Written evidence submitted by The English Organic Forum (ELM0023)

The English Organic Forum is a member of the Defra ELM Engagement Group (EEG) and represents the organic sector. We have participated actively in the EEG from the beginning. 

These brief comments are specifically related to the way in which organic farming should be included within the ELM policy. Organic is an approach to land management that operates at a whole farm (whole system) level. There is good evidence for the delivery of Public Goods from organic farming (see https://online.flipbuilder.com/exei/xjft/).

We have repeatedly put the opportunity to Defra, but so far have not had any positive response. This is perplexing in view of the positive position taken by Minister Prentis in her statement to the House on 25th January, where she said: "We will use the Agriculture Act 2020 to set an ambitious new course for the organic sector.” We welcome this ambition but have so far not seen details or evidence for it. 

At a recent meeting with Minister Jayawardena, which focussed on the export trade opportunities for organic food, it is necessary to encourage more organic production in England. There is also a growing domestic market for organic that  must be met. In either case the ELM policy represents a key tool to achieve this, and thus achieve the Governments intent for the organic sector, whilst also delivering the public goods that are the policy objective.    
 

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

•    It seems to be very ambitious, although Defra remains committed to achieving, as we get closer to the deadline, and as direct payments will be phased out, we are concerned that many farm types will suffer, and ELM will not be sufficient to make good the shortfall - particularly on more marginal farms. 
•    Time is pressing to achieve a coherent National Pilot, few details have so far been provided on how it will operate in practice, and how farmers (including those farming organically) will be recruited to the pilot.
•    Although there has been some progress made with the development of specific standards for the SFI, we believe that this piecemeal approach to standards relating to individual measures does not recognise synergies that system-based approaches can deliver. Organic farming delivers multiple public goods simultaneously and this is not being adequately recognised. 
•    There is, so far, no indication that organic will be included in Phase 1 of the National Pilot, so the benefits of an organic approach will neither be tested nor evaluated.  
•    There remains very little detail on how Local Nature Recovery (Component 2) and Landscape Recovery (Component 3) would work in practice.  

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?

•    It depends on the level at which payment rates are set, the obligations on farmers and the extent to which public goods are delivered. If there is to be take up by farmers, advice and guidance will be required. 
•    If payment rates are insufficient to induce the majority of farmers to join the SFI (the governments ambition) then the effective roll-out of ELM will be threatened and farmers will go out of business. 
•    The proposal to use Income Foregone + Costs approach to calculating payment rates is inappropriate for a policy that is aiming to pay public money for public goods. With there currently being no reference to organic farming, and no recognition of the system level benefits that arise from adopting a whole farm approach, based on clear legal standards, it seems that the SFI will be not reflect the true value that organic farming delivers. Something many commentators and consumers are mystified about given the policy objective.
•    It is unclear how the SFI will enable farmers who are already adopting environmentally friendly practices, such as organic farming, will be rewarded.  

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

•    The stakeholder engagement process, through the EEG, has involved a series of meetings where plans and outlines are presented to stakeholders. 
•    There has been insufficient time to respond to the detailed proposals. Preparatory papers have been supplied very close to the scheduled meetings. 
•    Confidentiality has been required, which has meant that it has been impossible to consult stakeholders more widely. 
•    The process of co-design - a key Defra principle for ELM policy - has not been as effective as it might have been, given the very few meetings held between the organic sector and Defra to specifically address how to include organic farming in the policy.   

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

•    An organic scheme should be included since this will secure environmental goods. At present England is not producing sufficient organic food on English farms to meet the domestic market demand, whilst there is also an export potential which should not be underestimated. Organic therefore represents an opportunity.
•    Clear legal organic standards, supported by independent auditing on an annual basis, ensure the simultaneous delivery of multiple public goods as a result of the farming system adopted, whilst also enabling viable farm business to flourish across all organic sectors to supply quality food demanded by consumers both domestically and internationally. 

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

•    An organic scheme within all three components (SFI, Local Nature Recovery and Landscape Recovery) should be included as a means to achieve the intended environmental outcomes. 
•    Recognition of the whole system synergy and building on this through an organic scheme in ELM would achieve environmental outcomes, is simple to operate (based as it would be on existing inspection, verification and certification of the farm on an annual basis), meaning that the farmer is not subject to additional bureaucratic burden, and also would represent value for money in view of the public goods delivered.   

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

•    The scheme must provide multi-annual payments based on the public goods delivered. 
•    Realistic payment rates must be set, which reflect the public good (environmental) outcomes delivered by the land manager. Payment rates should reflect more than simply Income Foregone + Costs since this has been demonstrated to be inadequate. 
•    Payments should be based on the use of effective inspection, verification and certification, with organic being a clear example of a working scheme.
•    Simple to administer and not overly bureaucratic, it would allow prompt payments based on an approach of ‘carrots’ rather than ’sticks’.    
•    Clear advice and guidance must be available - the model of the Organic Conversion Information Service (OCIS) was effective in the past, providing up to 1.5 days of advice to those considering conversion. 

January 2021