Written evidence submitted by the Rare Breeds Survival Trust (ELM0033)




Inquiry into Environmental Land Management and the agricultural transition



Introduction: Rare Breeds Survival Trust (RBST)


RBST exists to conserve our native livestock and equines. Since we came into being in 1973, no native breed has gone extinct.


We deliver our objectives in a number of ways, firstly by promoting the uses of the breeds, primarily the provision of food, clothing, and transport, secondly by working with government to secure support for the public benefits the breeds provide, such as conservation grazing and landscape quality, and finally through carrying out our own conservation breeding projects.


RBST is overwhelmingly supportive of the governments policy on ELM and the agricultural transition. It is the right thing to be doing and, if seen through, it will encourage a shift to a lower input, higher welfare more entrepreneurial livestock sector in which native breeds should thrive.


We particularly welcomed the Agriculture Act’s introduction of the power for government to provide financial assistance for the conservation of native livestock and equines.


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



From what we can ascertain, the timeframe for setting up the national pilot does seem feasible.


The roll out of ELM and the phasing out of direct payments is the bigger concern. Whilst acknowledging that ELM is not a replacement for direct payments, the availability of ELM payments will inevitably have an impact on farmers’ overall incomes and their business planning as direct payments are phased out.


It is therefore essential that firstly, there is transitional support to ensure no farm goes out of business purely because BPS is phased out faster than income can be recovered from ELM and other sources. Secondly sufficient details of the options and payment rates under ELM need to be made available to enable farmers to engage in proper business planning as soon as possible. 



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 SFI is not a support mechanism. Any farmer treating it as such, or as a variant of BPS, is going to face real challenges as the new policy is rolled out. The SFI is a mechanism for rewarding farmers for the provision of specified public goods. Farmers need to be approaching it from the perspective of identifying the public goods they can provide, and at what cost. This analysis should then be factored into the overall business plan.


However, and as noted, all this depends on having the information, in terms of both the details of the options and the payment rates, to make informed decisions. This is not yet available and there is no indication when it will be.


Page 33 of the ATP notes the environmental benefits provided by our native livestock, and states the aspiration to support them through ELM, but the there is no indication of when or how.




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


Engagement has been difficult, though the situation has improved significantly of late. Changes in management within Defra have resulted in a clear desire to engage farmers and land managers much more widely than was initially the case.


Nevertheless, although native livestock and equines are one of the public goods to be supported under s.1 of the Act, there does not appear to be an individual or team directly responsible for delivery. As such we have been finding we have to engage with a variety of officials not all of whom are easy to identify.


It is difficult to ascertain the extent to which this engagement has influenced the design of ELM or the transitional arrangements. Firstly, the full design of ELM and the transitional arrangements is still far from clear, and secondly most of what do know feels as though it has been presented as a fait accompli requiring ratification rather than the result of any co-design.



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


The payment rates need to be sufficient to make ELM attractive compared with the alternatives, primarily intensification or diversification. This requires payment rates of more than income forgone plus costs.  If your income is next to nothing, then income forgone is not much of an incentive.


Payment rates must provide a sufficient incentive to participate, reflecting the true cost of achieving the particular objective in the particular location, including transaction costs and the costs of advice.

With less profitable holdings, the incentive needs to be enough to encourage the land manger to stay on the holding and deliver what is required.

With more profitable holdings, payment rates need to reflect the full extent of the income foregone. In parts of East Anglia, for example, this could be significant.

Awareness of the benefits of the options and the availability of advice on the practicalities are also important.  For example, keeping native livestock and equines, if done with the right breed in the right place and at the right density reduces input costs, because the animals can live outdoors on grass, and with higher welfare standards that keep down veterinary and medical bills. In addition, with good marketing emphasising provenance and traceability, premium prices can be charged.  All this is in addition to the public goods provided in terms of biodiversity and landscape quality.  This is just one example of the ways in which the provision of public benefits can also deliver private benefits. Other examples would include the maintenance of soil and water quality and the provision of pollinators.


