Written evidence submitted by Ann Willcocks (ELM0009)


My name is Ann Willcocks and I farm in partnership with my husband on a family farm on the edge of Dartmoor. We have a livestock farm, suckler cows and sheep utilising the common land adjacent to our farm.  I am very involved with several local commoners associations across Dartmoor and have an interest in common land and upland farming and their support.  I am responding to this call for evidence as our future as farmers is in the hands of Government.  We continue to look after our environment and take great pride in our farm and our livestock, we want UK Government to understand how vulnerable our roles as farmers is under the current proposals of ELMS.


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

No, I do not consider the time frame is feasible.  The National Pilot is due to commence in 2021 (Farming is Changing, October 2020).  I am currently involved in one of the Tests and Trials and we have continued to meet via on line platform all through the year of 2020.  Whilst we have committed so much time, we are not in a position to trial on the ground any of our findings. 

Common land agreements need to be bespoke.  They need to encourage a strong working relationship between all parties, based on trust.  The number of tests and trials looking at the complexity of common land issues are minimal – maybe one or two, but no-where near enough.

There are no indications of any options under the sustainable farming incentive for common land.

The sharing of the options being considered for any new land management scheme need to be shared widely as draft documents, in order to achieve the highest potential take up.

There is insufficient information in the public domain for suggested options.

The SFI is due to be rolled out in 2022, this will be the Basic Payment Scheme money, so farmers need to be able to access what has been taken away from them.  Farmers will be expected to still adhere to the rules and regulations of BPS, but for less payment.

Once again, the lack of information available for a business to plan what changes it needs to make for a scheme due to start in 2022 is not available. Business plans take time to adapt and need information.

As a hill farmer, there must be an uplift in the payment for farming in areas of natural constraint.  For grants, any partial grant must be at a higher percentage to those farming in areas that are not designated as Severely disadvantage and disadvantaged.

Options must be fit for purpose and take into account what is possible in areas of natural constraint, often complicated by extreme planning regulations.

It would be most beneficial to have an overlap between schemes, so that current environmental land management schemes could run, with a given time – up to 2 years – to create and implement the new scheme, to enable a seamless transition.

It can take 2 years or more to negotiate an environmental agreement on common land and at great expense - £20,000 was the cost of negotiating the HLS agreement on this common in 2010 for 50 commoners and 5 owners. If there were an opportunity to roll over the existing scheme whilst negotiations were under way, it would open up the potential for a smooth transition with land staying under agreement.

The same principle should apply to BPS, with a recognition of the new schemes taking time to bed in, some farms may require additional support during the transition phase.


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?

There is little information in the public domain as to the options available within the SFI. 
If what I have seen with regards to a suite of assets and the list of indicators within a tiered system is flawed.  As a land manager it is far more appropriate to choose a certain number of indicators to achieve the level of success and then add more accordingly – but choice is the key word.  A set of indicators are a) not applicable to all farms b) not achievable by all farms, therefore uptake will be reduced.

Sustainable farming is all about the whole farm, ensuring the farm adheres to statutory regulations, is a viable business, and looks after the environment.  No one of those points is any more important.  They tend to work symbiotically.  It must therefore be recognised that ELMS must not be about destroying the productive capacity of a farm, even an upland farm.  Therefore, farmers want a choice to choose which option or tier can work in harmony with their business.

The payment rates must be acceptable and enticing to farmers.

The suggestion that farmers wish to spend money to make ‘improvements’ to their business, is not always the case.  Improvements can be made by spending less than is required to purchase a set piece of equipment as offered under some grant schemes.  Perhaps consider small grant schemes for the innovative farmer to do more with less.

There does need to be a form of support package offered during the transition period.  A basic payment to ensure businesses are not lost.  The farm, often within a community offers so much to that community, the glue, the local knowledge, the sense of place, identity.  Living cultural heritage.

