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Sustain Brexit Consultation responses

Sustain provides evidence to Efra committee on Health & Harmony, April 2018

Vicki HIrd of Sustain with alliance members Peter Stephenson (CIWF), Helen Browning (Soil Association), Professor Tim Lang (Food Research Collaboration, City University)

Vicki HIrd of Sustain with alliance members Peter Stephenson (CIWF), Helen Browning (Soil Association), Professor Tim Lang (Food Research Collaboration, City University)

Sustain provided written and oral evidence to the  Environment, Food and Rural Affairs Committee Inquiry into the Government’s consultation: ‘Health and Harmony: the future for food, farming and the environment in a Green Brexit.’ 

At the oral evidence session on 25 April 2018 Vicki Hird spoke of the need to address public health as a public good alongside social, ethical and environmental goods, and to take account of farm diversity and farmworker's needs. She highlighted public procurement as an opportunity, the need to maintain high standards in any trade deal  and for greater regulation to ensure fair play in the supply chain.

Sustain alliance written submission for EFRA Committee Inquiry: Work of DEFRA: Health and Harmony inquiry

About Sustain

Written evidence submitted by Sustain: the alliance for better food and farming. Sustain advocates food and agriculture policies and practices that enhance the health and welfare of people and animals, improve the working and living environment, enrich society and culture and promote equity. We represent around 100 national public interest organisations working at international, national, regional and local level. Sustain coordinates the Sustainable Farming Campaign, the Fish Cities Campaign, the Campaign for a Sugary Drinks Tax and the Sugar Smart campaign. We work with our members and others to promote integrated healthy and sustainable policies and practices for food, farming and fishing. This submission has been produced from Sustain agreed positions and core concerns of the members and in particular the Sustain Farming Working group. This does not however necessarily imply endorsement of every detail by the member organisations.


Sustain believes that the purpose of future agriculture policy should be a prosperous, resilient and sustainable farming system that provides healthy food grown to high standards of animal welfare, environment and nature protection. Farming must be able to provide good food, as well as good livelihoods, supported by fair prices and trading practices. Farming must also play its part in reducing the greenhouse gas emissions that cause harmful climate change.

Achieving this vision requires an integrated policy, a sufficient budget and a strong regulatory baseline, with incentives for farmers and land managers to make the transition to better practices where the market will not pay and new training, advice and research strategies. It also requires government to identify and support better food and farming as a core priority and to redefine productivity to deliver on wider objectives. We have previously circulated our agreed and endorsed paper ‘Beyond 2020 New Farm Policy’. This outlined a new set of principles and a policy framework to deliver a new sustainable and viable future for UK food and farming.  We have the following comments in response to your questions in addition to that paper:

Q 1 What will the consequences of the withdrawal of Direct Payments be?

Sustain agrees that the Direct payments need to be replaced but has considerable concerns that withdrawal of direct payments without a comprehensive and well-designed new policy framework could have catastrophic effects on farm businesses, rural economies and food supplies. This new framework needs to cover not only a new support and capital schemes, wider support for business development, training and advice, but also supply chain regulation to remove unfair trading practices, as well as trade policy that guards against unfair competition from imports produced to lower standards. Sustain welcomes the proposals to cap payments to ensure the money goes where it is needed, is more fairly and appropriately distributed, and so more funds are available for public goods. The final decision on this should be based on good impact modelling.

For smaller businesses which play such a key role in the countryside we are particularly concerned and published a joint statement arguing for specific measures. The Command paper does mention rural resilience but focus must go beyond the uplands.

Sustain and its members argue that having a diversity or range of farm sizes and types is vital to ensure a thriving farming and rural industry, available and attractive to new entrants, progressing farmers and producing a healthy countryside. Yet there has been a dramatic loss of English farms over the past decade threatening damage to landscapes, rural jobs and cohesion and habitats. Now there is a major risk of further loss of a mix of farms, and small and medium sized farms in particular, unless safeguards are put in place for when we leave the European Union.

