Written evidence submitted by Natural England (ELM0027)

Summary

 To achieve its environmental and climate outcomes on the scale required ELM itself should rigorously prioritise the delivery of environmental public goods; other measures within the Agricultural transition Plan support social and economic outcomes.

 ELM needs clearly defined and measurable objectives. Its contribution to the Nature Recovery Network, for example, should be clearly defined.

 The way in which the different components of ELM interact needs to be properly thought through. It will need to take account of the experience gained from monitoring and evaluating existing and previous schemes to avoid the mistakes of the past.

 The interactions between ELM and the other regulatory and non-regulatory processes to which land management is subject need to be carefully considered. Other complementary policy measures, such as conservation covenants may be needed to secure long-term commitment.

 Scheme design should be user focussed; agreements should be sufficiently flexible to reflect changing circumstances.

 Advice and guidance will be crucial to the success of ELM. Natural England has a key role to play in the provision of evidence-based advice in both scheme design and evaluation. We have many expert advisers who are well respected by the industry.

 ELM will need to be underpinned by a modern and effective regulatory and enforcement regime which supports applicants to deliver high quality outcomes.

1 Natural England is the Government’s statutory adviser on the natural environment established under the Natural Environment and Rural Communities Act 2006 (the NERC Act). Natural England’s purpose is to ensure that the natural environment is conserved, enhanced and managed for the benefit of present and future generations thereby contributing to sustainable development.

We are pleased to have an opportunity to submit evidence to this important inquiry. Our comments are underpinned by strong support for the Agricultural Transition Plan and a desire to ensure that Environmental Land Management (ELM) is as effective as possible in achieving its environmental outcomes.

If the urgent problems of environmental degradation, loss of biodiversity and climate change are to be tackled, then it is important that the agricultural transition process is followed through as quickly as possible, whilst still allowing the farming industry time to adapt. To succeed we will need to learn from past agri-environment schemes, overcome their limitations and take full advantage of the opportunities available for design of a scheme tailored to England’s circumstances. To do this ELM will need a relentless focus on environmental outcomes in all aspects of design and operation, with full use made of the expertise and delivery experience within Defra’s Arms-Length Bodies. Natural England has a key role to play in the provision of evidence-based advice and environmental assessment.

Q1. Is the Government’s timeframe for the national pilot, full roll-out of ELM and phasing out direct payments by 2027 feasible?

1.1 If Government makes full use of the expertise it has available within its Arm’s Length Bodies, then Defra will be able to roll out the different components of ELM to time. 1.2 The 25 Year Environment Plan sets out the huge scale of the challenges facing our environment. If these challenges are to be effectively addressed, then the resources currently used to provide income support payments to farmers need to be rapidly and progressively diverted to pay farmers and others to provide environmental public goods. The Local Nature Recovery and Landscape Restoration components of ELM are likely to contribute more than the Sustainable Farming Incentive (SFI) to Nature Recovery and Net Zero, as well as generating the most environmental benefits per unit cost, so these elements especially should not be allowed to slip. 1.3 Natural England recognises that this timetable will require many farmers and other land managers to make big changes to their businesses in a relatively short space of time. Further thought is needed as to how Government can best provide or enable the business planning, advice and skills training that may be needed.

Replacement regulatory regime

1.4 Regulatory requirements provide the foundations above which environmental action can legitimately be incentivised. A fit for purpose streamlined regulatory regime is required to ensure that the contribution ELM makes to the Government’s environmental targets is as effective as possible.

