Written Evidence submitted by The Game & Wildlife Conservation Trust (ELM0034)


The Game & Wildlife Conservation Trust  

We are a leading, independent UK wildlife conservation charity conducting scientific research into Britain’s game and wildlife to enhance the British countryside for public benefit.  We use our research to provide training and advice on how best to improve the biodiversity of the British countryside.  We employ 22 post-doctoral scientists and 50 other research staff with expertise in areas such as birds, insects, mammals, farming and farmland ecology, fish and statistics. We undertake our own research as well as projects funded by contract and grant-aid from Government and private bodies. The Trust is responsible for a number of Government Biodiversity Action Plan species and is lead partner for grey partridge and joint lead partner for brown hare and black grouse and has advised Defra on past environmental stewardship scheme options and option management such as conservation headlands, beetle banks and wild bird seed mixes.  In addition the Allerton Project, our demonstration farm in Leicestershire, undertakes research into the effects of different farming methods on wildlife and the environment, and shares the results of this research through educational activities for practitioners and the public. 


Terms of reference

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

1.1 It is as long as ELM remains an adaptive-based policy going forward and as long as the scheme design, particularly in terms of option remuneration and outcomes, learns from previous schemes in order to maximise uptake and farmer engagement.

1.2 Whilst the component parts of the structure are now set out, the details of what options will be available within each part and more importantly the payment rates are not yet known and this is a source of concern in the farming community in the face of a reducing BPS.

1.3 However any delays in the full roll-out of ELM needs to be reflected in a delay in the continued phasing out of direct payments as one is to replace the other; this would protect the viability of those farms most at risk of the conversion to public money for public goods. We understand why there might be political unwillingness to slow the pace of CAP reform measures, but Government should consider putting in place interim measures where phasing is not aligned.  

1.4  In addition it is important that the right advice is available, accessible and suitably signposted.  We know this is a Defra ambition but we would like to emphasise that our experience is that appropriate advice and guidance is vital to achieving ambitions and desired outcomes (see 6.8 below).


  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?

2.1 Until we know what will be funded and what the payment rates will be, this is impossible to judgeOnce details are known Government should carry out the pre-launch assessment across a small number of diverse enterprises to gauge the financial impact before full roll-out.

2.2 Payments rates will be vital in achieving the level of participation desired and therefore ensuring it becomes the viable support measure before full ELM roll-out.

2.3 If core elements of the scheme are to be launched in 2022 (alongside the Pilot) details need to be made available before the planned June 2021 to give farmers and land managers time to incorporate aspects of the initial focus on soil, nutrient and integrated pest management into their cropping plans.  Experience is that inevitably planned timescales slip.

2.4 The core elements identified (soil, nutrient, integrated pest and livestock management) for the initial phase may not provide the support for all farm types until full roll-out.  Additional support through the Farming in Protected Landscapes may protect some of the more vulnerable farmers during the transition period but the detail has yet to be published.

2.5 We are very concerned that farmers with extensive lowland pasture who are heavily dependant upon BPS will be forced, by financial hardship, to plough up this habitat, which is important for a range of environmental services, but most particularly as breeding habitat for lowland waders. Rules protecting Permanent Pasture under CAP “Cross Compliance” measures have disappeared, and whilst there remains a need for the farmer to carry out an Environmental Risk Assessment this ONLY protects the pasture if it contains less than 25% perennial ryegrass and clover. Virtually no extensive pasture (aka “low-input grassland”) will fall into this category.

2.6 The potential to lose this habitat due to declining income is exacerbated by payments being made for bio-energy fuel stocks such as maize. Payments are high, supported by “green” renewable energy payments, which often exceed the income that arable crops can produce. This creates a perfect storm for the loss of this type of grassland.      

2.7 We are concerned that many believe that changes to the BFP will result in some farmers on marginal land abandoning their farms, at least in terms of food production.  Our experience is that it is far more likely for farmers to pursue all opportunities to remain in their profession and that the pursuit of income will result in the intensification of production in these areas with a real risk of environmental degradation occurring.