We need clear acknowledgement of the need for safeguards in new national policy and for specific measures to rebalance support to strengthen the dynamism, innovation and sustainability of smaller enterprises, including: redistributed support i.e. the best way to achieve the fairest and most effective distribution of future support so that the future farm support budget is more evenly shared;  targeted support to ensure that only active farmers are eligible for on-going support and that schemes are targeted and designed to ensure active farmers on small to medium sized farms get adequate support for delivery of public goods; concentrating investment i.e.  provide accessible and well-advertised grants, low/no interest loans or loan guarantees targeted to smaller and medium-sized farm business to deliver specific tools to maintain or boost important sectors; delivering training, mentoring and advice accessible to smaller and medium-sized farms; and reviewing land issues including length of tenancies and loss of country farms. In a longer briefing we outline the evidence of why dynamic farm diversity matters and describe a set of approaches which will help that diversity to be maintained to ensure new entrants, progressing farmers and entrepreneurs can thrive in UK farming.

Q2 To what extent do the Government’s proposals support farmers to improve their profitability and prepare for the new agricultural policy?

Three key issues are relevant here. How far will there be sufficient funds to ensure all farmers have access to good quality advice and mentoring not only in terms of business planning, benchmarking, new marketing, succession planning and so on but also training on delivery of the integrated environmental and social benefits being asked for.

The second is the pilot and transition phase. We need strong socio- economic (jobs and incomes supported, volatility mitigated, local multiplier effect) as well as environmental evaluations of the pilots and plenty of time to test them. We also need regular, ideally an annual, review process built into the new UK Agriculture Bill that ensures full, transparent and effective review of the new policy and how well it is working towards delivering its purpose.

Finally and crucially, the Health and Harmony submission recognised the need to achieve supply chain fairness and end unfair trading practices– to help ensure farmer profitability - but does not give adequate proposals to achieve this and the current Groceries Code Adjudicator (GCA) only covers part of the supply chain. It is clear we need a new enforced code of conduct to support fairer purchasing practices in the parts of the agri-food supply chain not covered by the Groceries Supply Code of Practice (GSCOP).

Given that the European Union is also introducing a new measure for addressing unfair trading practices in the whole supply chain this would be a timely and appropriate approach. It would also ensure UK producers are not unfairly disadvantaged as being unable to make complaints of UK companies unlike their European counterparts.  The Command Paper refers to ‘codes of conduct’, suggesting that the Agriculture Bill might introduce voluntary codes that would govern purchasing practices in different agricultural sectors. Sustain suggests this would be an unnecessary complication, create confusion and potentially weaken any impact especially if any kind of voluntary approach is used. It would be far simpler to develop a single code covering purchasing practices across all agricultural supply chains.

Q3 The Government plans to base the new policy on public money being used to pay for public goods. To what extent do you agree with this approach? What public goods should be supported?

Sustain agrees with this approach and believes the kinds of public goods should be broad including a full range of environmental and biodiversity benefits (including protected water, soil and air), rural development and rural cohesion based on sustainable farming and growing, and animal health and welfare.

The four policy strands the Sustain alliance proposes include:

  • A new, universally available Land Management Support scheme with three elements: a menu of outcomes; an organic scheme; and a whole-farm scheme. Specific LMS strands would be available to boost agro-forestry, extensive pasture-based livestock, horticulture; new entrants and succession planning. There is a strong case for front loading and/or capping payments to use the support wisely;
  • Sustainable business, capital and infrastructure support with specific help for smaller businesses;
  • A new publicly funded programme of low-cost advice and support for a farmer-to-farmer advisory network;
  • Wider policy framework reform including: maintaining and enhancing land-based regulations to prevent harm; a strengthened and extended Groceries Code Adjudicator to protect farmers from unfair trading practices and policies to encourage retail diversity; maintaining organic legal standards; labelling regulations to drive up demand for food based on higher standards; reforms to tenancy rules; strong labour regulations to value farm workers and enhance employment and re-employment; high public procurement standards and delivery; and trade policies that promote these commitments. 