2 Q2. 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?

2.1 This question must be viewed in the context of Defra’s wider Future Farming and Countryside Programme. In addition to the different ELM components and ongoing Countryside Stewardship, there are a range of other interventions, including the farming investment fund, farm resilience support and the animal health & welfare pathway, among the other schemes listed in the Agricultural Transition Plan. ELM can therefore be designed to focus exclusively on the environmental objectives it is intended to deliver. 2.2 The SFI needs to be a significant step on the journey to ELM rather than an endpoint in itself. The SFI must measurably deliver public goods; it should not replicate the shortcomings of previous broad and shallow schemes and it is particularly important that farmers understand that SFI is not a replacement for the Basic Payment Scheme. 2.3 The Agricultural Transition Plan aims to bring about a transformation of farming in England so that it is no longer dependent on direct payments and farmers can contribute to the targets within the 25 year Environment Plan and help the country achieve the goal of achieving net zero in terms of carbon emissions. This will require many land managers to adapt. There is a case for investment in dedicated support for business, with environmental advice and training to build new skills during the transition period. This would help farmers re-think their business models and plan and prepare for ELM agreements on their land. 2.4 The Agricultural Transition Plan coordinates proposed spending on environmental schemes with the earmarked funding for Animal Health & Welfare. Given the different intervention logic and evidence base for these two categories, analysis of their respective Benefit-Cost ratios should be clearly delineated so the economic case for future funding for each can stand and fall on its own merits.

Q3. How effectively has Defra engaged with land managers and other stakeholders on the design of ELM including on the transitional arrangements?

3.1 There has been considerable engagement to prepare stakeholders, which has been provided, for example through the Health and Harmony publication and consultation which generated over 43,000 responses.1 2 Further key publications have included the ELM Policy Discussion Document,3 and the publication of the Agriculture Transition Plan.4 In addition, Defra have published two ‘farmer facing’ leaflets describing how farming is changing as part of the transition away from the CAP. In addition, Royal Assent for the Agriculture Bill was given on the 11 November 2020 which confirmed the policy of public money for public goods. In combination, these policy developments have provided land managers and other stakeholders

1 Early Review of the New Farming Programme HC 2221 SESSION 2017–2019 5 JUNE 2019 https://www.nao.org.uk/wp-content/uploads/2019/06/Early-review-of-the-new-farming-programme.pdf 2 https://www.gov.uk/government/consultations/the-future-for-food-farming-and-the-environment 3 https://consult.defra.gov.uk/elm/elmpolicyconsultation/ 4 https://www.gov.uk/government/publications/agricultural-transition-plan-2021-to-2024

3 with information on Defra’s intended direction of travel and an opportunity to comment on it. 3.2 These reforms have been described as the ‘biggest change in agricultural policy in half a century’.5 The potential scale and complexity of these issues should not be underestimated. To date they have provided the necessary detail or guidance to enable farmers to start comprehensive planning for how they will adapt their businesses to the new policy environment, improve environmental outcomes and work collaboratively with other farmers. 3.3 The Tests and Trials programme is one of the main ways in which stakeholders can actively engage with the development of the Programme. Defra has said that engaging stakeholders from a variety of organisations and disciplines in the design will result in higher quality ideas, higher user satisfaction and greater enthusiasm to embrace change and innovation. The programme has proved very popular. It is understood that some 3000 farmers have been engaged in Test and Trial projects as well as many other stakeholders, and much valuable experience has been gained.

Q4. How can ELM be made an attractive business choice for farmers and land managers while effectively delivering its policy goals?

4.1 ELM alongside other measures in the ATP, needs to be able to present a viable business proposition across all sectors. Historically AES has not been targeted at, nor contained, options for intensive horticultural, pig and poultry enterprises due to their small land base. But given an increasing focus on air/water quality and climate change these sectors should be fully considered. 4.2 Making ELM attractive to farmers is very important but; to be fully effective, ELM also needs to be an attractive business choice for other land managers, including those managing green space in urban and urban fringe areas and those managing woodlands and forests. 4.3 ELM is not designed be a financial replacement for the loss of BPS. The delivery costs of ELM (for the farmer or land manager) will be higher and will impact on land availability and intensity of production, so financial margins will be considerably less. ELM would enable farmers to re-structure their businesses in terms of reduced overheads or new systems6. 4.4 ELM needs to be easily accessible and understood by farmers. There is a pressing need to decide on respective ELM component budgets available and decide to what extent they need to be managed and limited utilising selection criteria. The points- based approach as used formerly with Entry Level Stewardship (2005-2015) has some potential advantages. As well as proving to be an effective budget management approach this approach was easily understood, easily accessible and enabled rapid access to and implementation of a wide range of management options. 4.5 Farmers already undertake a wide range of recording and actions related to environmental issues, often above and beyond that required by legislation. These are often due to farm assurance scheme requirements providing an existing mechanism for information dissemination, application of standards, control and

