Norfolk FWAG will be making the following response to the DEFRA ELMS Policy Discussion Document

Do you have any comments on the design principles on page 14? Are they the right ones? Are there any missing?

The design principles as set out in the ELM policy discussion document, are generally well considered. One area which should be considered more fully in the design principles, is how the public will be encouraged to interact with, and understand the public goods that are being managed, restored and created for their benefit through the scheme. It is essential, if the ambitions of the 25yr Environment Plan are to be realised, that the general public is more deeply engaged with rural land management, how our landscapes are managed, and why. We are very pleased to see the principle of flexibility and would encourage that this is maintained at every key step in the continuing design process, as it is key to the success of the scheme. Flexibility in the scheme, when coupled with timely payments and competent advice will ultimately lead to the best outcomes.

Do you think the ELM scheme as currently proposed will deliver each of the objectives on page 8?

If the levels of complexity can be kept to a minimum and the amount of flexibility to deliver can be maximised, then the scheme should deliver the objectives. It is also important that the scheme is as inclusive as possible for different types of landowners, and land types, if it truly wishes to deliver against all of the objectives. Uptake of the scheme by as many land managers and farmers across as many land types, at different scales and varying levels of involvement, is required to achieve the aims of the 25yr Environment Plan.

What is the best way to encourage participation in ELM? What are the key barriers to participation, and how do we tackle them?

As the consultation already identifies, setting and importantly maintaining the correct payment rates and payment dates, would remove one of the key barriers to participation of the scheme.

The other barriers to participation are centred around reducing complexity, ensuring an element of progression within the scheme and a suitable level of advice and support throughout.

There is also no small amount of work required by DEFRA and it’s arm length bodies of Natural England and the RPA to restore the trust of farmers and land managers for how the current scheme have been run and administered. This task should not be underestimated. The continuous improvement, simplification and timely payment under the current available scheme might go some way to addressing this point ahead of the arrival of ELMS.

For each tier we have given a broad indication of what types of activities could be paid for. Are we focussing on the right types of activity in each tier?

Broadly yes, we consider that a 3 tiered approach should work well, as long as option selection from different tiers within one agreement is possible, and that all tiers are appropriately funded.

It is also necessary to quickly gain a greater understanding of how Tier 3, or for that matter Tier 1 and 2, might interact with the upcoming policy for compulsory Biodiversity Net Gain and biodiversity off-setting. It is important that ELMS, Net Gain and other sources of private money, seeking nature based solutions, complement each other and do not restrict investment that would achieve the aims of the 25 year Environment Plan.

Delivering environmental outcomes across multiple land holdings will in some cases be critical. For example, for establishing wildlife corridors or improving water quality in a catchment. What support do land managers need to work together within ELM, especially in tiers 2 and 3?

There is a desire from landowners to work more collaboratively, as is shown by the rise of farm clusters and facilitation funding. This must be supported by trusted, local, independent advisers with the knowledge and energy to bring farmers together. Future funding of for this needs to enable some flexibility of delivery, as one to one advice and support, is essential to build relationships. Direct financial support for collaboration should also be provided to take into account the extra complexity, communication and time required to work in this way.

One other key aspect comes back to the issue of flexibility within the scheme. In order to allow proper collaboration, individuals agreements must be flexible, with the ability to amend and change to reflect new ambitions or objectives, as they come together with others to realise greater goals.

While contributing to national environmental targets (such as climate change mitigation) is important, ELM should also help to deliver local environmental priorities, such as in relation to flooding or public access. How should local priorities be determined?

Local priorities should be determined by all the local stakeholders, using existing datasets, policies and documents. This should be a bottom up approach by speaking with and listening to the local community about what they would like to get from their local environment. If the new system can bring in this level of local inclusion it will reap the benefits across many different aspects of society from health and wellbeing to economic vitality.

What is the best method for calculating payments rates for each tier, taking into account the need to balance delivering value for money, providing a fair payment to land managers, and maximising environmental benefit?

In general, we consider the payment methodologies that are set out in the policy document to be suitable, ranging from income forgone and costs, market-based pricing and straight procurement where suitable. It is important that payment rates are not set in stone and move over time to reflect market conditions and commodity prices, to ensure continued strong uptake of options. Payment rates could also consider an element of opportunity foregone in order to increase uptake. We would encourage the devolving of some elements of the budget, potentially in Tier 2, to a county or regional decision-making forum, who can ensure that it is being targeted at local priorities effectively.

To what extent might there be opportunities to blend public with private finance for each of the 3 tiers?

We consider that a scheme designed so that it can accommodate the blending of other public or private monies is essential in Tier 3 and would be equally beneficial in Tier 2 or 1. By the time the scheme becomes live our thinking around natural capital maybe further advanced and the scheme must be not conflict with any payments for the provision of other ecosystem services

As we talk to land managers, and look back on what has worked from previous schemes, it is clear that access to an adviser is highly important to successful environmental schemes. Is advice always needed? When is advice most likely to be needed by a scheme participant?

Advice ahead of participants taking up a scheme is always necessary and most critical to ensure that a proposed scheme fits, supports and enhances current and future business direction. It is also important that all of the possible opportunities on a landholding are scoped out, regardless of whether they are eventually pursued. Experienced advisers, who have worked in a patch for many years and have formed lasting relationships, are expert at these kinds of conversations.

Advice is most critical in the establishment years of a scheme and can often come from many different places. Advice must have an understanding of farming and farmland ecology, be independent, impartial, qualified and well founded. Free advice is not always good advice. A range of specialist advisers can also be necessary depending on the focus of a project, water, soil, biodiversity, landscape, woodland or socio-economic.

We do not want the monitoring of ELM agreements to feel burdensome to land managers, but we will need some information that shows what’s being done in fulfilling the ELM agreement. This would build on any remote sensing, satellite imagery and site visits we deploy. How might self-assessment work? What methods or tools, for example photographs, might be used to enable an agreement holder to be able to demonstrate that they’re doing what they signed up to do?

Self-assessment is a useful tool and will encourage farmers and land managers delivering the scheme to engage more with the delivery of the scheme, this can already be seen from the early results of the Payment by Results trial. This should be backed up by local expert advice and continued guidance – natur doesn’t always respond how you might expect or would like and flexibility to react and change, under the guidance of an experienced adviser, will lead to the greatest results. If the scheme were to provide for a day’s advice a year for every agreement, this would almost certainly lead to an overall improvement in the quality of delivery, and a greater number of agreements reaching their objectives.

Do you agree with the proposed approach to the National Pilot? What are the key elements of ELM that you think we should test during the Pilot?

One of the key aspects that the National Pilot should ensure is that the basic end to end functionality of the scheme processes are working properly, i.e. scheme literature (online and in handbooks) all tallies up, qualified advice delivery, legible and meaningful agreement documents and most importantly for farmers, timely payments every 6 months within the agreement year, rather than 12-18 months in arrears. Farmers and land managers cannot be expected to bank roll tax payers’ public goods.

Do you have any other comments on the proposals set out in this document?

We would like to re-iterate that if the ambitions of the 25yr Environment Plan are to be realised, it is essential that the general public is further engaged with rural land management, how our landscapes are managed and why, not to mention where our food comes from. This support is essential to ensure that the scheme is properly funded and respected by the public.

The scheme must be kept simple and flexible at all costs to ensure a good uptake. It would be great to have a scheme that farmers and land managers are keen to take up, are properly rewarded for their work and then properly regarded by the general public for the work they do for the environment, our wider countryside and the high quality food they produce.