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

3.1 Defra has consulted widely on the ELM proposals, and the Test & Trials and national pilot are part of the co-design approach. We applaud the level of engagement given to stakeholders and the willingness to test exploratory concepts rather than present fully formed ideas.

3.2 Given the level of engagement and the wealth of knowledge and experience contained in the Stakeholder Engagement Groups now, Government should be in a position to rapidly draw this together and present more granularity. 

3.3 However there have been criticisms that the Test & Trials were generally NGO-led consortia, even though many involved the active participation of farmers, with very few ‘pure’ farmer-led projects and so the national pilot with its aim to incorporate 5500 farmers will be a key time in understanding whether lessons have been learnt from previous schemes. 


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

4.1 We were encouraged that ELM reflected many of the suggestions made by the GWCT and in particular that it is voluntary, open to all farmers and pledges to support farmers to deliver public goods

4.2 It also draws on the key message of the Sustainable Food and Farming Scheme, co-authored by the GWCT, that a farm’s environmental and business successes do not exist in isolation and that conservation should be seen as another business income stream within the farm accounts and its ‘production’ and ‘delivery’ reflect this.

4.3 The Sustainable Farming Incentive is correctly targeting measures which deliver the twin outputs of business efficiency and environmental improvement.  This should make it attractive to most farm businesses ensuring the widespread uptake needed to achieve national outcomes.  

4.4 The payment rates will be important in achieving this ambition; Government’s thoughts in this regard are as yet unpublished although we understand will include a cost incurred and income foregone approach, supplemented by a reward element. The reward element is likely to be linked to “public money for public goods” and be more prevalent in the Local and National Nature Recovery components. Early indications from the Tests & Trials on payment rates which only provide money to cover income forgone and costs incurred show that this formula provides a very weak incentive for farmer engagement and therefore is inadequate to fulfil the Governments, and Societies’, ambitions for ELMS.

4.5 We favour thereward’ payment to encourage best practice delivery, but this could also be used to support a ‘maintenance’ payment where farmers have already provided the environmental goods being sought.  It is important that existing habitats are fully valued to ensure that those who already provide the features desired are not penalised (this is relevant to the points we made in 2.5 and 2.6 about protecting lowland pastures/hay meadows). This is of critical importance and one of the lessons that should be learnt from the past (see also answer to Q6).

4.6 We are also concerned that Defra has yet to establish how best to reward a joined-up, system-based approach to conservation. We know that the individual measures can support wildlife recovery, soil health and carbon capture as they have been developed over the course of the last 30 years (since the first agri-environment scheme in 1987) but true success is rarely achieved unless the separate measures are appropriately combined (linked) to create an impact greater than their individual parts. We hope the final details of the scheme will recognise this.

4.7 As we have said throughout the evolution of ELM, farmer motivation remains key to its success (i.e. take up) and therefore the ability to deliver policy goals. 

4.8 Consequently we would highlight the need for ELM to:

  1. focus on outcomes rather actions per se
  2. sufficiently reward farmers for the outcomes delivered – recognising all the public goods delivered,
  3. avoid too prescriptive scheme options – farmers understand and know their land better than any Official,
  4. allow for flexibility in scheme design and outcomes delivery - to allow for individual farmers to work ELM into their business model, and
  5. view the farm holistically so that all the farm’s natural assets are considered in policy delivery. There should also be some consideration to reward certified farms who are delivering holistically e.g. organic or LEAF Marque.

4.9 These points are based on input from our members that we sought as part of our response to Defra’s ELMS consultation in July 2020.  To quote from our response “Common themes for encouraging participation were the need for appropriate financial reward and adequate funding, flexibility (option design, start dates etc.), simplicity (in administration and scheme delivery), farmer/land manager engagement and trust. Overly prescriptive rules, poor scheme administration, delayed payments, reducing excessive regulation and uncompromising inspections with unnecessary focus on minor infringements were key barriers to participation.”