5 https://www.gov.uk/government/publications/agricultural-transition-plan-2021-to-2024 6 https://www.sciencedirect.com/science/article/pii/S0308521X20308702?via%3Dihub

4 audit, all funded through the private sector. We would encourage Defra to work with the industry to investigate the extent to which assurance schemes can, or could meet ELM requirements, particularly for SFI.

Q5. How can the Government ensure that ELM agreements achieve their intended environmental outcomes, reduce bureaucratic burdens on farmers and deliver value for money?

Achieving the intended environmental outcomes

5.1 ELM is crucial for delivery of the targets set out in the Government’s 25 Year Environment Plan, including for example, the targets to restore 75 per cent of the area of terrestrial and freshwater protected sites to favourable condition and to create or restore 500,000 hectares of wildlife-rich habitat outside the protected site network. 5.2 Government is already committed to the Nature Recovery Network (NRN), which aims to achieve a series of major environmental objectives. It is vital that the ELM outcome targets commit ELM to making a major contribution to the NRN objectives. The targets set for ELM should also include a substantial, defined contribution to helping the Land Use and Land Use Change sector contribute to the Government’s commitment to achieving net zero carbon emissions by 2050. This will require the spatial prioritisation of ELM to be aligned with the Local Nature Recovery Strategies which are due to be introduced through the Environment Bill. 5.3 Although ELM is not the only mechanism that can contribute to achieving the NRN’s ambitious targets, the other mechanisms are either transitional and of limited duration (e.g. the Nature for Climate Fund and Farming in Protected Landscapes) or as yet unproven (e.g. Biodiversity Net Gain and Conservation Covenants). ELM has by far the greatest potential. Government intends that by 2024 57% of the money currently spent on Direct Payments will be spent on environmental and animal outcomes. At just under £1 billion per year this, together with the budget for the existing environmental land management schemes (Countryside Stewardship and Environmental Stewardship), has the potential to provide the majority of the £1.32 billion annual cost of meeting the scale of need for environmental land management interventions identified in a report published in 2017 by RSPB, the National Trust and the Wildlife Trusts. 5.4 To ensure that ELM agreements achieve their intended environmental outcomes then needs to be clear that this is the primary policy objective for ELM. This focus needs to be maintained through all stages of the policy cycle, design, development, operation, monitoring, evaluation and review. 5.5 A good starting point would be to set quantified evidence-based outcome targets at the appropriate scale i.e. national or local, according to scheme design, and make it clear that it is against these targets that the success or otherwise of ELM will primarily be judged. It is important that these targets are based on evidence and that they take account of the scale of change needed to address current pressures on our environment. 5.6 Linking payments and compliance monitoring to outcomes rather than actions has been shown in trials to produce better environmental outcomes7. This is an

