Written evidence submitted by Plantlife (ELM0008)


January 2021


  1. Plantlife welcomes the opportunity to provide written evidence to the committee on this issue and would be pleased to provide further information, or to elaborate on any points made within this response.


  1. Plantlife is a UK conservation charity working nationally and internationally to save threatened wildflowers, plants and fungi. We own nearly 4,500 acres of nature reserve across England, Scotland and Wales. We have 11,000 members and supporters.



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

3.Over the past four years, there has been considerable work taken to develop the ELM scheme, and we applaud the Government for the progress that has been made. However, there is still considerable work to be done to integrate the Agriculture Act with the Environment Bill and the Nature Recovery Network. A review of farm regulation and an assessment of the ELM tests and trials (Plantlife leads a test and trial on digital advice and land manager collaboration) results still needs to be conducted. For ELM to be successful, it is critical to take the time to consider more deeply how these different elements will fit together and complement each other. Consequently, we would urge the Government not to rush the development phase and to ensure the policies put in place are fit for purpose and sufficiently integrated.

4. The Agricultural Transition Plan provides general guidance about the rollout of ELM and SFI, but more clarity is needed. Farmers and land managers need to be given a clear schedule of payments and the phasing in of the new schemes to avoid an income gap caused by the loss of BPS.  It is vital that clarity is now given on the detail of this funding, for instance how much will go into the Countryside Stewardship scheme between 2021-2024.

5.Without such clarity, farm businesses will be stranded, and there is a risk that they could adopt damaging practices to cover their costs. One such risk is that farmers might plough up their grasslands to be eligible for arable payments, or to prepare it for development. Such an action would have devastating results for plantlife and fungi, not to mention invertebrates and farm birds. Since the 1930s, over 97% of our meadows and grasslands - a staggering 7.5 million acres - have been ploughed, agriculturally ‘improved’, or built on so that today, only 1% of species rich grasslands remain in England.[1] It is critical that Government recognises the potential risk to this irreplaceable habitat when rolling out their payment programs.

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? 

6. To deliver the step change that is needed to move UK agriculture policy away from CAP, the design of the new SFI cannot merely reflect the BPS. It needs to be holistic and recognise the interconnectivity of farming with the natural world to help reverse the environmental damage that industrial agriculture has caused. The SFI should be designed to be accessible to all land managers delivering public goods, not just farmers. By increasing eligibility for SFI, Defra will help to prevent artificial distinctions between different categories of participants and encourage a high level of uptake.

7. Key to ensuring that SFI is successful in its goal to bridge the gap between CAP and a fully rolled out ELM is actively encouraging adoption and distinguished it from previous support systems. Ensuring that the design is not overly prescriptive in terms of management techniques will help to encourage uptake since it will allow land managers to approach the task with their own expertise. Consequently, the SFI needs to be enough flexibility to allow land managers to make the best decision for their land, provided they deliver their environmental targets.

8. Plantlife supports the introduction of productivity grants to support land managers and farmers to meet the new regulatory baseline. Within this, Plantlife welcome the introduction of a Slurry Investment Scheme and plans to implement new regulation on slurry stores as part of the Clean Air Strategy. Air pollution (particularly from ammonia) damages wild plants and fungi and today, 90% of sensitive habitats in England and Wales are suffering from excess nitrogen.[2] The significant capital investment is frequently a barrier for farmers looking to reduce their nitrogen emissions and this scheme should help to address that issue. That said, support to reach the regulatory baseline should be time limited so as not to unfairly benefit those who have continually failed to make the necessary improvements.


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

No response

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

8. For ELM to deliver its public good objectives, high uptake is required, and it needs to be executed with conviction. For farmers and land managers to adopt ELM wholeheartedly, ELM needs to make financial sense. Consequently, the design of ELM needs to take a balanced approach and consider the economic sustainability of a farm business on equal footing with its environmental sustainability. ELM needs to use an approach that empower land managers and farmers to make the best decision for their land and not be too prescriptive. Otherwise, it will merely be a tick box exercise and fail to deliver its true environmental potential.