The threshold below which land managers are ineligible to apply to participate in ELM should be kept low. Many of those who conserve our most genetically important livestock, and who we need to continue to do so if we are to maintain genetic diversity, operate on a small scale.

There must be no “Active farmer” type tests. People keep important native livestock and equines for a range of reasons, many of them unconnected with farming, but they are just as deserving of support to do so as farmers are. They are providing the same benefits.

The Government has said ELM will consist of three components.

Component 1 should specifically be broad and shallow, open to anyone capable of delivering the environmental benefits, including the conservation of native livestock and equines.

Component 2 should promote local engagement and a sense of place. Many of our native livestock breeds are strongly associated with particular areas; they were bred to meet certain human needs in a specific location. Gloucestershire Old Spots pigs in Gloucestershire and Dartmoor Ponies on Dartmoor are the perfect agri-environmental example of the “right thing in the right place”. 

Promoting this local connection will directly encourage the conservation of the breeds concerned but will also bring other advantages in terms of helping to promote a greater sense of place and encourage local brands.

Many environmental benefits are best delivered at scale, and Component 3 should therefore include specific incentives for farmers and other land managers to work together, backed up by facilitators able to get projects off the ground.

Advice is important, but to be effective it needs to take different forms according to the circumstances.

Most farmers will already have their own trusted sources of advice, both formal and informal. Government needs to be alert to the risk of crowding out what already works reasonably well.

Generally, farmers and land managers say the most helpful advice comes from obviously trusted sources such as other farmers, farming organisations and the farming press. Government’s role here is primarily facilitation, supporting events at which knowledge and best practice can be exchanged and discussed. The AHDB’s Monitor Farms are an example that could be built upon.

In addition, there is an established network of agronomists, land agents and farm business advisers who will be able to provide professional advice. Government does not need to duplicate this, just ensure that the payment rates under ELM are sufficient to enable farmers to afford the advice.

The role of directly provided government advice should be limited to specialist technical advice found in Natural England and the other agencies.


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


An element of bureaucracy is inevitable. ELM is concerned with the management of natural processes and the distribution of significant amounts of public money, its not unreasonable for there to be a degree of control.


In terms of securing compliance, we would urge that the recommendations in Dame Glenys Stacey review are adopted. An approach which is supportive of farmers needs, flexible according to the circumstances and incentive led is far more likely to yield results than the penalty focussed approach we saw under the CAP.



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


Our native livestock and equines are a fundamental part of our native fauna, aside from the environmental and ethical obligations, we have an obligation to conserve them under both the Convention on Biodiversity and the Sustainable Development Goals. In its most recent report, the JNCC found that we were falling short. 


ELM is one the keyways in which we can address this. That requires it to be much more ambitious than current agri environment schemes. Firstly, it needs to extend to all our native livestock, including pigs and poultry.  Secondly, it needs to support the full range of ecosystem services that native livestock and equines provide us with. They of course have an intrinsic value as a part of our biodiversity, but there is much more.


There are the regulating services native breeds provide. Our native breeds play an important role in the development and maintenance of natural habitats and increasing biodiversity. Bred for our landscape, native-breed cattle helped create the pastures and meadows we now cherish; native pigs can be used in woodland management to increase biodiversity and play a key role in arable rotations. We need incentives to encourage farmers and other land managers to use them in preference to larger commercial breeds.

Then there is the cultural side; native breeds are part of our national identity and heritage. White Park cattle were brought to Britain when it was still joined to the European mainland – well before Stonehenge was built. The Large White pig is the cornerstone of pig breeding across the world. We expect Government to help promote and conserve our built heritage, why not our livestock heritage too?

Specific consideration should be given to commons; the most widespread form of land managers working together. Commons include large tracts of our most well-loved and ecologically rich landscapes including Dartmoor, the Lake District, Yorkshire Dales and Shropshire Hills.

The experience of commoners and commons owners under the CAP was not good. Because successive CAPs never really acknowledged the existence of commons, the regulations made within that framework did not fit well with them. Full engagement with Commoners Councils and Commoners Associations is essential.  

In practice much of what can be delivered under ELM will be done on common land, so it needs to be designed with commons in mind.

Christopher Price

January 2021