On Tuesday 18th October, on behalf of the FWAG Association, Adam Lockyear and Gary Rumbold sent a letter to the Secretary of State, offering to support his department in their review of Defra activity. You can read the letter below...

c/o Hawkridge House
Summerfield Way
Chelston Business Park
TA21 9JE
Tel: 01823 660684

Date: 18th October 2022

Re: Offer of Assistance to any proposed ELM review process

Dear Secretary of State, the Rt Hon Ranil Jayawardena MP

The national Farming and Wildlife Advisory Group Association (FWAG Association) represents a group of “boots on the ground” organisations that have supported farm businesses across the country for over 50 years, working on all iterations of Agri-Environment schemes since their launch in 1987. We strongly believe that any step back from the clear direction of travel set out in the Agricultural Transition Plan could have serious impacts, both environmentally and financially, for the farming sector. As an experienced and respected stakeholder that represents the interests of farmers and wildlife, we extend an offer to meet with any of your ministerial team or advisers to contribute to the review process.

As a new team takes on responsibility for Defra, a review of activities is a welcome and necessary step in ensuring that the department is efficient and effective. Although subsequent DEFRA statements suggest a considered approach to a review of ELMS, the initial references reported in the media to maintaining area-based payments and scrapping ELMS were deeply concerning for the industry, society and the environment.

During a time where there have been calls from the farming community for certainty, there has been a concerted effort by Defra to develop clarity over the timeframe for transition to ELMS, alongside other elements of the Agricultural Transition Plan and for Defra to demonstrate clear intent in the development of the “Public Money for Public Good” principles.

Over the last four years we and other stakeholders have provided thousands of hours of input into engagement processes with Defra on the codesign of ELMS, drawing on 30 years of experience of Agri-Environment Schemes to contribute a wealth of data to Defra. We believe to halt this development would be a failure to address the dual challenges of a climate and biodiversity crisis, where a maintenance of the status quo will put the country on course to fail to achieve its environmental commitments set in law; The  Environment Act and the commitment to halt biodiversity declines being the primary example.

We recognise that ELMS is not currently perfect but we believe it offers a framework that can be developed to deliver for the environment and for farm businesses. The standards in the Sustainable Farming Initiative need to provide clear ambition for farmers to aspire to. The current “income foregone plus costs” model to valuing actions is inadequate but we believe there should be a doubling of efforts to ensure it works rather than delaying action.

To maintain an area-based payment scheme based on “entitlement” of land occupation for minimum environmental outcomes cannot be justified, nor does it provide a business model for innovation and transition in the industry which can address our dual crisis of climate change and biodiversity loss.

A systems-based approach that pays for the unvalued social impacts farming can offer and provides businesses with a production model that makes them more resilient to commodity market volatility, allows adaptation to climate impacts, provides the public services set out in the 25 year Environment plan such as biodiversity, clean air, clean water etc. and improves the mental and physical health of those working in the industry, should be pursued at pace.

This systems-based approach must be based around healthy soils and functioning ecosystems alongside the production of healthy food that is valued by society. The Government-commissioned independent National Food Strategy published in 2021 clearly sets out the case and actions needed for this to happen.

Done well, ELMS can support these aims however it must demonstrate that the people who manage the land are part of this new future otherwise we will not achieve the hearts and minds shift required to engage with this new policy.

For us, at the heart of the issue is the income forgone plus cost model for calculating payment rates under ELMS that often do not adequately compensate farmers for the transition and maintenance of environmental services they can provide for the public good. This is an area that requires rapid policy/political leadership to overcome. Without this ELMS will continue to be viewed as offering a poor alternative to the Basic Payment Scheme.

We continue to support Defra staff in the development of ELMS and would welcome any opportunity to provide external knowledge and experience to your office as part of this review process and beyond.

Yours Sincerely,

Gary Rumbold Chief Executive Officer, FWAG South West
Adam Lockyear, Head of Advisory Services, FWAG South West

Both on behalf of the FWAG Association