Written evidence submitted by the University of Gloucestershire (ELM0046)

Response to the EFRA Committee consultation by the CCRI


Thank you for providing the opportunity to submit evidence to your Inquiry on Environmental Land Management and the Agricultural Transition. If you feel it appropriate we would also be happy to give oral evidence.

Context - Introduction to the CCRI

The Countryside and Community Research Institute (CCRI) based at the University of Gloucestershire conducts and publishes world-class, agenda-setting research into agri-rural and environmental policy and practice, with potential to influence policy actors, practitioners and decision makers at all levels, from local to global. Our approach over the past decade has been to embed and develop a robust, multi-disciplinary, evidence-based and policy-relevant research agenda focused upon key global priorities. Sustainability, transformation, co-innovation, multi-level governance and resilience have been unifying themes. Our objectives are to:

1)      be a centre of excellence in relevant and impactful research;

2)      create an intellectually stimulating research environment;

3)      deliver a valued postgraduate student experience through high quality research degrees and research-led teaching; 

4)      deliver impact and widen access to our work via effective stakeholder engagement, communication and dissemination; and

5)      develop and foster international collaboration that reflects the breadth and depth of our global outreach and evidence-based approach.

We have an international reputation for high quality food, farming, rural environmental, climate change and community research. We engage with a wide variety of partners in the UK, Europe and beyond in natural and social/ political science, policy and practice communities.

Consultation questions and responses

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

The phase out of Direct Payments as outlined in the Agricultural Transition Plan appears straightforward and should be achievable by 2027 using the arithmetical process outlined. The full roll-out of ELM is more challenging as it will need to be available equally across the country to suit different agricultural types and settings.  There is a risk that as the Direct Payments are phased out, the full roll out of ELM is either delayed or not equally available to all.  Sectors likely to be especially disadvantaged are those where the RPA has struggled in the past to fulfil obligations, such as farm businesses with complex legal arrangements, also heavily CAP-dependent marginal areas like the uplands, and agreements involving common land.  These are also situations where farmers bear responsibility for managing significant natural capital assets.

During this period of considerable change, it is vital to assess the level of engagement, awareness and understanding among farmers, foresters and land managers (FFLs) of the changes being introduced and the policy ambitions underpinning themCCRI has undertaken early testing of social indicators that can be used to assess the quality of agreement-holders engagement with a scheme, and its social outcomes – for commitment, understanding and well-being (Mills et al 2020). A study by CCRI into collaborative mechanisms identified a number of specific factors that will influence farmer and landowner engagement in ELM components 2 and 3 (Ingram et al 2020). It is critical to gain a better understanding of these engagement factors and social outcomes from the outset as increasing evidence shows that they impact environmental outcomes and, in particular, influence agreement holders willingness to undertake environmental activities in the longer-term. Larger-scale testing in the National Pilot should collect sufficient data to develop a robust and statistically-valid set of social indicators and ensure confidence in the methods used to measure them.

  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?

Under SFI there is a need to embed some basic standards across the whole holding, and lessons can be learned from the cross-compliance mechanisms that accompanied the Basic Payment Scheme. For example, agreement holders should not be permitted to actively damage walls and hedgerows irrespective of the elements of the ELM scheme that they have signed up for. However, experience with cross compliance also showed that some benefits to environment (e.g. for soils) were weak and rarely enforced, and that farmers often followed a tick-box mentality in their approach to compliance – only doing the minimum necessary (Ingram et al 2020), suggesting that conditions also need to be accompanied by other mechanisms, to ensure better outcomes.

SFI should include environmental assets that can deliver across the broad spectrum of the 6 goals underpinning the ELM scheme.  The issue of whether it is a viable support measure for FFLs is unclear, as there is limited detail on financial and legal aspectsThis lack of detail already puts sensitive and marginal land at risk, as FFLs will make decisions now on how to manage this land both before and once direct payments are reduced. Further support to help FFL planning, both financial and advisory, would be a welcome addition to the current ongoing Defra activities.

