Below is our response to the ongoing DEFRA consultation on Environment Land Management. The consultation closes on 31st July 2020.

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

I think the overall design principles look sound. However, I am concerned by the absence anywhere in the consultation document of the mention of perennial energy crops (PECs) such as short rotation coppice (SRC) or miscanthus. A great deal of public money has been spent on looking at the potential for PECs to assist meeting climate change and renewable energy targets and providing natural capital and ecosystem services. Virtually all the reports produced (e.g. Energy Technogies Institute (ETI), Climate Change Committee (CCC) and countless academic institutions) come to the same conclusion that PECs are required and in large areas. The CCC suggests 23,000 hectares per year. Hence, the design principles must take on board the findings of academic research and arrive at a scheme which promotes planting of these crops in the most appropriate areas.

If PECs are not included in the scheme you are in effect leaving one of your best toolbox items in the shed. It is important not to leave it in the shed or even in the toolbox but to use these tools widely and exploit the potential of these highly versatile multi-functional environmental crops.

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

It appears that the consultation is not being too prescriptive about what is covered. My worry is that unless SRC and miscanthus are mentioned from the outset then they will not be included. There are so many natural capital benefits and ecosystem services to be derived from perennial energy crops either alone or in when integrated with other crops and livestock (e.g. silvoarable and silvopastoral schemes) that they need to be at the forefront of this scheme alongside woodland creation and hedgerow management. Science suggests that the greatest biodiversity benefits are achieved from SRC (and miscanthus) when strips are planted given a great deal of edge effect. This maximises the habitat for predatory arthropods and other beneficial insects which could potentially help sustainable food production with lower pesticide inputs. This practice should be encouraged. Some willows in particular produce valuable pollen and nectar sources in the late winter and early spring. If planted in the correct location this could help maintain and rebuild pollinator populations whilst also providing wind break potential for high value pollinated crops.

The perennial energy crops sector is small and it is easily muscled out by competing forces e.g. food, forestry, conservation sectors etc. As the answer to Q6 says the science has been done and this points to PECs being of the utmost importance. Objectives will only be met if PECs are included more specifically.

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

A lesson can be learned from the Energy Crops Scheme (ECS) and the Renewable Heat Incentive (RHI). The former was bureaucratic and not massively rewarding to growers and only supported establishment and didn’t create markets or help with the supply chain. There was also no uplift for planting in areas where these crops could help with flood prevention (whereas there were substantial additional payments for woodland planting which do the job less well and take a lot longer to achieve results). The ECS was massively undersubscribed. The RHI is also bureaucratic but the rewards warranted the hassle – it was in effect a “no brainer” and as a result 25,000 biomass boilers have been installed. Therefore, the scheme was the necessary “game changer” that the biomass industry warranted.

The status quo is a powerful thing particularly with a sector (farming) with an average age of 59. In order for the agriculture sector en masse to be persuaded to enage in new practices for the sake of the environment then the offer has to be very appealing. If it is not then the majority will stick with the status quo.

9. 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?

Perennial energy crops (PECs) should be a viable option for all three tiers. There is increasing appetite for planting energy crops because of the end of subsidies for sheep farming and reduced areas of Oilseed Rape (OSR) being planted.

• Tier 1 for instance could involve a farming company using an SRC crop to dispose of processing effluent e.g. dirty water from washing potatoes or carrots or dairy parlour run off. This could have a massive impact – fewer tankering vehicles on the road, lower carbon emissions, cleaner air and massive financial savings. One of my clients could save over £150,000 per year by using a willow biofiltration plot instead of exporting carrot washings from their processing site.
• Tier 2 could encourage several farms to plant SRC and miscanthus in appropriate places in say, a local project aimed at reducing flood damage
• Tier 3 could deliver a regional energy crops fund in order to encourage PEC planting to service a biomass combined heat and power (CHP) district heating for a town or village. I have provided a fully costed example of this in a past consultation response for the 2014 CAP reform – it can be found on page 16. 
  Even with a rounded approach to funding and enhanced payments this presents significantly better value to the tax payer than woodland plantings (although that is not to say that these aren’t required as well).

