Written Evidence submitted by The National Sheep Association (NSA) (ELM0036)



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


NSA agrees with the need for a seven-year transition period. There is a long way to go before we can be confident of the final outcomes for future farm support schemes. It is really important to bear in mind that the next seven years still need to be about learning and fine-tuning schemes, with potentially more radical change where appropriate. Any changes need to be introduced slowly to ensure they have the least impact on businesses.

However, there is a vital need for more detail on what schemes sheep farmers will actually be able to access. As sheep producers and land managers, we require much greater detail if we are to create meaningful business plans for the future. Payment rates and the impact on management practices together with input costs and levels of output will all influence our decision making. We are aware that more detail will stem from pilot schemes already underway and those being implemented soon, but the sooner this information is available, the easier it will be for farmers to prepare and adapt.

It is difficult to comment on the full proposed timeframe as the skeletal bones of the ‘plan’ need to be fleshed out promptly. We look forward to working closely with Defra over the future months and years. 


  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?

The proposal to use an interim ‘Sustainable Farming Incentive’, funded by BPS clawback would aim to fill a gap for many famers not able to access any part of ELMS through the early years. Some form of farm support payment needs to be provided, especially for those more at risk sheep farm types (such as the hills and uplands) who rely heavily on current BPS payments and that BPS payments will be gradually decreasing over the next few years. Proposed schemes for payment for public good seem to by-pass Sheep farming and focus very much on making intensive systems more extensive. The UK sheep industry is not a sector that has huge infrastructure projects or one that needs slurry stores or pollution control. It already has a close relationship with and commitment to creating diverse countryside, living with nature, supporting attractive communities, and bringing in new entrants to farming, and NSA’s strong belief is that this needs farm support programmes that enhance delivery and profitability of this rather than attempt to change it. Again, without any current detail on how extensive sheep farmers will be able to access specific ELMS schemes, it is difficult to adapt ahead of time, resulting in the potential need for more support until appropriate on farm changes can be implemented.


Not sure how this affects the devolved nations?


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


The NSA has been working closely with the ELMS, Pathway and Productivity teams to advise, comment, and influence the detail of the schemes.


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

NSA welcomes the inclusion of key topics such as the exit scheme, incentives for new entrants, the ability to go beyond income foregone when rewarding farmers for environmental and animal welfare management, and the farm investment programme in the transition plan. We would stress the importance of recognition for early adopters of the new schemes.

NSA would simply remind Defra and Ministers that the UK sheep farming sector is one that already engages closely with a form of regenerative farming in many ways and that the sector consists mainly of traditional enterprises where the innovation and technology spoken about in the plans needs to be relative and proportionate to the farming system. With sheep farming already being intrinsically beneficial for the environment, biodiversity, soil health, carbon storage etc, many of the proposed schemes seem to benefit more intensive systems who are looking to switch towards being extensive. Many of our nation’s sheep farmers are already farming in a manner that meets many of the schemes’ requirements. NSA stress that sheep farming is already working harmoniously with nature, producing high-value quality product that needs to be rewarded accordingly so we hope this early recognition will be given.

Ensure tiered scheme that is inclusive for all types of farmers, allowing farmers / land managers to make strategic business decisions over which, and how many schemes to be involved in. Pressure should not be applied to be involved in all tiers of support schemes but flexibility be on the farmer / land manager to make these decisions based on their business.


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

-          Continue to engage with industry on proposed schemes

-          Make objectives clear

-          Balance delivering improvement with rewarding existing good

-          Make eligibility clear

-          Ensure inclusivity for all


NSA would suggest that the ‘list of public goods’ be broadened to include food production, in recognition that society needs access to affordable, quality food that contributes to human health and nutrition. Food production also contributes to the nation’s food security, while activity around artisan foods with provenance is part of our cultural heritage and contributes to the rural economy.

The list of public goods should also recognise the beneficial role of permanent and ley grassland and its management by grazing animals.

NSA suggests that schemes allow inclusion of tenant farmers. Schemes should not dissuade short-term grass lets, for example, but should give tenants greater security and confidence to invest in long term best practice even on tenancy agreements.


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

Need to keep it simple – reduce paperwork burden, easy to access, easy to understand, simple application process, 

Provide easily accessible support and advice, especially during implementation phases. 



January 2021