  • Sustain is also championing public health as a public good – currently largely absent from the ‘public goods’ approach so far, despite ministerial emphasis in speeches. Recognition of public health as a public good could help pave the way for beneficial improvements to farming standards, investment of public money and publicly supported research and development. Public health expressed as a public good could include, for example, support for activities:
    1. contributing to healthy diets by reducing the health and economic burden of diet-related disease and making sustainably produced, fresh food available, affordable and accessible to all, by for instance:  
      1. more and diverse horticultural production based on sustainable methods and decent working conditions,
      2. specific support for diversification away from producing products we should be reducing in our diets, such as sugar (links to separate EFRA committee submission),
      3. better household food security, better working conditions in the food and farming sector as a whole (notorious for low pay and precarious jobs)
    2. reduced or eliminated risk of food borne diseases;
    3. cessation of the prophylactic use of antibiotics in livestock farming, as well as reduction of antibiotic use overall through better hygiene and management strategies;
    4. reduction of pesticide use, exposure in the environment, and pesticide residues in food;
    5. tackling air pollution from farming such as ammonia;
    6. active promotion of access to countryside;
    7. policy and contractual requirements for fresh, healthy and sustainably produced food in schools, hospitals and other public sector institutions via public procurement measures, as well as helping diverse and sustainable farmers to access these contracts;
    8. active promotion and growth in acreage of beneficial farm systems that can deliver some – or all – of these outcomes such as organic, agro-ecological and agro-forestry.

Q4 How should the new policy based on supporting public goods be coordinated and delivered?

It is clear we need a scheme delivered by collaboration between public, private and voluntary partners and finance. The Common Agricultural Policy (CAP) was too costly, ineffective and too complex. Schemes do need to allow farmers to be flexible and innovative in achieving environment and climate and other goals in a way that is appropriate for the specific site conditions and they should reflect government policy in valuing innovation and entrepreneurship through the new scheme.

So we do need a scheme that is tested, flexible, under review and proportionate. But we need to embrace the reality that it may need to be a bit intricate and not let the ease with which schemes will be administered, controlled and verified be the main criteria for choice of scheme. The much derided CAP three-crop rule was too simple in design and probably did not fit UK farm types and landscapes. And support from the public purse will not come without strings - taxpayers will want to see results. An agreement will give farmers some decent financial reward in return for some specific reasonable actions (for instance to enhance farm biodiversity) plus some form filling and inspections which would reduce once the farmer is proven to deliver.

Farmers should get a decent living via the market (and we need better rules there via extending the Grocery Code Adjudicator and other policies) and via taxpayer support for what the market won’t pay for. The time taken to do form filling and inspections could be calculated and covered in the agreement. Skills development, mentoring, training and advice also need to be on tap and financed.

The new schemes need to allow farmers to be flexible and innovative in achieving environment and climate goals in a way that is appropriate for the specific site conditions and should reflect government policy in valuing innovation and entrepreneurship through the new scheme.

Certain farm systems like organic have been through the process of developing a comprehensive ‘contract’ and they’ve come out the other side of 50 years of development with a system based approach that is a useful approach – a prescription for the whole farm with known results for soils, nature, carbon, welfare and so on. It does not lack complexity but organic farmers agree to it because they have a whole-farm, knowledge-based system and gain both from the process and in the market place.

There is a common call for pilots and trials for new approaches and learning from current and past agri-environment schemes. One possible approach to governance and delivery could be defined in three levels: national; regional/local; and on farm.

