Written evidence submitted by Tom Jewers (ELM0001)


Famer and land manager support post 2020



As a farmer we have know for some time that BPS will be phased out.  We have tried to tramline our business by cutting overhead costs as far as we feel able by changing our farming practices considerably. 


We have also known for sometime that the governments plan was to phase out BPS and phase in ELMs.  However the detail on any of this is very sketchy, even the recently published ATP was light on detail.  I believe that the timeframe for phasing out direct payments by 2027 is entirely feasible, but the concern for me as a farmer and land manager is the ability to plan my business ahead with no detail of any payment structure for the SFI or ELM.


The role of direct payments has always had a bad press, but the reality is that this is a risk management payment for our business.  We are at the mercy of global commodity pricing, and the weather - 2 things out of our control.  When these go in our favour, we can easily manage without direct support, but when one of the other go against us, its touch and go, and when both go against us together, BPS is the only thing that keeps my family fed.



Given the changes we have made to our business, knowing that direct support is going, I welcome the idea of the sustainable farming incentive, as we have been moving to a more regenerative style of farming, which I’m hoping sounds like the sort of thing that will be rewarded under this scheme.  My hope is that this incentive will be available to all, and those already adopting sustainable practices will not be disadvantaged. 


Due to the lack of detail surrounding what exactly is involved with the SFI it is difficult to comment on whether further support is required during the transition period.  For example - actions like direct drilling and cover cropping to improve soil health are mentioned - but what rate of payment is likely to support this practice?  IPM is also mentioned - we use many IPM methods to decrease our reliance on pesticides, but this INCREASES our risk of not getting a crop - for example we want to reduce our use of residual herbicides for grass weed control in wheat, and now neonicotinoid seed dressings are banned, we want to avoid a foliar insecticide application to kill BYDV disease spreading aphids.  By using IPM we can delay the sowing of the wheat crop until late October or November to give grass weeds a chance to grow so we can kill them before sowing, and also the weather is cooler which lessens the risk of aphids flying into the crop and breeding.  However, the past 2 autumns have shown this is a huge risk to our business as if the weather turns wet, we are forced to either sow in poor conditions giving us a poor crop, or may not ever be able to sow at all.  So IPM is a good thing, but increases risk of a poor crop.

It would be nice to know details on planned payments to be able to comment on if I think further support is required.

Hedgerows are also mentioned - I hope that farmers who have retained small fields with hedgerows and suffered the inefficiencies for the past decades are rewarded for existing features, and the support is not just given to plant new hedgerows, effectively rewarding those people AGAIN, who were paid to remove them and make their fields bigger in the 50’s 60’s and 70’s.



Im pleased with the interaction between DEFRA and land managers on the design of ELM. The appointment of Janet Hughes has been a good one, she seems ready to engage and listen to stakeholders.  We are looking forward to pilot schemes and the feedback of how these work - but I am worried about the potential complexity of Tier 2 and especially Tier 3, which could swallow up a lot of the budget on consultancy fees.



The key to making ELM an attractive business choice for land managers is flexibility and payment rate.  The idea of Income Forgone does not work for me.  In existing Countryside Stewardship, for example the payment rates for options such as AB1, 8 and 9 which have huge public benefit and very fast wildlife benefit are too low.  The prescriptions in AB1 suggest choosing a sunny aspect free from shading, but in reality due to the IF payment rate I cannot afford to put this option in a south side of a hedge, because I can earn more money cropping that part.  For me, the place to put it, is on the shaded side, where I have a lower margin from a cash crop, and so the payment rate makes more sense than cropping it.  Clearly from an environmental aspect this is not the ideal situation, but if it paid more like £900/ha I could site it on my very best land.  Another example is AB12 - a truly fantastic win for farmland birds - we see a huge benefit for doing this.  But the payment is £632/ton.  I have been feeding today, I spend 2 hours a week carrying out this option.  To buy in a feed mix costs around £320/ton.  We must feed this for 20 weeks, so 40hrs work of man plus ATV means I’m receiving £11.70/hr to pay myself and run the machine. I believe the environmental benefit is worth a lot more than that. The other issue with IF is that is does not count for overheads.  I still have all the machinery on the farm, and its associated costs, so taking land out to put into environmental options just increases the cost/ha on the remaining cropped land.  To summarise, the payment rates need to be attractive enough to make ELM a good risk management option for land managers. 

Current CS schemes are a bit restrictive as you have to plan the 5 year period ahead, and cannot really change much once you are in.  There is a good option called AB15 2 year legume fallow.  Wonderful for soil health, but also habitat for pollinators and other beneficials and will create seeds for birds over winter too.  It would be good if farmers could react to a situation and decide “right we will put that field into AB15 next year to give it a black grass break and increase fertility” without having to make a new agreement.  Also AB14 low input cereal - the past 2 autumns have been very wet and we have had very poor cereal establishment on headlands of fields.  If we could be reactionary and decide the crop is thin there, but it will meet the requirements for AB14 if we don’t apply herbicides, then we could receive some payment which will help offset the crop loss, but without having to have seen the future 5 years ahead to know it was going to happen!



There is plenty of science to show that good pollen and nectar mixes will increase pollinator numbers, and winter bird food cover and supplementary feeding will increase farmland bird numbers, cover crops will reduce nitrate and phosphate leaching, buffer strips will reduce watercourse pollution etc. So if these are in place its because farmers are engaged and want to do it.  To have an inspector come around and say, for example, “Your AB12 supplementary feeding diary is incomplete as you have not recorded the amount of feed put down on the 12th January, therefore we will have to fine you” is frankly petty officiousness.  Same with buffer strips - if I have a 4m buffer entered and most of it is 5m wide, but 5 meters of length is 3.8m wide, is it really necessary to fine me?  Of course rules need to be in place so people to do take the mickey, but I hear of so many examples of petty officious fines which disengage farmers with the schemes.


Real engagement with land management about costings.  We used to put all our hedgerows into Entry Level stewardship, but have not entered them into any of our CS schemes as the £8/100m management payment is derisory.  Payment rates aside, the main issues with schemes is processing applications. We entered a small farm initially into CS, and it wasn’t until May 2018 when we had an offer, for a January 2018 start date.  Then we did not get the first payment until June 2019, so this made use very cautious when other ELS schemes finished.  THe Wildlife offer in mid tier was an improvement, and I think increased uptake of CS dramatically, and I’m pleased that the progress has now meant that I have received an offer for a full CS scheme starting January 2021 by early December, but I am aware that many have not, and this is hopeless from a planning perspective. Offers really need to be out by September preceding January start date others land is left out of production on a hope that the application for a scheme will result in an offer.


December 2020