecosystem Objective, which has an explicit link for reformed UK fisheries management to assist with the delivery of GES. In addition, there is a Climate Change objective in the Fisheries Act whereby fleet impacts should be reducing impact on those key habitats that are marine carbon stores, such as deep sea mud, but should also be reducing emissions from the burning of fossil fuels. Note that currently the UK fishing industry pays no duty on fuel used for fishing operations; this adds up to an annual subsidy of over £100m. It is perhaps no coincidence that those vessels that do the most damage to the seabed are those that also benefit the most from the Fuel Tax Concession. Fish are a public asset and it is time that the premise of Public Money for Public Goods was accordingly applied to commercial fishing, so that HM Treasury investments in fishing not only reduce the environmental damage done but also incentivise the shift to more sustainable practices in how we derive marine protein.

Natural England - September 2022

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