National - setting the overall objectives - At the national government level, land management policy would be set integrating farming, food and the environment, forming the policy reference for delivering public goods and natural capital and fitting with an overall vision for food and farming. An overarching UK framework would set an agenda and targets for the public money to be spent wisely and to ensure cross border priorities are achieved such as on climate, landscape and mobile species. This would be signed off by the Secretary of State and Devolved Administration ministers in a four-nation approach, and would set the framework for landscape plans and objectives.

Local - Landscape approach to governance and allocating resources - Given that central government is not set up to handle local and live information about land use changes and opportunities, some have proposed a local level of governance, which would provide funding for locally valued ecosystem services and ‘fill in the gaps’ that arise from the operation of the national funds. Local governance organisations could be grouped eg via National Character Areas (NCAs) which divide England into 159 distinct natural areas, or current CAP divisions.

Each NCA is defined by a unique combination of landscape, biodiversity, geodiversity, history, and cultural and economic activity. Their boundaries follow natural lines in the landscape or other features rather than necessarily administrative boundaries. The maps describe what is there, appreciated and understood by communities and the different stakeholders. They could help form the framework for agenda setting, delivery, partnership working, integrating - public sector, private sector and voluntary sector collaboration. For protected areas additional resources and information already exist to deliver additional protection, support and advice.

A joint ‘committee’ could be made up of local community reps, farmers and landowners, park authorities, conservation bodies, private sector and planners, in facilitated meetings, who would devise a management plan for the area which would be signed off by the Secretary of State but which would remain a live document subject to reviews and change. From this, individual plans with appropriate indicators for progress for each farm in the area could be drawn up using the priorities. Where needed, the plans would focus on specific issues for a specific area with general wildlife and environmental assets and characteristics – what did and does and could be protected, enhanced and restored and by whom.

Farm – Land Management Scheme agreement - At the farm/estate level, the scheme would ideally have a single point of contact representing the public sector with each farm/farmer, with the back office support from Government Agencies, Government Departments and Local Authorities. This point of contact could perhaps combine with a private accredited body. But they would need a new set of skills, knowledge and would build a positive but impartial relationship with the farmer.

A farmer would develop with this contact, a multi-annual whole farm/estate Land Management Scheme agreement - one that farmers can work through with their advisor so it fits the farm and the catchment and the landscape as needed. Farmers would do much of the on-going assessment themselves, and would have training if needed. But there would need to be an initial agreement meeting, spot checks and an annual survey to discuss issues, look at new opportunities, compliance and so on. The idea often mooted of ‘earned recognition’ could be part of the process later but currently schemes are not generally appropriate in terms of capacity and skills. 

Q5 The consultation indicates a transition period will be needed. How long should this last and what lessons can be learnt from previous implementation of agricultural policy?

Sustain does not have a position on the length but it is clear we should have a decent period of transition, with new schemes being available to farmers when they are ready, given the need for farmers to plan especially in terms of long-term changes and investments needed. Sustain has critiqued the design and implementation of the CAP and RDR and agri environment schemes over the years as have many others and there is much to be learnt. One overarching issue is to ensure funding for well facilitated discussions on the pilots, reviews and final scheme design so that dominant voices are well managed and all expert views taken into account

Q6 In which areas should the Government seek agreement with the Devolved Institutions to ensure a common approach across the UK?

Sustain’s position is to not have a top down approach and that most of these areas should continue to be devolved. The nations could and should agree a consensual four-nation framework which maintains UK-wide structures and objectives where needed such as on trade policy and cross border environmental issues such as climate, nature protection (bird migrations, etc.). On issues of trade, ensuring cross border fairness will be vital and new arrangements must be subject to full transparency and accountability to the parliamentary process.

Brexit: We stand at a cross-roads. When the UK leaves the European Union, will our leaders uphold good standards for our food, farming, fishing and trade deals? And will they agree a sensible deal with the EU? We need to make sure that they do!

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Sustain advocates food and agriculture policies and practices that enhance the health and welfare of people and animals, improve the working and living environment, promote equity and enrich society and culture.

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