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

Defra has communicated with farmers, but there has not been enough detail.  We are months away from new schemes, yet there is no structure to the schemes and no opportunity for long term business plan – we cannot plan our way through the transition as the detail is not there.

There is no certainty.  Businesses thrive on certainty; and farming businesses thrive on the support from Government of the recognition in the part they play as essential food producers.  The importance of food production alongside environmental enhancement is not to be ignored.  But the lack of details is impacting on the long-term future of some businesses.

ELMS and the options and layout need to be shared with the much wider farming community.  I am fortunate to hold a position that keeps me informed, but I am always shocked that when an organisation holds a members’ update how so many of the members know so little as to the changes to agricultural support ahead.  Therefore, I would suggest Government needs to circulate much more detailed information to the farming community.

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

Flexibility, choice of the options undertaken that enable the options to be achieved whilst running a viable business.

The current proposal that I have seen is for a tiered system, tiers 1, 2 and 3.  Within tier 1 there are Assets: hedgerows and boundaries/field margins management, Permanent grassland – and others, but take the permanent grassland as an example, there are then three Standards within that Asset. 
Semi-improved grassland, improved grassland and grassland soils.  Take the Semi-improved grassland Standard, this is then spilt down to Basic, Better and Best.

We would need to adhere to all 7 actions within the base level actions before we could move up a step to adhere to the additional 5 medium level actions and if we were really keen adhere to another 3 high level actions to achieve, we presume, a higher payment.

If that was turned around so base level actions had a list of 7 actions and 3 could be selected – the important word here is choice, then move up to the medium level action and an additional 2 were chosen from the list, moving up to the higher tier where there were a choice of actions.

If you want to encourage participation, then there must be choice. So, select a number of actions from the list. 

The Standards are not the same across the country.  Take a hedge, a Devon bank which has a base of stone infilled with soil and then a hedgerow on the top providing the most amazing habitat against a Shropshire laid hedge – which are just trees planted into the soil, no bank, no stone, just trees, yet they are the same Standard?  The Standards must recognise the regional variation.


Good working relationships with the organisations involved in delivering environmental enhancement.

Trust that not all farmers are bad. We love the landscape we live in; we have a far greater depth of knowledge about the wildlife on our farms that many realise. We are proud of what we do and what we have created.  With the right guidance and a shared vision, improvements to the natural environment can be made. We have had 4 Natural England project officers during a 10 year agreement.  We as the land managers/farmers are the constant in any agreement.  Make sure we are empowered to deliver what is wanted, make sure we are the drivers of environmental schemes.

An example is the Two Moors Butterfly project, where a grant of over £600k was provided to support key butterfly habitat across the two moors. The 2 year scheme did tick so many boxes, it engaged with the public and took them on guided walks, leaflets were produced about the butterflies, a pretty booklet was printed and handed to visitors. There were s couple of days work that the commoners had to do on the site, but the most important thing that it did not do was to leave a legacy with the commons, the farmers who graze and care for those areas, it did not enable them to wholeheartedly understand what habitat was needed and how that habitat could be created.  So at the end of 2 years, with the project finished, has it been worth it?  No, because there is no legacy of understanding left with the constants on the common, that is the farming commoners.

As to paying for advice, an interesting problem.  I thought that currently Natural England were paid to be advisors.  However, if that is to change, then yes, we can pay for advice if and only if, we are provided with the funds from the government pot to seek appropriate advice and the advice we receive must be recognised as valid by those that are enforcing the agreements.

We have seen with HLS agreements where the advice of external parties has been sought during the term of the agreement, yet the NE project officer can still come in and make sweeping changes to the livestock grazing numbers as his opinion, and only his opinion is what counts.  One may call this subjective opinion and that is not good enough.

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

Empower the farmer to deliver.  Make sure the farmers know what is needed and they will deliver.  Look at something as simple as food production, look at how headage payments drove up livestock numbers, it was what was needed in the day.  Give a clear message and target the payments accordingly and it will be delivered.  If you want to see more trees in hedgerows, if you want to see a diverse sward, then say this is what we want to see, and it will happen if the money is right.

