Judging the future of farming policy against what nature needs

Today, I am taking part in a conference hosted by the Zoological Society of London to debate how much space is needed for nature.

The motivation is to reflect on progress made in meeting existing global targets for managing land and sea for nature (17% on land and 10% at sea by 2020: Aichi Target 11 of the Convention on Biological Diversity) and to begin to scope what ambition is needed to guide conservation efforts over the next decade.

This feels like the right debate.   To take the threat of climate change seriously, the scientific community worked how to avoid catastrophic climate change hence setting an aspiration (in the Paris Climate Agreement) to stay within 1.5 degrees Centigrade global temperature increase above pre-industrial levels and determining what levels of greenhouse gas emissions reduction are now required.  This now drives the decarbonisation agenda around the world and we have mechanisms to assess whether the world is collectively is doing enough.

Nature conservation has needed something equivalent to determine how best to avoid extinctions and ensure that humans continue to benefit from the services provided by well-functioning natural habitats.

Over the next few months you will hear more about whether we should be protecting up to 50% of the planet to meet these objectives.  Indeed, today, there will be a number of talks on this subject designed to start the process of building consensus about what global ambition should be in the run up to the crucial meeting of the Conference of the Parties to the CBD in China in 2020 – the moment when the world will agree our ambition for 2030.

Setting ambition is one thing – making it happen is another, which is why there needs to equivalent energy invested in determining how to meet the target.

In the UK, for example, we currently have c10% of land designated as Area/Site of Special Scientific Interest and we know that roughly only 50% of these sites are in favourable condition which means that arguably only 5% of land is protected and well managed for wildlife.  However, we also know that we have been making strides in addressing the Professor Sir John Lawton mantra of more, bigger, better and connected protected areas by trying to put wildlife back into land outside of protected areas.  The principle mechanism to do that has been agri-environment.

So, in order for us to meet our current 2020 target (of 17% of land well managed for wildlife 2020) let alone any higher target that may be set (based on science) for 2030, we need to do what we can to bolster existing protections AND ensure that there is more support for farmers to manage their land for wildlife. 

This is why yesterday’s consultation paper on future farming and land management policy after Brexit was so welcome. 

Below, my colleague Tom Lancaster, offers his assessment of the proposals and invites you to get involved and have your say.

However, I urge you think about the adequacy of the proposals against what nature needs.  Not only will our generation be judged on how we responded to the UK vote to leave the EU, we shall also be judged on how we took action to address the crisis facing the world’s wildlife.

Friesian cattle at Coombes Valley RSPB reserve. Staffordshire, England. Fields are managed by grazing or mowing, to benefit wild flowers & insects (Andy Hay, rspb-images.com). 

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RSPB thoughts on Health and Harmony: the future for food, farming and the environment in a Green Brexit by Tom Lancaster

This paper outlines the future direction for policy in England after the UK has left the European Union (EU), and opens a 10 week consultation during which we will seek to engage many of our members, supporters and the farmers that we work with in making the case for change.

My first impressions are that the paper represents a potentially significant step forward – and this blog covers my initial thoughts on the good, the uncertain, and the possible risks on the horizon.

The good

I’ll start with the good, and there’s plenty to go at.

Public money for public goods

Policy jargon at its finest, but important nonetheless. Directing public money toward the goods and services that we need from land, but which are not provided by the market – wildlife, resilience to flooding and climate change, amongst others – is a case we have been making for decades. Identifying this as the guiding principle for future policy is a major shift in emphasis, and a necessary first step toward meaningful reform.

The environment as the ‘cornerstone’

The principal public good, as flagged by the Secretary of State earlier in the year, will be environmental enhancement, which would take the form of a new environmental land management system that is intended to form the ‘cornerstone’ of a future agriculture policy. There’s not a great deal of detail here, but what there is largely mirrors the framework outlined in the recent 25 year environment plan. As I said at the time, this looks broadly good, and much of it is in line with the policy proposals that we set out with Wildlife and Countryside Link last autumn.

Putting the environment at the heart of a future farming and land management policy would be a major step forward, and is a necessary prerequisite to achieving the aim of being the first generation to improve the natural environment.

Integrating farming and the environment

A huge positive of the consultation paper is that it recognises that farming and the environment are intrinsically linked, and that farming depends upon sustainable management of our natural resources for its long-term future. The paper makes it clear that a “…new system will promote long term sustainable land management”, that Defra want “…farmers and foresters to integrate their plans for the production of environmental goods with plans for the production of food and timber” and that “Improving the environment can also benefit the competitiveness of the sector.” All good stuff.

How this will be achieved is an unresolved question, and there are obvious risks that improved productivity and environmental enhancement could be pursued on parallel and potentially divergent tracks. For now though, the ambition is there, and it’s up to consultees in part to tell Government how this can be achieved.

Ongoing commitment to Countryside Stewardship

With all this future-gazing, there is a risk that we lose sight of the here and how. So it was great to see a commitment to continued improvements to Countryside Stewardship (CS - the existing agri-environment scheme in England), especially given its bumpy start in life. This, reinforced by a commitment to keep the scheme open until new policies are in place and that those in existing CS and Environmental Stewardship agreements will not be “unfairly disadvantaged when we make the transition to new arrangements”, provides important certainty for those in, and thinking about applying for, existing schemes.

