Environment, Food & Rural Affairs Committee
House of Commons
London, SW1A 0AA

28th January 2021

Dear Committee Members,

RE: Call for evidence - Environmental Land Management and the agricultural transition

I am writing on behalf of the Pasture-Fed Livestock Association (PFLA). The PFLA is a farmer-led membership organisation, numbering over 600, which also includes butchers, retailers, academics, food & farming professionals and vets. The PFLA champions the regenerative role of ruminant animals and the grazed habitats they evolved alongside and, in doing so, plays a central role in the debate around what constitutes a sustainable food & farming system in a net zero UK.

We specifically promote the benefits – in terms of ecosystem health, net carbon balance, animal welfare and human nutrition – of raising these animals wholly from pasture and forage and have developed standards that underpin the Pasture for Life certification mark. Success for us means UK agriculture transitioning towards, and on certain farms reaching, these farming standards.

DEFRA statistics show that 53% of UK farmland is grassland (permanent, temporary and rough grazing); coupled with the growing awareness of the benefits of introducing ruminants onto arable lands as part of a mixed rotation, we believe the practices we promote should be a foundation stone of future UK farming policy, delivering as they do on the above benefits.

I will address the terms of reference in order and hope these responses will be useful in the deliberations of the Committee. We would be happy to send someone to present evidence in person, if that was helpful.

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?
   In representing a group that have already made many of the required changes to their farming systems we are in a position to comment on the feasibility and timing of the proposed changes. We would argue that the timeframe outlined by the government is adequate in and of itself, provided the farming community have the required information to make the changes and the Government’s systems for managing ELM are in place and fully operational. Our members’ experience with RPA systems to date does not give much confidence on this latter point. It is not clear at this stage what information farmers will get and when, given the prevailing mood is that the solutions remain vague and there is still much work to do on the design side. With the clock now ticking, we have a concern that it may not be until 2024 when we have the full picture and that the delay will result in a dumbing down of the proposed requirements on farmers under the SFI. Either way, three years may be enough time for a farmer with the right mindset but we doubt it would be enough for the wider farming community.

2. 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 farmers that we represent at the PFLA, in the vast majority of cases, are already over-achieving on the environmental and animal welfare goals set out by the government for the future of farming in the UK. There is a hope, or perhaps expectation, within our membership that these results – in many cases underpinned by organic and/or Pasture for Life certification – will be rewarded in the future payments schemes. In addition, many of them benefit from short or direct supply chains and the margin benefits that come from that. In these respects, the farmers we represent are not vocalising a fear of financial hardship from the proposed changes. However, the large drop in direct payments – which has been clearly mapped out – without clear information on what will replace it and when the new agri-environment scheme payments begin is of concern to most farmers.

If the Government wishes to achieve a fundamental change in mindset and approach to farming, the evidence from the PFLA is that farmers need a lot of peer-to-peer support in achieving this. This is perhaps one of the biggest contributions member-led organisations such as the PFLA can make – an understanding of what it actually takes to make change. So, in summary, the SFI in itself will not be sufficient, but actively taking measures to support farmer-led change will help. The PFLA is uniquely positioned in this respect as its members have made changes and are more than happy to share this with fellow farmers. We represent a whole farming system with proven beneficial outcomes that the Government says it wants to achieve, and are in a position to promulgate this to others. 

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

We have a major criticism in this area in that we have had very little contact from DEFRA on the design of ELM or future of UK farming policy, with the exception of a number of tests and trials, where we have been consulted purely on the basis of our close relationship with people conducting them (not DEFRA). It remains unclear as to the future relationship between our audited system and the SFI. We did make two separate and consecutive submissions to carry out test & trials but both were rejected, which we couldn’t understand given the benefits our farmers are delivering. We are aware that our partner organisations in the organic movement have also not been fully consulted, which raises questions about the agenda being pursued at DEFRA.

The PFLA, through the Pasture for Life certification, a 100% pasture-fed farming system for ruminant livestock, represents a whole farm agroecological system already delivering on all of the outcomes the government is looking to achieve through ELM. In addition, the system is proving, primarily through the reduction of agricultural inputs, to be more resilient and profitable than business-as-usual conventional farming practices. While farmers already doing these things are clearly not the focus of the transitional support, per se, we do offer a unique perspective of both how to get there and the wide range of benefits that are on offer to the farmer and wider society.