But the targets must be measurable and specific to the area.  Do not set standards appropriate for a Shropshire hedge in Devon.  Set standards for a Devon hedge, make it robust enough to be measured, look for the success not the failure. 

SSSI assessments where they deem the area to be based on the least favoured approach, such a shame we do not celebrate all the success of other measures within the assessment, instead we always look for the negative, let us change that approach and measure success as any improvement, no matter how small.

The current options and standards that I have seen are too prescriptive.

Enable viable farming to be carried out where a land manager/farmer wants to be productive.

Do not assume all upland farmers do not want to be productive.

Upland farmers want to farm, not to be park keepers, they want to maintain the environment they live and work in and produce food.  We want a better understanding of livestock systems by those that draw up agreements and those that enforce stocking rates within agreements. 

Where we have been told to reduce sheep grazing numbers on moorland common land agreements for the winter at a moments notice, with a 50 -75% reduction wanted and maybe complete removal of sheep in the winter. Has a serious impact on the business in so many ways.  Removing part of a flock for a period of time impacts on the in-bye land and the environmental agreements governing the management of that land.  The reduction in a flock of sheep impacts on the financial viability of the farm and the flock.  The reduction in the flock numbers reduces the selection of female replacements.  The reduction of a flock on common land impacts on the grazing pattern of neighbouring flocks and disturbs the well established hefts and lears; an imbalance is created.

With a reduction in flocks and herds, with no financial recompense, reduces the viability of the farmstead, without the upland farmers there is no community, the knowledge of the moor is lost, the workers of the hills are lost and the natural beauty is no longer maintained. 

Farmers in the uplands, in areas designated as disadvantaged and severely disadvantage, need up uplift in support, these designations have not changed because the schemes have changed.

It must also be noted that common land is not owned by the commoner, so for all the talk of there being adequate support for those in the uplands, that may not be the case.  A commoner does not have the right to the soil, that belongs to the owner.  An owner of common land is under no obligation to share any carbon storage, peat rewetting payments with commoners.  The same applies to tenanted land.

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

Claims for errors on agreements.

Where an error is found on an agreement, there must be an acceptance that Natural England can make errors.  The current procedure for appeal would be better to be assessed outside of the organisation.

When an inspection is carried out on an agreement, a line must be drawn to recognise that from that point on, the agreement is correct and has delivered according to expectations.  From that point on, there is no claw back of money.  So lines are drawn regularly throughout the term of the agreement and assessments are made so all parties know they are on the right track.

We are currently undergoing the HLS roll over assessment where NE project officers consider they can apply pressure and threaten commoners with no roll over unless they adhere to stringent stocking reductions. This is not conducive to a good working relationship.  If there had been regular assessments undertaken throughout the duration of the agreement, then the shocking reductions would not be necessary.  So the lesson learned, is the need for ongoing  regular assessment and lines drawn.

At the start of the HLS agreement, we had a brilliant  Natural England project officer, who recognised the holistic approach needed to an agreement and would bring all the parties together for constructive discussion as to what needed to be done and when. We are now in the same agreement, the fourth project officer, who cannot (even without covid) meet on the common land to discuss management – it is not his job, it is up to the RPA.  The current system of dealing with an unknown contact within the RPA and wait for them to discuss with the project officer is nothing short of ridiculous.  I have been trying to submit a request to carry out a controlled burn since November 2020, I still do not have the consent as I am passed between RPA and NE, with various forms completed as requested by RPA, then told they are not needed, it is a fiasco.

So the way forward, is a single point of contact, who can make decisions if needed, discuss the right course of action and sign off that an agreement is working up to that point.

We are at risk of losing the hefted and leared flocks of our upland landscapes.  Please stop this from happening by understanding whole livestock systems.  Livestock are not cloud based. Livestock are still the key to landscape management.


January 2021