In relation to the issue of advice, and whether the farmer/land manager should pay for advice received under SFI, the Catchment Sensitive Farming (CSF) initiative offers interesting insightsRecent research (Chivers et al 2021) explored whether farmers are willing to pay for CSF advice, which is currently free of charge. An online survey of farmers (n = 221) and telephone interviews of farmers (n = 60) and farm advisors (n = 50) from across England suggest that the vast majority of farmers are not willing to pay for this advice. Just 10% of online consultation survey participants expressed some willingness to pay for CSF advice. Qualitative analysis revealed that this reluctance to pay for CSF advice is, in part, because environmentally-led advice is not deemed commercially relevant enough to warrant payment, particularly in a situation of ongoing financial constraint. In addition, many farmers do not engage even with free advice; if this advice was no longer free, it would run the risk of the so-called 'hard to reach' becoming the 'impossible to reach'. A move towards an exclusively charged-for advice model in the SFI could be harmful to both the environment and farmers, in particular, during the biggest transition period that farmers have faced since 1947.   

In an evaluation of the Countryside Stewardship Facilitation Fund (CSFF) 25 facilitators were asked whether farmers would be willing to pay for one-to-one advice (Mills et al 2020).  More facilitators felt that members would be willing to pay for such advice than not, but on condition that such advice would have to financially benefit the farm business.  Those facilitators who thought there would be a low or very low willingness to pay for advice referred mainly to smaller farms whose financial margins were tight. This is particularly likely to be the case if members have been receiving some advice for free from various NGOs, to date

Defra-funded research undertaken by CCRI with Forest Research to inform the Tree Health Pilot involved co-designing new options for tree health grants together with stakeholders. This identified a need for other elements to be included in order to encourage FFLs to apply, such as advice and guidance at different stages in the process, and funding for other activities such as maintenance grants for restocking after felling, due to a pest or disease outbreak, or group schemes where owners of smaller woodlands or trees outside of woodland could apply collectively for a grant. Farmers have specific needs associated with tree management, which assumes increasing prominence in the context of the UK’s net zero targets. However, farmers are often not linked in to forestry/tree networks so are not well informed about tree health issues. Given that most farmers will have woodlands, or trees outside of woodland, on their land, it is crucial that they are engaged in management for tree resilience and have the necessary information and support. Aligning new tree health grants to ELMs will help to encourage uptake from farmers, but raising awareness and engagement in woodland management remains a challenge.


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

Much of the focus in Defra’s public engagement has been on a promise to keep things simple and reduce the amount of paperwork.  Our research suggests that complexity should not always be seen as a negative, for farmers and for scheme uptake. ELM scheme outcomes should deliver substantial societal benefits, which may include a degree of complexity. The problems of complexity can be addressed and overcome: some types of land, e.g. common land, are complex in their legal status and the nature of land management, and yet previous schemes have had some success with commons.  The specific needs and opportunities for different types of land should be recognised and embraced and schemes should promote the robust administrative governance that this requires.

There has been little clarity in policy documents concerning the role and value of advice: this term is used generically and rather simplistically. It is not always clear what types of advisers are being referred to and what sort of advice they will be delivering. We recognise that advisers can have many different roles, at different stages of the process: from initial encouragement and information-spreading, to detailed negotiation during sign-up, and to ongoing advice and feedback once agreements are in place. Also, FFLs will have very different advisory needs and concerns depending on enterprise type and structure, location, levels of prior knowledge and experience in ELM and pre-existing attitudes towards networking and learning from their peers and other sources. 

The question of when advice is most likely to be needed by scheme participants was asked as part of the recent CSFF evaluation undertaken by CCRI researchers (Mills et al, 2020). A majority of FFL respondents agreed that advice was valuable to help identify the environmental potential on the farm, before making an agreement; that advice is also required during the implementation stage, particularly in the first year and at a mid-way point as a health check’, and finally towards the end of the agreement to discuss future priorities.

Providing free or subsidised independent advice to support ELMS applications and implementation seems a key opportunity to ensure that the scheme will deliver real public benefit. Involving and upskilling farm advisers and agronomists in ELMS elements is important, particularly for SFI which seems likely to include nutrient management and good husbandry within the higher standards. In order to meet government’s longer-term environmental targets, it will be important for all FFLs to take up these standards over time, so advice to support this is clearly in the public interest even though in the short-term, it might appear non-essential to farmers (and thus not worth paying for). A recent CCRI review of advisory skills for soil management identified a significant shortfall in expertise and skills among FFLs in England (Ingram and Mills 2019).