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

They key here for us is whether the true value of the public goods that farmers can create is recognised and rewarded as well as how ELM is positioned in the wider food & farming context in the UK.

In particular, we think it is important that any ELM solutions offer clear guidance on the pathway beyond the SFI and to whole farm systems like organic and Pasture for Life, rather than see the SFI as a goal. It is and should be seen as a stepping stone and the government should be promoting incremental change through SFI and beyond to ensure the health of our landscape and citizens. We don’t think ELM will work if it is seen as a cul-de-sac.

In addition, ELM needs to be positioned in the food marketplace as a determinant of good practice, primarily through labelling, as well as enable support from government relative to imports. To date, it is not clear that DEFRA have been taking this holistic approach, seeing it as purely a farming scheme.

The moves within the wider food sector towards adoption of regenerative agriculture practices and marketing terms suggest a much greater role for that sector in driving positive changes in agriculture, if nothing else than for marketing gain. If the government’s proposals are not designed within that context, it is possible some farmers will shun governmental support in favour of a supply chain, often controlled by foreign enterprises, that can be demanding and leading with their own solutions, which may not lack rigour or the desired outcomes. This would also lead to a lack of regulatory oversight and much needed transparency.

5. How can the Government ensure that ELM agreements achieve their intended environmental outcomes, reduce bureaucratic burdens on farmers and deliver value for money?
   There has been an apparent wavering from the ELM designers on the SFI / Level 1 due to the issue of it needing to be accessible to all. It is hard to imagine a scheme that is accessible to all differing from the status quo in any significant way. If we accept this as a given, it then becomes all the more important for the SFI / Level 1 to improve over time, bringing land managers along with it. The Pasture for Life certification standards, for example, are updated every two years reflecting both new information about farming practice but also a recognition that it takes time for new practices to be adopted. A similar approach might provide an acceptable trade-off between accessibility and outcome.

In terms of value for money, we believe that investments in ecosystem services outperform other investments, thinking about the unquantified impact on human health, the partly quantified impact on things like water quality and treatment, as well as more tangible effects on farming bottom lines. These changes in themselves will reduce burdens on farmers who will find they spend less time and money dealing with farming issues that stem from ecosystem ill-health.

In addition, encouraging farmers to adopt a UKAS accredited certification scheme that delivers on all the desired benefits – such as whole farm systems like organic and Pasture for Life – will reduce bureaucratic burden by aligning with existing on-farm inspections. For example, Pasture for Life is auditable in conjunction with organic and biodynamic schemes and the Soil Association audit alongside Red Tractor. Encouraging further integration on the side of the certifiers would reduce the burden even further. The certification schemes will also process the necessary paperwork from an administrative side, reducing the burden on DEFRA to have to do this. Passporting these existing schemes directly into ELMS will therefore be of great benefit.

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

We are aware of previous schemes that have not rewarded farmers who have already made the necessary changes to achieve positive environmental outcomes without grant support. This has to be the point at which we decide that land managers should be rewarded for both what they have achieved (their habitats) and not just the process for restoring those habitats. The alternative is the incentivisation to destroy habitats before entering schemes as has occurred in some cases under previous schemes. It would also mean environmentally favourable changes would be held back.
There is also evidence that without a change in fundamental approaches to farming systems and habitat management that the environmental outcomes are not there to stay.  In the case of Pasture for Life certified farmers these outcomes are built into the business operation as they make financial sense.  The standards provide for significant habitat improvements as well as farming in a manner that treats nature as a partner.  This should be the aim of the Government – to support farmers to make these fundamental changes and to maintain them into the future.

We had a very constructive call with Janet Hughes (Programme Director, Future Farming and Countryside Programme, DEFRA) this morning (Friday 5th February) having been put in touch with her by one of our certified farmers. There looks to be positive movement on the part of DEFRA to determine the equivalence between whole farm systems like Pasture for Life (our certification standards) and the SFI, which may stem from Janet’s appointment. It clearly remains to be seen where we get to on this but we wholeheartedly welcome the move and will engage fully.”

We very much appreciate the opportunity to be consulted on this and look forward to the findings of the Committee being published.