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Our response to farming consultation: “Yes, but…”

Bainbridge, 15 May, 2018

The government’s “direction of travel” for food, farming and the environment post-Brexit is spot on, but the plans have serious “shortcomings”, National Parks England (NPE) has said.

Acting on behalf of the Yorkshire Dales National Park Authority (YDNPA) and England’s other National Parks, NPE has submitted a 28-page response to Defra’s major “Health and Harmony” command paper consultation.

NPE says there are omissions in the list of public goods that should attract payments in a new system of farm support, and describes the plans for rural development as “too weak”.  The response also makes clear that farmers’ livelihoods – particularly in the uplands – are at stake, along with recent environmental gains.

The YDNPA has formally identified post-Brexit farming policy as being of “critical” importance.

YDNPA Chairman Carl Lis said:  “It is hard to overstate the size of the opportunity at hand. Here is a chance to make upland farming pay again, while dramatically improving the state of the environment.  Yet if we get the transition to a new system of farm support wrong, rural poverty could increase and communities could be lost, as could environmental gains achieved over many years.

“Perhaps the most important point we have made is that the proposed new Environmental Land Management scheme (ELMs) must avoid a system of national prescription that prevents local flexibility.  Broad parameters could be set nationally – and we are delighted with direction of travel towards an outcome-based scheme that makes ‘public payments for public goods’.  But it is absolutely vital that large amounts of discretion are granted to those who will implement the scheme with farmers and landowners at a local level. All the experience and the knowledge of the land that farmers have must be utilised.

“As the paper says, we believe an outcome-based approach should be a fundamental underlying principle for the new ELMs. This means changing to a culture of positive reward for delivering environmental outcomes rather than compensation for loss of production.”

The NPE response made several constructive criticisms of the command paper, including that:

  • Proposals to preserve rural resilience and traditional farming and landscapes were “too weak and underdeveloped”.  The response says that the ELMs should not be “divorced” from rural development.  “Supporting the continuity of active farming families and communities is critical to maintaining and delivering the full range of public goods and benefits outlined in the command paper,” it argues. 
  • Paying only for environmental “enhancements” could unwittingly penalise farmers who have been good custodians of the land.   The solution would be to create payments for environmental conservation as well as enhancement. 
  • Public access needed greater emphasis.  The NPE response says farmers and landowners should be paid for providing a joined up and integrated access network including to areas of open access.
  • Water management was omitted from the list of public benefits that might be delivered through the new ELMs.  Water management payments would reward farmers for reducing flood and drought risk and increasing resilience to both.   
  • Too little recognition was given to the role the ELMs could play in the protection of the historic environment.  
  • Urgent action should be taken to extend existing Higher Level Stewardship schemes that are due to expire in order to protect past investment in public goods.  

The full link to the NPE response is: http://www.nationalparksengland.org.uk/__data/assets/pdf_file/0016/1211704/National-Parks-England-response-to-Health-and-Harmony-Command-Paper-May-2018-.pdf

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