9. For many, this shift will be challenging since it may demand significant changes to current management practices. Plantlife would advocate that guidance by provided through the transition period to support farmers and land managers to switch to more sustainable methods of production. Beyond the transition, Government should improve access to training and advice on both agronomic and environmental practices. Whilst some support could be delivered digitally, it will remain vital for land managers to have face-to-face guidance from an advisor. Consequently, we strongly advocate for an improved advice and support service for farmers and other land managers with secure long-term funding. To ensure that the advice provided is of adequate standard and consistent across England, we would recommend the creation of an industry standard with an approved accreditation to ensure that land managers were receiving the best advice possible.

10. The Local Nature Recovery and Landscape Recovery pillars should be given equal weight to the SFI in order to deliver the best outcome for nature. However, for the uptake of these two pillars to successful, there needs to be independent professional facilitation, secured by long-term funding. Using professional facilitation would increase the likelihood of success since facilitators bring together individuals across the specified region and would help to build trust between neighbouring land managers to deliver target actions across the region.

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

11. For the beginning, Plantlife has welcomed the principle of PMPG and the ambition to put environmental outcomes at the heart of farming, forestry and other land management. Designed and implemented well, ELM has the potential to transform the fortunes of England’s wild plants and fungi, both in diversity and abundance of species. To achieve this, the design of ELM should encourage all land managers to take steps towards greater sustainability since transforming the future of land management will only happen if there is wide adoption of ELM. To encourage land managers to sign up, the SFI needs to have a relatively low entry point with easy and accessible incentives to interest farmers and land managers who might otherwise feel environmental schemes are not for them.

12. In order to demonstrate that public goods are being delivered, farmers and land managers should provide farm-level data on an annual basis. Not only would this provide a benchmark for each holding, but would also measure the overarching success of these schemes. Therefore, Plantlife would advocate to using the metrics outlined in the Environment Bill to build a more complete national picture of our public goods. By gathering and mapping farm-level data, Government can have a more targeted approach since they will be able to better identify areas of good practice and potential weak spots. It is critical that this data been transparent and open source so that civil society and academia can learn lessons and improve their modelling.

13. However, to qualify for public money, funding should focus on positive long-term outcomes, not simply maintaining the status quo or avoiding deterioration. For example, a land manager should not be paid leave their permanent pasture intact. But they should be paid to increase the species-richness of that grassland through restoration techniques that deliver greater biodiversity, increased well-being and improved animal health. Consequently, in terms of grasslands specifically, it is critical that there is funding for both restoration and maintenance of species-rich grasslands to support active and ongoing management for species-richness.

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

14. In the past, the design of CAP adopted a tick-box approach and did not encourage a holistic approach to agriculture policy. It is essential that ELM recognise the complexity of ecosystems and avoid adopting overly simplistic approaches that have unintended consequences. For example, CAP advocated for tree planting without due consideration of other habitats. While we welcome additional tree-planting and would support woodland creation, it needs to be managed effectively so that there are no unintended consequences for open habitats. For example, it might happen that species-rich arable land or grassland could be lost when creating new woodland. We would ask for a strategic framework for tree planting to minimise any potential damage to open habitats. Additionally, we are calling for the ‘greening’ rule on maintenance of permanent grasslands ratio within the EU’s Common Agricultural Policy (CAP) to be replaced with equivalent protection.


January 2021

[1] Plantlife, National Meadows Day Parliamentary Briefing, July 2020, available online https://www.plantlife.org.uk/download_file/force/3163/1146

[2] Plantlife, We need to talk about nitrogen, 2017, available online https://www.plantlife.org.uk/application/files/1614/9086/5868/We_need_to_talk_Nitrogen_webpdf2.pdf