5 extremely significant conclusion that should shape the development of the schemes over time. However, considerable further work is needed to achieve this vital transformation. More work is needed so Government can introduce result-based payment systems for all objectives as soon as possible. The aim should be for result- based payments for complex, multi-objective agreements to be simple enough not to overload farmers. 5.7 The provision of good quality advice, linked to outcomes and delivered by trusted advisers, has also been shown to improve environmental outcomes8. Experience suggests that advice is required at the stage of setting up an agreement and at intervals throughout the period that an agreement is in operation9. 5.8 Social science research10 has also shown that environmental outcomes can be improved where farmers can learn from each other, where they can feel a sense of pride in successfully achieving environmental outcomes and where they can earn the respect of their peer group by doing so11. Farmer clusters, supported by the Countryside Stewardship Facilitation Fund, have had some success in achieving these aims. A possible further initiative might be to introduce local, regional and even national prizes for the best environmental outcomes. This approach has had some success in France, where competitions to find the best managed species-rich grasslands have been operating for some years12. 5.9 Over the longer term, the achievement of environmental outcomes can be improved by a well-designed programme of scheme-level monitoring and evaluation. It is important that this programme focuses on outcomes (which are harder and more expensive to measure) as well as outputs and results. Evidence of the value of monitoring and evaluation in helping to improve outcomes is provided by the example of the 2003 review of agri-environment schemes in England, which reviewed the results of the monitoring of the first generation agri-environment schemes and used them to design Environmental Stewardship13. Although this

7 Chaplin, S., Robinson, V., LePage, A., Keep, H., Le Cocq, J., Ward, D., Hicks, D., and Scholz, E., (2019). Pilot Results-Based Payment Approaches for Agri-environment schemes in arable and upland grassland systems in England. Final Report to the European Commission. Natural England and Yorkshire Dales National Park Authority http://publications.naturalengland.org.uk/publication/6331879051755520 8 Smallshire, D., Robertson, P. Thompson, P. (2004) Policy into practice: the development and delivery of agri-environment schemes and supporting advice in England. Ibis (2004), 146 (Suppl. 2), 250–258 https://onlinelibrary.wiley.com/doi/pdf/10.1111/j.1474-919X.2004.00367.x and Defra (2013) Report of contract LM0411 Value for money evaluation of ELS Training and Information Programme (ETIP) summary available at http://randd.defra.gov.uk/Default.aspx?Menu=Menu&Module=More&Location=None&ProjectID=18537&FromSearch=Y& Publisher=1&SearchText=etip&SortString=ProjectCode&SortOrder=Asc&Paging=10 9 Defra (2015) Report of contract LM0432: Assessing the impact of advice and support on the outcomes of HLS agreements Summary available at http://publications.naturalengland.org.uk/publication/5163786125180928 10 McCracken, M.E. Woodcock, B.A. Lobley, M. Pywell, R.F. Saratsi, E. Swetnam, R.D. Mortimer, S.R. Harris, S.J. Winter, M. Hinsley, S. and Bullock, J.M. (2015) Social and ecological drivers of success in agri-environment schemes: the roles of farmers and environmental context, Journal of Applied Ecology, 52, 696–705 11 Hurley, P., Lyon, J., Hall, J., Little, R., Tsouvalis, J. and Rose, D.C. (2020a). Co-designing the environmental land management scheme in England: the why, who, and how of engaging ‘harder to reach’ stakeholders. https://doi.org/10.31235/osf.io/k2ahd MLA

Lyon, J., Hurley, P., Hall, J., Tsouvalis, J., Rose, D. C. and Little, R. (2020): Inclusive design of post-Brexit Agri-Environmental Policy: Identifying and engaging the 'harder to reach' stakeholders. A Quick Scoping Review. The Universities of Sheffield and Reading. Report. https://doi.org/10.15131/shef.data.12506582.v3

12 Chambres d’agriculture France (undated) Website article on Le Concours des Prairies Fleuries https://chambres- agriculture.fr/actualites/toutes-les-actualites/detail-de-lactualite/actualites/le-concours-des-prairies-fleuries/

6 scheme was far from perfect, it was generally agreed to be an improvement on its predecessors.