The polluter pays principle

A final, and perhaps unexpected highlight, is a commitment to move toward a more effective application of the polluter pays principle. Whilst our public goods arguments have always been based on the idea of ‘provider gets’, we have always been equally clear that this needs to be underpinned by effective regulation, based on the idea that polluters should pick up the costs associated with environmental harm. 

So it is great, and refreshing given the unhelpful language sometimes used by Government about ‘red tape’ and ‘regulatory burdens’, to see a clear commitment to “maintain a strong regulatory baseline of standards that reflects the ‘polluter pays’ principle”. Important for society and the natural environment, this is perhaps most important for those more forward thinking and progressive farmers, who would otherwise be at risk by those damaging the environment for their own short-term, but unsustainable, advantage.

So this is all good stuff, and it’s important not to underplay how important this paper could be. It is important though to flag that there are some areas of uncertainty, and some potential risks that could emerge.

Areas of uncertainty

Geography

Readers of this in Wales, Scotland and Northern Ireland would be forgiven for not having any real clue as to what this means for them. The paper is clear that all of the specific proposals are for England only – it does say that Defra believe that this vision “…could work for the whole of the UK” but they “…recognise that devolution provides each administration with the powers to decide its own priorities.”

What is interesting is that the paper makes it clear that the UK Government expects to need legislative frameworks for the UK where ‘commonality is essential’, and looser, non-legislative arrangements where ‘commonality is desirable’. There will be a bunfight over what’s essential and what’s desirable I’m sure.

What is key is that UK and devolved administrations, via a shared and mutually agreed process, should agree on a shared and high level of environmental ambition for future policies, and a shared understanding of the regulatory baseline. These two things are essential if we are to foster a race to the top, and avoid short-termism in policy that threatens the natural resources upon which farming depends.

Transition

The paper talks a lot about transition and what will happen, including progressive reductions to direct payments.

What it doesn’t do though is commit to when any if it will happen. Nothing much will happen in 2019, although it does say that a ‘new environmental land management system’ will be in place from 2022. This is a welcome commitment, and assuages some concerns that we had after the Secretary of State’s speech at the Oxford Farming Conference in January that this could be delayed into the mid-2020s.

However, it does not say when the ‘agricultural transition’ will begin, nor when it will end. Clarity on this sooner rather than later will be needed for farmers and others to prepare for the changes ahead.

Future funding

Beyond the existing commitment to match funding to 2022, the paper says nothing about money. This is a gap, albeit not an unexpected one. The last section on the Agriculture Bill asks whether the proposed powers are sufficient, and here we’d say no – the Bill also needs to include a provision to ensure independent scrutiny over the funding needed for future policies, and the extent to which this is sufficient to meet any objectives. An independent assessment of funding need that we commissioned with The Wildlife Trusts and National Trusts suggests that at least £2.3 billion will be needed per year for environmental land management alone across the UK, 450% more than is spent on existing agri-environment schemes.

Finally, and at the risk of going on, I’ll reflect on two potential risks that could emerge in the future.

Risks on the horizon

Regulation and the deterrent effect

What the paper says about regulation is by no means bad. As I say above, the recognition of the importance of effective regulation and the polluter pays principle is heartening. There are a couple of specific proposals though that open up the risk of a reduction in enforcement specifically.

Firstly, one of the suggested options for transition is to ‘de-link’ direct payments from land – to remove the need for recipients of direct payments to have any land in order to claim those payments. This could work well if it facilitated a transition to a new policy. However, it could also leave a ‘gap’ in regulatory enforcement given that this would also spell the end of cross-compliance conditions attached to these payments. Whilst the paper notes that farmers and land managers would “…still need to comply with environmental, animal and plant health and animal welfare standards”, and that this “…would therefore require a new enforcement mechanism”, it’s not clear what this would look like in practice. If it didn’t operate effectively, there could be a significant reduction in the deterrent effect of regulation if enforcement was reduced compared to now.

Secondly, the section on ‘changing regulatory culture’ opens up many of these same risks, focusing on streamlining implementation and enforcement. Whist there is scope to improve the enforcement of regulation, if Defra get this wrong, they will undermine their stated commitment to high environmental standards, and the investments made in environmental enhancement.

Trade

The section on international trade is full of slightly cryptic language. Although it commits the Government “…to ensuring the maintenance of high standards of consumer, worker and environmental protection in trade agreements”, it doesn’t say how this will be achieved, who will hold them to account, or if these will be applied to imports, as well as UK production.

Get any of these things wrong, and the whole edifice of a public goods policy could be undermined by a race to the bottom driven by future trade arrangements.

A good day

Even with these risks and uncertainties though, yesterday was a good day. The RSPB and our partners in the environment and farming sectors have been advocating for many of the proposals included in today’s consultation paper for many years. Two years out from the referendum on EU membership, and this is perhaps the one of the first concrete signs of progress. These next 10 weeks, and the months and years ahead, will be pivotal in making sure that the opportunities this moment presents are realised for the future of farming and wildlife.

Make sure you have your say, it’s perhaps never mattered more than it does now.

You can have your say directly at https://www.gov.uk/government/consultations/the-future-for-food-farming-and-the-environment. We’ll also be encouraging our supporters to respond the consultation in due course. If you’d like to stay informed, and hear about all our campaigns, sign up at www.rspb.org.uk/CampaignChampions