Written evidence submitted by Historic England (ELM0028)

Historic England is the government’s statutory adviser on the historic environment, championing historic places and helping people to understand, value and care for them. HE is an executive non-departmental public body, sponsored by the Department for Digital, Culture, Media & Sport.

Heritage is identified as an objective under the government’s 25 Year Plan, under the umbrella of enhancing beauty, heritage and engagement, and we consider ELM to be the primary mechanism for the delivery of this objective for the historic environment.


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


Historic England does not have specific expertise in direct payments but considers it should be possible given the relatively long timescale for the national roll out of ELM.  We do, however, have concerns that the complexity, scale and the somewhat iterative nature of the development and introduction of ELM (e.g. multiple phases of tests and trials, pilots and SFI 22 running concurrently). We feel that this might be an obstacle to sector engagement and ultimately, to take up. The overlapping timescale of many of the ELM activities (e.g. tests and trials and pilots running in parallel with scheme development), mean that the results of these will not necessarily be available to feed into the decision-making process at the appropriate times. This adds to complexity and uncertainty.


Conversely, we have concerns around the comparative lack of ambition in relation to the first phase of the pilot in targeting only 1,000 land owners from a wide range of industry sectors, including many who do not have a track record of scheme participation, and may therefore not be the most receptive to the pilot



  1. 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?


We haven’t seen sufficient information regarding the SFI payment rates and modelling scenarios to be able to offer any detailed commentary, but our understanding is that the rates for SFI have been based on Countryside Stewardship payment rates, which form only a fraction of farmer support under current provision. If this is correct, this therefore raises concerns as to whether SFI will be a viable measure alone


We also note that the SFI standards are targeted as specific sectors of the farm industry relating to land holding/management, and don’t include provision for industries such as poultry or pig farming.  We consider it unlikely therefore that the SFI will be able to offer viable support measures across the industry.



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


As a stakeholder involved in the design of ELM we have found the process complex and difficult to navigate.  Historic England was only invited as a stakeholder relatively late in the process, and for the large part engagement has been limited to Defra arms-length bodies, with only very high-level engagement with wider industry stakeholders and land managers, giving rise to a lot of uncertainty and confusion.


On some levels Defra has engaged well with the wider sector – the high-level sessions that were run to accompany the ELM policy discussion document being the obvious example, but this has not been followed up with substantive detail about scheme components and timescales in the run up to the national pilot. The national pilot is due to be launched in March 2021, yet very little information is available to the wider sector and to land owners with only just over a month to go.



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


We consider that simplicity and appropriate payment rates are key factors in making ELM an attractive business choice


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


Again, we consider that simplicity of the application process will contribute to the uptake of agreements and reduce the burdens on farmers.  We also consider that longer term agreements (e.g. 10 years +) for the local nature recovery and landscape recovery components of ELM are essential to secure appropriate environmental outcomes and reduce administrative burden and costs, as these promote long-term behavioural change and sustainable outcomes.


We are concerned that the complexity of SFI e.g. amending standards year on year and allowing farmers and land managers to opt in and out of particular standards, will add yet more uncertainty and administrative costs. We would much prefer simple, easy to understand measures that apply universally.


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


The most significant failure of previous schemes has been the ‘renting out of outcomes’ as a result of the short-term nature of agreements and the changing priorities from one scheme to the next.   As a result, many environmental gains are lost at the end of an agreement, without a requirement, natural progression or incentive to retain these into a subsequent scheme.


A success of earlier schemes, particularly Environmental Stewardship, is having an entry level that is attractive to a wide audience and includes a range of options available to applicants.  The Entry Level scheme, which achieved 70% coverage, delivered beneficial management for a wide range of heritage sites.


Another success from current and previous schemes has been the uptake and outcomes relating to the maintenance and restoration of traditional farm buildings.  These options have been well received and deliver outcomes for habitats, landscape and heritage, alongside the obvious opportunities for farm business use or wider diversification.


Another success of previous schemes, certainly in relation to heritage, but also more widely in environmental terms, is the successful invocation of the polluter pays principle. In short, agriculture and rural land management fall outside the spatial planning system, yet their effects can be no less detrimental than development and other processes which are tied to a system of consenting and environmental mitigation. This is evidenced by the number of nationally important Scheduled Monuments on the Heritage at Risk Register due to land management practices in comparison to the comparatively small number affected by development.


It is important therefore that we retain (via the SFI, Nature Recovery and Landscape Scale Recovery) the principles of avoidance/mitigation in respect of the environment impacts, but also that of “no detriment”. This basic condition – which was instigated in Environmental Stewardship and retained within Countryside Stewardship - ensures that achieving one environmental outcome does not prejudice another. In our view, this has been one of the key improvements from the first Countryside Stewardship Scheme under which historic landscape features, especially scheduled monuments, were more likely to be in unfavourable condition when falling within agreements than those outside them.


January 2021