Reducing bureaucratic burdens on farmers

5.8 It is important to make a distinction between unproductive administrative requirements, which may fairly be described as bureaucratic burdens, and the investment of farmer time needed to produce the intended environmental outcome and demonstrate that these have been achieved. 5.9 A more outcome-focused scheme, operating outside the CAP, should be able to simplify these requirements considerably, though a certain amount of administration will still be needed to ensure that public money has been correctly spent. Outcome- focused schemes are however likely to require time for activities that are linked to outcomes, such as skills training and self-monitoring, the latter providing the feedback that farmers need to adjust their management to achieve the desired environmental outcomes. 5.10 Rather than trying to restrict the need for such inputs of time, payments need to fairly reflect the time inputs needed for successful outcome delivery.

Delivering value for money

5.12 True value for money is a complex function of several parameters including scheme uptake, (both overall and of specific actions), outcome delivery, payment levels and delivery costs. In the past, value for money has sometimes been interpreted as the ratio of overheads to money distributed to agreement holders, thus leading to pressure to keep delivery costs to a minimum. Relatively modest investments in advice and/or training to support agreement holders can, for example, deliver improvements in the value of outcomes that far outweigh the additional cost. 5.13 An inherent problem with voluntary schemes based on annual payments is that the environmental outcomes that they produce are essentially rented not bought, and there have been examples where expensively created habitats have been destroyed shortly after agreements expire. There is no universal answer to this problem, but careful consideration should be given to complementing ELM with other policy instruments and incentives to ensure the longevity of environmental outcomes, since short term inflexible agreements can act as a disincentive. Its value for money could be improved by raising the level of regulatory requirements that underpin ELM A higher level of regulatory requirement would free more money to fund more ambitious interventions by eliminating or greatly reducing what are essentially payments not to pollute. Consideration could also be given to the use of conservation covenants to secure longer term control over how some land is managed. 5.14 One aspect of value for money that is often overlooked is the extent to which a scheme helps to build or damage trust in environmental management schemes. For example, the various IT problems of Countryside Stewardship damaged that trust. It

13 Radley, G. (2005) Evaluating agri-environment schemes in England in OECD (2005) Evaluating agri-environmental policies: Design, practice and results. Pp 161-176. OED Publishing, Paris.

7 is essential that ELM is underpinned by a robust IT system and that payments due are made accurately and on time.

Q6. What lessons should be learned from the successes and failures of previous schemes paying for environmental outcomes?

6.1 To achieve its environmental and climate outcomes on the scale required the design of ELM will need to learn from the experience gained from monitoring and evaluating existing higher and entry level schemes. High quality advice has been shown to better deliver our environmental targets, including at landscape scale 6.2 Monitoring and evaluation of current and previous schemes shows they can be very effective in conserving biodiversity and are likely to be key to achieving Defra’s Bio2020 and 25YEP targets. Over successive programme cycles these schemes have become increasingly better at matching the right land with the right management option. A good example is the way Environmental Stewardship has been shown to be capable of benefitting farmland bird populations.14 Modelling based on field data shows that AES provision needs to exceed 2.5% of the farmed area and may need to be as high as 10% to stabilise vulnerable populations.15 6.3 The effectiveness of Higher-Level Environmental Stewardship (HLS) in maintaining and enhancing botanical diversity has also been shown through agreement level monitoring16, although the often-slow pace of change highlights the value of continuity of management over successive schemes. Appropriately targeted and supported habitat creation such as species-rich grassland on ex-arable sites can achieve results relatively quickly17. 6.4 The main priority objectives for the current CS scheme are biodiversity and water quality, with additional objectives including historic environment, flood management and climate change adaptation and mitigation, all of which fall within the range of public goods that ELM will pay for. Targeting of options, allied to capital spend on infrastructure and dedicated advice through the Catchment Sensitive Farming Programme has already contributed to reductions of 4-12% in agricultural pollutant losses in target areas18, although more needs to be achieved. Modelling studies have demonstrated the potential contribution to air quality improvement19 and climate change mitigation through soil carbon storage20.