However, a long term energy crop is still a difficult decision for a farmer or land manager to make. Placing PECs as an option in all three tiers and rewarding growers appropriately for the many benefits that these crops can provide will enable more sustainable farming industry, local environmental benefit and meet net zero targets.

10. 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?

For Short Rotation Coppice (SRC) in particular there is the need for investment in machinery so that it can be deployed locally at an affordable price for growers. Until the industry is very well established it is too much to expect that contractors will invest heavily without some support. This could be delivered as apart of a regional energy crops scheme as mentioned in the response to Q9.

11. 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?

If you study maps of England that show areas where flooding is a problem, where water quality is a problem (e.g. Nitrate vulnerable Zones), where forestry cover is low , where pollination services to food crops are most important and where greater numbers of households are off the gas grid and fuel poverty is highest you will notice a significant correlation. There is a very strong argument for focussing the planting of perennial energy crops (PECs) and trees in several areas where they will help meet multiple objectives at once. Areas which I think would be well suited to a regional project would be the SW (particularly Somerset), Cumbria, Herefordshire & Worcestershire, East Anglia and North Yorkshire.

Several of these areas also include upland areas dominated by sheep farming – i.e. less favoured areas that are no longer able to compete without subsidies so a regionally applied scheme would provide a shot in the arm to these farmers.

12. 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?

I think a good starting point would be an evaluation of a regional Energy Crops Scheme – I have already presented an analysis of this. Pg 16 of this link.

Perennial energy crops (PECs) would be made a much easier concept to sell to land managers if the payments were better and approached those for Woodland creation. If the payment level is set too low you will get low take up. Academic studies have shown that in order for farmers to be persuaded to change land use the return needs to be signicantly better than what they are currently doing. See Paulrud & Laitila (2010) 34 (2010) 1770 -1779 Farmers’ attitudes about growing energy crops: A choice experiment approach.

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

Flooding events are devastating, incredibly disruptive and very costly. They are also increasingly frequent. Each year £billions of insurance money is paid out to victims. This is untenable and will lead to increased insurance premiums. The insurance sector could be sought to be more pro-active and invest in tree planting and perennial energy crop (PEC) planting schemes where significant benefits could be achieved. SRC and miscanthus have higher hydraulic roughness and achieve this in a fraction of time compared to woodland creation. These plantations when established in the right place can act as green leaky dams and delay the flow giving people downstream more time to react and get valuables out of harm’s way. Similarly, PECs stop objects from travelling downstream and blocking bridges and other culverts. This prevents dangerous objects from causing damage and could ensure that there is less water backing up from a blocked waterway. SRC harvesting can be delayed if there is a flood incident. It is also resilient to being inundated with water for 2-3 months. This versatility should be rewarded. If insurance companies could be encouraged to invest in PEC establishment and management schemes then this would certainly help reduce expenditure, prevent damage to infrastructure and save lives.

14. 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?

The perennial energy crops (PECs) sector is small but the majority of actors involved have enormous experience of land preparation and management. The ELMS scheme should be reaching out to work with these protagonists at an early stage in order to correctly position PEC planting within the framework and ensure it is done properly.

I think it makes sense that there be minimimum requirements to becoming an an adviser. Any adviser should have sufficient experience (e.g. 5 years working with PECs) to qualify. Otherwise there is a chance that jobbing consultants will jump on the bandwagon and be providing advice without having the necessary technical expertise.

15. 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?

With perennial energy crop planting it is important to achieve the best practice stocking rates. It is fairly easy during the establishment year to do quadrats and work out if this has been achieved. If gapping up is necessary then evidence of material purchase and labour (e.g. invoices) could be submitted. Drone pictures might also help.

16. 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?

As per Q6 & Q7 the National Pilot has to include perennial energy crops as part of the options looked at. The science indicates the need and the benefits and DEFRA and other Governmental bodies must recognise this and ensure that it is part of the portfolio. As I have indicated in Q14 there are a number of hugely experienced protagonists in the perennial energy crops sector that can be consulted to design these projects in various parts of the country that would benefit e.g. SW England, Herefordshire & Worcestershire, Cumbria, East Anglia and North Yorkshire.