Written evidence submitted by Farm Consultancy Group (ELM0007)

The Farm Consultancy Group is the representative organisation for 9 agricultural consultancy business in England and Wales. We were formed in 1988 and now have 25 consultants working under our banner.  We work with approximately 1100 farming and rural businesses across all sectors of the farming industry.

Working with predominantly family farms were trusted providers of technical financial and business information. We have extensive experience of helping clients with applications for all types and support and grants in addition we identify opportunities for farmers to develop their businesses. 

Whilst we work across all farming sectors we have a specialist knowledge in the dairy and ruminant sectors where we work with many of the leading opinion formers in the sector.

1. Is the Government’s timeframe for the national pilot, full roll-out of ELM and phasing out direct payments by 2027 feasible?

We are concerned what the impact of the phasing out of BPS will have on family mixed and livestock farms especially as the government has only committed to the level of payment for the duration of this parliament 2024.

The timescale for the roll out of the national pilot is ambitious given that the test and trials programme has failed to engage with a significant number of family farming businesses. The national pilot is going to test the future model for payment for public goods in line with the government’s 25-year environment plan, then it needs to be constructed to achieve these objectives.

2. Will the Sustainable Farming Incentive be a viable support measure for farmers before the full roll-out of ELM? Is further support required during the transition period?

The details of the Sustainable Farming initiative are currently unclear and therefore the level of uptake is likely to be low.  For the SFI to be a viable support measure it will need to achieve levels of uptake that have not been achieved by any voluntary environmental scheme before.  The average family mixed or livestock farm will be more severely disadvantaged from 2024 onwards than the larger corporate arable business.

It is important that the income reduction resulting from the reduction in BPS payments does not result in family farms being forced out of business and therefore some form of additional tapered relief is required in the period 2024 -2026.

Further support could be given to farmers who adopted a systems wide approach to their business such as Read Tractor Assurance LEAF registration of organic certification.

3. How effectively has Defra engaged with land managers and other stakeholders on the design of ELM, including on the transitional arrangements?

Our clients tell us that they are insufficiently informed about the principles surrounding ELM and have limited knowledge of the Sustainable Farming Initiative. Clients are aware of the timescale for the removal of direct support and are becoming increasingly concerned about the reduction in income.

4. How can ELM be made an attractive business choice for farmers and land managers while effectively delivering its policy goals?

The key to ELM becoming widely taken up is the rate of payment.  Historical payments simply based on income foregone will not attract the majority of farmers, a premium of at least 10% is needed to make the scheme attractive to land managers.  If the scheme isn’t seen to be generous enough, or is too restrictive in its rules, there is a big risk that many land occupiers will not engage at all and will just farm every hectare for its maximum productivity. This is particularly the case for more fertile, productive and intensive farms.

Farming is a long-term business, and it is important that the ELM scheme is designed to meet the Government’s 25-year Environment Plan.

The ELM scheme needs to provide at least a 10-year horizon with payment rates being reviewed annually based on farm incomes. This could be a simple % adjustment to all payments on an annual basis.  Fixed payment rates will not encourage farmers to commit to a long-term scheme. 

The bureaucratic burden around both the application for the programme and the annual claim needs to be reduced.  This is particularly important for the smaller and average sized land manager and there needs to be a premium for small farms, a simple flat rate is not attractive to the family farm.  

ELM needs to be kept simple with outcomes being the centre and not the focus around a list of prescriptions.

5. How can the Government ensure that ELM agreements achieve their intended environmental outcomes, reduce bureaucratic burdens on farmers and deliver value for money?

Farmers and land managers are keen to see the environment in which they live and work being improved.  To achieve their desired outcomes the schemes will need a greater level of uptake than has been achieved by previous schemes.  They will also need to encourage farmers to co-operate with neighbours.

Our clients believe that the ELM schemes will be a complex and ambitious programme, they have serious concerns about:

1)      The cost and time involved in applying if the ELM is to achieve the intended outcomes, there will be a requirement for well informed and relevant advice being available both on a farm-by-farm basis and also on a local basis.

2)      The duration of an agreement is important in reducing the initial burdens of the application process so the schemes should be for 10-year periods and allow farms to adapt and change their undertaking on a regular basis if the outcomes are not being achieved.

3)      A single application date makes it expensive and difficult for farmers to apply, the use of remote technologies should help with the mapping of features and inform land managers.

4)      Farmers need to be rewarded for taking a whole farm/system approach to improving the environmental outcomes, such as LEAF membership or Organic certification.

5)      Ensuring that small farms are able to join the scheme, there needs to be a small farm premium which could be tiered so that the more ambitious the scheme the larger the premium.

6)      Ensuring the environmental outcomes are achieved will require a collaboration between farms and the premium for this needs to reflect the outcomes being achieved.  We have seen the success of a number of cluster groups but to achieve wider uptake will require additional payments not simply facilitation funding.

As businessmen farmers are used to self-declaration such as VAT and Income Tax, the ELM scheme should trust farmers to deliver on their undertakings. 

The ability to remotely monitor the outcomes needs to be accepted as part of the scheme, whilst this is new technology, farmers can adopt these practices.

6. What lessons should be learned from the successes and failures of previous schemes paying for environmental outcomes?

The past environmental schemes have by and large failed to deliver the outcomes desired; uptake of the schemes have been patchy and generally low. We believe that these results are a consequence of several factors including:

1)      The schemes have been of insufficient duration to have the lasting impact desired.

2)      For the majority of family farms and particularly livestock farms the payment rates have been too low to make the business case for joining the scheme.

3)      Previous schemes have been solely targeted at individual business and so there has been a piece meal approach which is inconsistent with a broader and more contiguous habitat that is needed to enhance biodiversity and to meet the environmental outcomes.

4)      The schemes have changed on a regular basis with the prescriptions often changing on an annual basis this is a big hinderance to the uptake of the scheme.

5)      Delays in payment have been a major issue for farms who have given up income and expected payment in a defined period only to find that payments have in some cases been delayed for more than 12 months.

6)      An overly onerous inspection process and penalties that bare no relation to the effect of the misdemeanour leads to a lack of trust in the scheme and lower adoption of the scheme.

Clients

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