14 LM0458: Agreement Scale Monitoring of Countryside Stewardship Agreements Baker, D.J., Freeman, S.N., Grice, P.V. and Siriwardena, G.M. 2012. Landscape-scale responses of birds to agri-environment management: a test of the English Environmental Stewardship scheme. Journal of Applied Ecology 49: 871–882. Walker, L.K., Morris, A.J., Cristinacce, A., Dadam, D., Grice, P. V. and Peach, W. J. 2018. Effects of higher-tier agri- environment scheme on the abundance of priority farmland birds. Animal Conservation 21: 183–192. 15 Predicting the extent of agri-environment provision needed to reverse population declines of farmland birds in England. Report to NE on project ECM52672 (module 2) Sharps et al (2019) 16 Staley, J.T., Lobley, M., McCracken, M.E., Chiswell, H., Redhead, J.W., Smart, S.M., Pescott, O.L., Jitlal, M., Amy, S.R., Dean, H.J., Ridding, L., Broughton, R. & Mountford, J.O. 2017. The environmental effectiveness of the Higher-Level Stewardship scheme; Resurveying the baseline agreement monitoring sample to quantify change between 2009 and 2016. Natural England project ECM 6937. 17 Hewins, E. 2013. A survey of selected agri-environment grassland creation and restoration sites: Part 1 - 2010 survey. Natural England Commissioned Reports, Number 107. 18 Environment Agency. 2019. Catchment Sensitive Farming Evaluation Report – Water Quality, Phases 1 to 4 (2006-2018). Natural England publication, June 2019. 19 Carnell, E.J., Misselbrook, T.H., Tomlinson, S.J., Thomas, I.N., Sawicka, K., Rowe, E., Sutton, M.A., Dragosits, U. 2018. AROMA – Agri-Environment Reduction Options for Mitigating Ammonia: Assessment of the effects of RDPE environmental land management schemes on air quality. Centre for Ecology and Hydrology, Edinburgh.

8 6.5 A clear lesson from the monitoring and evaluation of current and previous schemes is that they are most effective when they are designed and targeted to achieve specific environmental objectives and when they are supported with good quality advice. A problem with such schemes in the past has been that they have often not achieved the coverage needed to address environmental problems at the scale required. 6.6 Several past schemes have achieved high levels of uptake, including the Environmentally Sensitive Areas (ESAs) and Entry Level Environmental Stewardship (ELS). Monitoring and evaluation have however shown that high levels of uptake do not automatically mean high levels of environmental delivery. These schemes have not always got the balance right between uptake and the impact of activity, with uptake targets and budget spend often the dominant policy drivers. The additionality provided by ESAs was limited due to unambitious objectives.21 Flaws in the design meant that ELS demonstrated limited benefits (despite widespread coverage) compared to the higher management intensity of HLS.22 6.7 It should however prove possible to improve the performance of large scale ‘entry level’ schemes. Defra commissioned a major review of ELS, known as ‘Making Environmental Stewardship More Effective’ (MESME)23. This identified several ways in which ELS could have been made more effective, including the introduction of an element of directed option choice, and it is important that lessons are learned from this exercise. 6.8 Reversing the decline in specialist farmland bird populations is a good example of this. Higher Level Stewardship was able to provide the right management but lacked the coverage to turn around overall population levels in England. Entry Level Stewardship achieved very high coverage (70 per cent of farmed land at its peak) but did not provide the range of management interventions necessary to provide for the needs of these birds. 6.9 To meet the ambitions of the 25 Year Environment Plan ELM will need to combine the clear targeting and prioritisation of current higher-level schemes with the large- scale uptake that, to date, only entry level schemes have achieved. This will require adequate resourcing and clear targeting and prioritisation to optimise delivery across the objectives.