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

We support the goal of maximising societal benefits from the management of all environmental assets in a cost-effective way. Our research (e.g. Dwyer, 2013; Dwyer et al, 2020) indicates that the ELM scheme will achieve more and deliver better outcomes if it sees nature and culture as two sides of the same coin and fully embraces the concept of social-ecological systems and biocultural heritage, whereby environmental assets embody both natural and cultural elements. For example, virtually all the habitats associated with High Nature Value Farming are the product of co-evolution of nature and farming practices over many centuries. A traditionally-managed hay meadow, semi-natural grassland, or moorland is as much a cultural asset as a traditional farm building, field boundary or archaeological site.  Encouraging active connection between farming as a business and environmental asset management is a critical part of ensuring sustainable and resilient outcomes, because otherwise, landscapes fragment into zones of intense production and areas of under-management which threaten ecosystem functioning and cause continued biodiversity loss.

Numerous CCRI evaluations of local environmental initiatives (e.g. in Exmoor, the Upper Thames, Marlborough Downs, the SW uplands, Upper Teesdale, Forest of Dean, South Cambridgeshire) demonstrate the need for flexibility in the approach to determining local priorities, based on the local social-ecological situation and the environmental assets within each area (Dwyer et al, 2020). The nature of the environmental issues being addressed and the range of actors involved in their identification and management should determine the appropriate scale of decision-making (Dwyer and Hodge, 2016). Priorities could be determined using:

         Integrated delivery. This approach has been tested in the WILD project in the Upper Thames (www.ccri.ac.uk/WILD) and has shown that combining agri-environment, Water Framework Directive, flood risk reduction and private goals (water company) as well as other local strategies (tree planting) can be effectively achieved by joined-up local planning and action among farmers and local communities, stimulated and facilitated by a bespoke local advisory team.

         Local Nature Partnerships which work well and are actively delivering collaboration between a range of partners. These can act as local data hubs to monitor progress against the range of outcomes that ELMS is seeking.

         Other existing landscape-scale projects – e.g. CSFF, Living Landscapes and some Landscape Partnerships under NLHF, so long as the partners cover all relevant actors and responsibilities. In CSFF, its approach to determining priorities has been shown to work well and has the added benefit of developing a sense of shared ownership in implementation (CSFF Phase 3 Evaluation Report, CCRI).

         Common Land management structures. Commons cover only 4% of England but contain 20% of all SSSIs, 86% are within protected landscapes and they represent 39% of all Open Access land, delivering many public benefits. Securing environmental management agreements on commons has proved difficult and challenging in many places. Commons Development Officers in the Glastir scheme have supported enhanced outcomes (Brackenbury et al 2012)

         National Parks and AONBs, which have particular advantages of resources and plans which can aid ELMS targeting and decision-making. Most protected landscape area Authorities work closely with the farmers and landowners within their boundaries, facilitating discussion and agreement on local priorities for ELMS.

         The significant number and range of those currently delivering ELMS tests and trials, which is testament to the capacity of local actors to come together to support this important task. Social capital established through this experience should be recognised and rewarded in the approach to the national ELMS. CCRI’s seminal work on encouraging positive environmental behaviour among farmers and land managers (Dwyer et al 2007; Mills et al, 2016) noted that policy decisions significantly affect local motivations and that when actors feel disenfranchised, they are much less likely to respond positively to subsequent government schemes. The test and trials pilots represent an investment by stakeholders that has raised their expectations of what ELMS might deliver: government should consider carefully how it can avoid widespread disappointment in the eventual offer.

The CCRI has longstanding links with landscape evaluation and management, and supports the holistic approach of the Council of Europe’s ‘European Landscape Convention’ (ELC) to which the UK is a signatory (and to which CCRI research has contributed, in past decades). ELC emphasises the interdependence and importance of active citizen participation in the protection, management and planning of current and future landscapes. In this spirit, we recommend that within any locality, time should be allocated and devoted to understanding the values and meanings attributed by all stakeholders to different environmental assets, natural and cultural. The ELM scheme should avoid predetermining the local asset base by over-reliance on invariably partial national or regional datasets, which rarely encompass social and cultural elements. In a spirit of learning and co-design, ELM should enable ongoing research to create frameworks for local priority-setting, at least as part of the National Pilots for components 2 and 3.