4.10 That said in answer to Q6 we also flag that the habitat only approach to species conservation has been less than successful, particularly for species of conservation concern, and so this needs to be challenged. 


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

5.1 Given that it is a stated ambition “In 2021 … to improve how existing schemes and regulations operate” (Defra The Path to Sustainable Farming: An Agricultural Transition Plan 2021 to 2024
November 2020) we felt the best way to answer this was to give an example of the poor administration of the current scheme.  Clearly such situations will not inspire farmers to join future schemes.

5.2 Scheme administration needs to improve.  Our research and demonstration farm’s Countryside Stewardship application for 1st January 2021 was submitted to the RPA by 31st July 2020.  It was returned late, after a key milestone date for a conservation activity.

5.3 In addition, and even more concerning, is that the application we made was returned with a substantial but unjustified revision. We have been involved in the design of Agri-environment schemes since their inception, took independent expert advice on our application and know our own farm better than any office based assessor.  This does not inspire us that “transitional” approaches are as yet any different from the maladministration which so be-set the previous schemes. Farmers are currently optimistic about the ELMS, but this will be continuously undermined while old attitudes and approaches continue to prevail.

5.4 There are also contradictions within the options that may discourage farmers to tackle a more regenerative approach such as restricting the ground that cover crops and herbal leys can be sown on.  Such restrictions create unnecessary complications for the farmer.

5.5  These examples demonstrate that it appears that Defra/RPA still has a long way to go to improve scheme administration and if revising individual scheme applications and implementing unnecessary restrictions is the “change [to] the tone of Rural Payments Agency interactions with farmers to make them more constructive and advisory” (Defra November 2020) we are concerned.



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

6.1 In many ways we would regard this as the first question that should be asked as Brexit was considered an opportunity to devise a domestic scheme that avoided all the pitfalls and regulatory red-tape associated with the CAP.  Those lessons must be learnt – not only in scheme design but also in scheme administration, advice and regulation.

6.2 Systematic fraud in the claiming of CAP support payments is not disputed, but this was an issue associated largely with other EU countries. The level of inspection in England going forward needs to be proportionate to the threat faced.

6.3 We also need to learn lessons from the success (and failures) of previous agri-environment schemes in delivering intended outcomes.  The UK Biodiversity Indicators demonstrate that the current approach of protection and prescription has largely failed to arrest biodiversity decline. 

6.4 ELM needs therefore to address the reasons for this disconnect between habitat provision and species recovery, as it is one of the Government’s principal methods of delivering landscape-scale biodiversity improvement (alongside designations and Nature Recovery Network ambitions).

6.5 A more enlightened approach to agri-environment policy is needed based on greater flexibility and adaptive management to species conservation.  To date policy has assumed that species conservation depends on the provision of its habitat alone. This is not always the case as species’ lifecycles can be compromised by other factors such as climate change, pesticides or predation. Successful conservation policy should be flexible enough to address these other factors too.  

6.6 Furthermore in 2010, Sir John Lawton called for agri-environment policy to promote “more, bigger, better and joined” and the establishment of farmer clusters funded by the Facilitation Fund was the realisation of the ‘joined’ ambition. The current ELM proposals promise to “look to run a further round of the Facilitation Fund.” Facilitation funding neatly combines the aim of landscape scale recovery envisaged by Lawton and farmer motivation/empowerment set out by the Minister, so we hope this intention is made more concrete in due course.

6.7 As alluded to in answer to Q4, farmers who have undertaken habitat creation and maintenance, such that there is a value in the quality and maturity of that habitat, should not be precluded from entering these into ELMs provided they are delivering the public goods desired. We accept that it is not ‘good value for public money to pay for the creation of habitats or features already in situ from previous schemes (or indeed through private investment), but a maintenance payment is we believe justifiable and desirable given the risk of existing habitat being destroyed in order that financial reward is gained by re-creating it. This is in nobody’s interest.

6.8 The other key factor in scheme success in our experience has been the provision of advice and training.  There are three areas in which we see this as particularly important:



29th January 2021