6.10 The way in which the different components of ELM interact needs to be properly thought through to avoid the mistakes of the past. The design of previous agri- environment schemes has sometimes been complicated because the way in which the different components of that scheme interact in practice have not been fully thought through. The original design brief for Environmental Stewardship required that the holders of Entry Level Stewardship agreements should be able to enter into

20 Warner, D.J., Tzilivakis, J., Green, A. and Lewis, K.A. 2020. Establishing a field-based evidence base for the impact of agri- environment options on soil carbon and climate change mitigation – phase 1. Final Report. Work package number: ECM50416. Evidence Programme Reference number: RP04176. Natural England. University of Hertfordshire 21 Defra (2004). Appraisal of Management Agreements under the Environmentally Sensitive Areas Scheme 22 Heard, M.S., Botham, M., Broughton, R., Carvell, C., Hinsley, S., Woodcock, B., Pywell, R.F. in press. Quantifying the effects of Entry Level Stewardship (ELS) on biodiversity at the farm scale: the Hillesden Experiment. NERC Centre for Ecology and Hydrology. http://publications.naturalengland.org.uk/publication/5764018810650624 NECR133 Monitoring the impacts of ELS: http://publications.naturalengland.org.uk/publication/5518902616391680 23 Defra and Natural England (2013) Making Environmental Stewardship More Effective (MESME) http://publications.naturalengland.org.uk/publication/5662762122870784

9 Higher Level Stewardship agreements without having to amend their entry level agreement. Although a laudable aim, this greatly complicated the design of Higher- Level Stewardship, requiring multiple payment rates, alternative prescription sets etc. It is important that lessons are learned from this in the design of ELM, so that the three components can inter-relate as simply as possible. 6.11 The interactions between ELM and the other regulatory processes to which land management is subject need to be carefully considered. There are existing regulatory processes that need particularly careful consideration in the development of ELM For example, SSSI consents and those relating to the felling of trees and the establishment of new woodlands. The way these processes interact with Countryside Stewardship should not be a model for E.L.Ms. Other processes that need to be considered include those relating to scheduled ancient monuments and those relating to estates that have been granted Inheritance Tax Exemption. 6.12 Monitoring and evaluation have shown the value of requiring a farm-level baseline audit of resources, feature condition and opportunities, supported by access to geographic information and external sources of data such as information on historic environment features. This informs agreement planning but is also integral to effective agreement and scheme monitoring. Agreement set-up and subsequent management and monitoring also needs to be supported by effective documentation of objective setting, decision making and advice. The evaluation of HLS agreements24 and thematic monitoring has shown a lack of documentation to hamper full analysis and evaluation of cause and effect. As noted in the answer to question five, it is important not to categorise such important information gathering as a ‘bureaucratic burden’. 6.13 Experience from past schemes indicates that a variety of incentives can encourage uptake, but too many schemes and elements of them or lack of clarity on how they fit together can lead to confusion, reduction of trust and diminishing uptake25. 6.14 Some sectors including poultry and dairy have typically had low levels of engagement with current and past schemes, in part due to few relevant options being available, but have significant impacts on soil, air and water quality. Widening eligibility alone isn’t enough; the scheme design needs to cater for different types of participant recognising differences between areas. 6.15 The marginal economy of upland farming means the sector is particularly affected by changes to schemes and market impacts. While the quality of environmental outcomes from CS in the uplands has increased through better targeting of priority features, the appetite for these highest quality higher tier agreements has been less than expected. A different model, properly incentivised and supported, will be required to produce the levels of environmental outcome delivery required under the 25YEP. 6.16 Most schemes to date have been based on paying farmers to carry out defined actions, rather than directly for achieving environmental results. Pilots of schemes offering payments for results have shown that they increase farmer engagement and produce better outcomes26. The self-monitoring required in payment for results

24 Mountford, J.O. & Cooke, A.I. (editors), Amy, S.R., Baker, A., Carey, P.D., Dean, H.J., Kirby, V.G., Nisbet, A., Peyton, J.M., Pywell, R.F., Redhead, J.W. & Smart, S.M. 2013. Monitoring the outcomes of Higher-Level Stewardship: Results of a 3-year agreement monitoring programme. Natural England Commissioned Reports, Number 114.