More broadly, we are concerned that the necessary jointness and synergies in achieving both environmental management, and sustainable food production through good farm husbandry (the win-wins) are not recognised or promoted strongly within the Transition plan and associated working documents on ELMS. Emphasising this link should be an important part of the policy messaging to all FFLs. ELM components need to have demonstrable synergies (shared tools, compatible targets and metrics) with other policy instruments affecting farming, including incentives for increased productivity and regulations and advice for more sustainable production (e.g embracing retailer-led and market-oriented schemes, taking account of flood risk strategies and climate commitments such as net zero by 2050). The Defra Transition plan document presents a bundle of different strands of government activity for different aims, and all of these impact farms and farm business strategies in different and potentially contradictory ways. What is missing is a unified vision of the whole – a working definition of sustainable agriculture and land management acting as a clear guide for FFLs to what government is ultimately seeking to encourage. CCRI research has previously identified how lack of a positive overarching vision for agriculture can leave actors within the sector working at cross purposes, at local level. This was one of the key motivations for co-development of the Integrated Local Delivery approach (Short, 2010).  


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

A recent Rapid Evidence Assessment of Collaborative Mechanisms for the ELM scheme for Defra by CCRI and Exeter University (Ingram et al, 2020); and a study of 15 case studies (Wheeler et al., 2020) found strong evidence for the following:

• Facilitators are important but play different roles and accordingly need to have a number of attributes (expertise, skills, mediation). Facilitators help in developing trusting relationships between group members and are important in motivating and enthusing members to achieve agreed goals.

It is important to build on pre-existing networks and projects, and target, facilitate and support existing groups which already demonstrate some level of social capital (see Mills et al, 2008)

• Large-scale coordinated schemes face institutional challenges and dealing with these has associated costs. There are challenges in envisioning, incentivizing, and sustaining initiatives to alter land management practices. Having a project coordinator or facilitator is essential to success in large-scale coordinated schemes and to build up essential long-term relationships with farmers/partners.

• Facilitation, monitoring and training together in farmer groups (e.g. CSFF) can be effective in adding value to land management schemes (Mills et al, 2020). Jointly setting objectives, accessible monitoring and evaluation and offering feedback to farmers are all important to foster engagement (Ingram et al., 2020).

Delivering environmental outcomes across multiple land holdings will in many cases require excellent data and knowledge on the nature and distribution of environmental assets. Some of this data may come from existing databases and GIS systems but there are important opportunities for baseline data to be co-created with FFLs and stakeholders, drawing on local knowledge and practice. In some circumstances, specialist knowledge may be required to maximise environmental benefits.

The issue of self-monitoring has been raised as a potential mechanism for increasing effectiveness and providing VFM.  Chiswell et al (2020) undertook a literature review and behavioural analysis of agri-environmental self-monitoring and identified a number of recommendations as to how self-monitoring might work:

• A well-devised auditing and verification system is required, i.e. one that encourages FFLs to stay on track but does not overburden them or ‘police’ them too much. Working with FFLs to design this could be an option; getting a balance between keeping them on track but not being overly prescriptive will be key.

• A risk-based approach to auditing and verification that samples a small percentage of land managers according to risk factors and other information, e.g. LEAF marque or Red Tractor membership, is recommended.

• Training in self-monitoring activities would be required. Peer-to-peer teaching could help with ensuring training events are delivered at the correct level. Mechanisms that support/facilitate informal training/learning exchanges could also be developed, e.g. farmer-to-farmer self-monitoring discussion forums or providing a list of ‘expert’ names and contact details for farmers to utilise. Training should also be offered throughout the lifecycle of the monitoring programme, i.e. not just at the beginning.

• Self-monitoring programmes should avoid being ‘one size fits all’, but should be flexible and sensitive to the diversity in the sector, particularly farm types. Choosing the self-monitoring activities linked to personal interest(s) will facilitate better engagement. Monitoring dates should also be sufficiently flexible to allow for unseasonal/changing weather patterns and the farming calendar.

• Self-monitoring programmes focusing on visible outcomes are more likely to facilitate better engagement from FFLs. In Dartmoor Farming Futures, an increase in understanding the connections between management decisions and the desired environmental outcomes was attributed to self-monitoring. For less visible outcomes, the importance of monitoring the outcome must be well explained/clear.

• Extensive work and testing of self-monitoring activities with FFLs across different contexts (e.g. farm types, size of holding, seasons, farmer experience) is recommended to gain a true understanding of input required ensuring time-requirements can be accurately calculated.