25 https://www.sheffield.ac.uk/geography/research/projects/agri-environmental-governance-post-brexit/project-outputs

10 schemes can help farmers and land managers can gain a much deeper understanding of what they are being asked to achieve, and this sense of understanding, ownership and pride is a major driver of engagement and hence outcomes. 6.17 This suggests that it would be desirable to include an element of payment for results in ELM though there are technical difficulties with this approach, most notably the definition of indicators, that would make a wholesale switch to payment for results difficult. A step toward a greater focus on outcomes may be the written Indicators of Success that have been a feature of ES and CS. These work best when simple and tailored to the farm, to allow land managers to assess progress against their agreement objectives and give a clear sense of the progression that might be expected throughout the lifetime of an agreement. 6.19 Trusted, good quality advice transforms land manager participation in and quality of engagement with AESs. Evidence shows that advisors are key to building land managers’ ownership of environmental impacts and their motivation and ambition to engage in environmentally friendly practices. Direct advice is important in establishing agreements that deliver a range of outcomes, including providing evidence that results are achievable – to build confidence and enthusiasm, and helping integrate environmental outcomes with business planning. 6.20 It is important that advice can cover the range of management needed to achieve all the outcomes that ELM aims to achieve. Advising on the safeguarding of cultural heritage may, for example, require a different set of skills from that required to advise on the conservation of biodiversity. 6.21 Other advice formats, such as one-to-many, can work but usually only if trust is built through one-to-one engagement and the relevance of messages to a local, or ideally farm, level is apparent. Co-operation between land managers can have a range of benefits including knowledge exchange, sharing resources and local planning and prioritisation, but generally requires facilitation by trusted individuals. Generic advice as typically delivered through written material including online, or information events, can help raise awareness and clarify details but on their own are insufficient to motivate, change behaviour or address skills gaps. 6.22 The importance of an efficient process for developing applications managing agreements and making payments was briefly mentioned above. The lessons from previous schemes are set out in more detail here. 6.23 Under CS, the compliance requirements placed on land managers are viewed by many as overly complex and demanding, and the approach to enforcement has been widely seen as overly punitive and harsh, and not balanced by positive recognition for good delivery. Research suggests that agreement holders are looking for personal positive feedback and for some public or formal recognition. The ELM compliance system needs to be proportionate, risk based, fair and supportive. This will allay much of the current concern about SFI standards. 6.24 Application processes in previous schemes have been too complex, and, until recently payments late. The rationale for, and specification of, evidence has not always been clear, and collection/submission has been burdensome and expensive. Farmers have often needed additional self-funded assistance to complete their applications. ELM will need a process of scheme application, administration and

26 Chaplin, S., Robinson, V., LePage, A., Keep, H., Le Cocq, J., Ward, D., Hicks, D., and Scholz, E., (2019). Pilot Results-Based Payment Approaches for Agri-environment schemes in arable and upland grassland systems in England.

11 verification that is as simple as possible without compromising the environmental effectiveness of the scheme. 6.25 Timing of application windows can influence scheme uptake and the smooth operation (or not) of the scheme. The single start date for CS created a spike in applications at the very end of the application window, which then meant applications weren’t processed in time. 6.26 An opportunity to amend agreements over time could be valuable. CS has been criticised for providing limited opportunity for participants to amend agreements over time to allow for changes to support delivery. 6.27 CS participants, where they have broadband access, generally find the scheme’s online platform to be too complex and cumbersome in its processes.27 The computer system that was developed for CS is the same system used for BPS and there have been issues as the system isn’t entirely suited to the needs of CS.

January 2021

27 Short C, Lewis N, Reed M, James R and Jones N (2018) Initial Evaluation of the implementation of Countryside Stewardship in England in 2015/16: Applicant and Non-Applicant survey, Final Objective 1 Report, to Natural England by the Fera Consortium. Countryside and Community Research Institute: Gloucester.

12