• All aspects of self-monitoring design need to take into consideration levels of IT literacy or quality of internet in the FFL community and provide alternative mechanisms that remain accessible for those unable to use a computer.

• Photographs and videos can be a way of verifying/substantiating self-monitoring reports, but in some instances alternatives are required. Ingram et al (2020) found that where farmers are involved in monitoring and target setting there is greater confidence both in understanding environmental value of habitats/features and in their ability to deliver appropriate management.

• A well-designed multifunctional smartphone/tablet app that houses all self-monitoring reporting tasks is recommended.

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

Learning from previous agri-environment schemes (AES) funded through the CAP, it should be recognised that societal benefits from the management of environmental assets were only partially realised. In particular, cultural heritage was not a recognised area of competence for the EU and therefore Defra focused the majority of resources in recent AES to deliver the goals of the main EU environmental directives covering biodiversity, water and, latterly, climate. Our knowledge of the benefit streams from ecosystem services provided by heritage assets is less well-developed. Being free of the CAP gives ELMS the opportunity to maximise societal benefits from cultural heritage, and this should be fully integrated into the monitoring, evaluating, learning and innovation process.

Existing systems should only be re-used/developed where they are fit for purpose. If the ELM scheme is to be truly transformative this is not a time to cut the resources for management tools: this would be a false economy. Data, knowledge and information systems should be fully integrated into the monitoring, evaluating, learning and innovating process. Previous AES monitoring and evaluation by CCRI and numerous partners has encountered persistent difficulties in working with the fragmented and incomplete data/databases provided by Defra and its agencies. There is an opportunity for Defra to engage with the research stakeholder community to co-design appropriate and more holistic systems to measure and track ELMS performance across all its natural and cultural heritage goals as well as its socio-economic impacts.

A co-design approach to monitoring and evaluation involving stakeholders improves all elements of the scheme and increases local buy-in. Regular co-learning sessions where stakeholders are able to feedback into the development of the ELM scheme on lessons learnt from the implementation phase will be beneficial.

There are some issues that need to be resolved from previous schemes:

Payment rates should not be based upon income foregone: once BPS subsidies are removed, many sectors will fail to generate sufficient income on which to base such calculations and it is not always the case that ELMS management will require a trade-off against agricultural production or productivity. Management costs – both day to day and those requiring structural adjustment - should be considered, as well as some incentive element to encourage uptake and address up-front transaction costs. A pragmatic approach to payment rates may offer advantages over anything which relies heavily on rigid theories concerning the relationship between commercial farming and environmental management: this is bound to miss important real-world variability. In the first years of the pilot Countryside Stewardship scheme (1991-1996), payment rates for various options were determined by simple market research, in discussion with farmers in different parts of the country.

The ambition of ELMS should be transformative and co-designed with FFLs, in order to encourage and instigate lasting behavioural change. Now that the ELM scheme is free of the CAP there are opportunities to market the scheme in ways that more fully resonate with FFLs. Cultural heritage is closely linked to local identity, a sense of place and belonging, and the meanings attributed to environmental assets by rural communities. In a practical everyday way, FFLs use heritage to give value and meaning to their environmental assets. This is an important lesson from non-CAP-funded previous initiatives – farmers responded very positively to payments for landscape features and historic assets, in the past. Also, they express a particular recognition of the importance of maintaining such features as a source of income, knowledge and cultural identity, for younger generations growing up in farming communities.

A focus on clear objectives or targets can be effective. There is evidence that identifying common value in assets that can bring farmers together increases scheme engagement (Mills et al., 2008).

Public recognition of farmers efforts has been limited to date and should be increased through local publicity, demonstration events, and achievement awards as recommended by Mills et al (2008). There is evidence that recognition by wider society can motivate farmers to farm in a more environmentally friendly manner and participate in schemes (Dwyer et al., 2007, Mills et al., 2013).

The inflexibility of management prescriptions with current schemes was identified as an issue within CSFF groups (Mills et al, 2020). The groups use a soft approach to encourage farmers to sign up to AES but they are then met by inflexible AES options which fail to meet their groups’ goals. Enabling a stronger focus on desired outcomes and agreed indicators of progress towards these in both contracts and the payment mechanism should facilitate better motivated management that can be tailored to local conditions and their variability through time. In this respect, early indications from PBR – payment-by-results – approaches are positive, particularly in contexts where farmers already have decades of AES experience.


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