TFF Grassroots Group evidence submitted to Government

TFF Grassroots Group evidence submitted to Government Addition of Lords S&T Committee evidence

holwellcourtfarm

Member
Livestock Farmer
holwellcourtfarm submitted a new resource:

TFF Grassroots Group evidence submitted to Government - Evidence submitted to the EFRA commitee on the ELMS development

The TFF Grassroots Group is a group of 14 farmers who gathered by PM to discuss ELMS test and trials relating to grassland. When we heard that the EFRA Committee was holding an inquiry into the ELMS development we decided to submit our own evidence as we felt our views were not being represented by the organisations supposedly representing us at the highest level in the process. We were concerned that some of the issues we felt strongly about were being ignored and needed to be pointed out...

Read more about this resource...
 

holwellcourtfarm

Member
Livestock Farmer
Thanks @Doc and @Boysground

We've had quite a bit of support over the last 2 days for what we've tried to do. It's been quite hard work at times but we might just make some difference. Personally, if it all turns out to be a sh!tshow then I can rest knowing I tried.

Someone has to be prepared to say it like it is to those in power. Our representative bodies won't, for understandable reasons.
 

Kiwi Pete

Member
Livestock Farmer
They've never "had to think that way" before, most issues are manmade/complicated whereas environment is "complex", quite a marked difference between how you approach the two types.

Really, you could say that "agriculture" comes under not only the environmental umbrella, but also the health, finance, social development and various other portfolios - because agricultural policy affects all of this to varying degrees.

As you said, "understandable" ---- it's understandable how our societies are full of problems today, that siloed approach as opposed to a more holistic, realising-that-it's-all-connected approach.

Realising that following recipes got us into this mess and that recipes cannot get us out.
 

Boysground

Member
Mixed Farmer
Location
Wiltshire
What a great idea this 'new' resource section is BTW.
Cheers for putting this up Ian, after rereading it, it really is quite good.
I still have my reservations that "not being prescriptive" is going to be too-hard for policy-makers, but at least we gave it a bloody go!
Can't say we didn't try.

Your right, DEFRA think that every regulation in agriculture can be driven by date and as we all know it just doesn’t work like that. This has just come up with the changes to the manure applications by the EA. Which again is a do as we say or we will prosecute regulation. Discussion and consensus over time would just make life easier for everyone on both sides.

I am fed up with the implication by government and many of the population that as farmers we really do not understand the environment we work in and that we don’t embrace change. Something that couldn’t be further from the truth. Your document/discussion goes a long way to dispelling this, as long as it’s seen by the right people.

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holwellcourtfarm

Member
Livestock Farmer
Your right, DEFRA think that every regulation in agriculture can be driven by date and as we all know it just doesn’t work like that. This has just come up with the changes to the manure applications by the EA. Which again is a do as we say or we will prosecute regulation. Discussion and consensus over time would just make life easier for everyone on both sides.

I am fed up with the implication by government and many of the population that as farmers we really do not understand the environment we work in and that we don’t embrace change. Something that couldn’t be further from the truth. Your document/discussion goes a long way to dispelling this, as long as it’s seen by the right people.

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I feel a group needs forming to challenge the EA and DEFRA on this issue. The rules are being seen in isolation but have much wider ramifications.

It is clearly vulnerable on a number of grounds, not least that:
- Calendar dates for closed seasons are unscientific when nature is the subject
- The rules directly contradict the need to encourage increasing soil organic matter levels
- The rules have huge implications for sewage systems. We must find ways to return the nutrients in sewage to the land to close that nutrient cycle and this (along with the increasing contamination of modern sewage with plastic and pharmaceuticals) directly opposes that
- The rules take no account of practicality and deliverability
- The rules risk pushing farms toward spring cropping instead of winter resulting in falling food output (contrary to the NFS recommendations) leading to more "offshoring" of impacts
 

Boysground

Member
Mixed Farmer
Location
Wiltshire
This farm is mostly dairy with a decent amount of wheat, I feed 500t a year which obviously reduces food miles for the cows. My processor is calculating carbon footprints at the moment and this is bound to help. I have over the years made as much use of the slurry/fym as possible even putting slurry on wheat in the spring. This reduces my nitrogen bill, on 700 ac I do not buy p & k. I export a significant quantity to arable neighbours

My thoughts on the manure spreading ban is all spring cropping and probably at least doubling my liquid storage. So a massive cost for less output. With more reliance on decent weather in the spring. How is this a sensible solution to the problem.

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holwellcourtfarm

Member
Livestock Farmer
This farm is mostly dairy with a decent amount of wheat, I feed 500t a year which obviously reduces food miles for the cows. My processor is calculating carbon footprints at the moment and this is bound to help. I have over the years made as much use of the slurry/fym as possible even putting slurry on wheat in the spring. This reduces my nitrogen bill, on 700 ac I do not buy p & k. I export a significant quantity to arable neighbours

My thoughts on the manure spreading ban is all spring cropping and probably at least doubling my liquid storage. So a massive cost for less output. With more reliance on decent weather in the spring. How is this a sensible solution to the problem.

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It's a sensible solution if all you look at is N and P leaching in isolation.......
 

Goweresque

Member
Location
North Wilts
I applaud your efforts in attempting to influence the ELMS design process in ways that you consider better, and I think you paint a very good picture of what is wrong with the current setup, its obsession with rules and box ticking, its them and us attitude, and the distrust in Defra, the RPA, NE and other government bodies by the farming industry as a whole.

Where I find the submission a bit problematic is in the 'what we should be doing' section. Its very vague, using a lot of 'word soup' of phrases such as 'a holistic approach' and 'partnership between equals' etc etc. It sounds nice, and I'm sure that MPs on the committee reading it will love it, it ticks lots of boxes but I wonder what it actually means in practical terms. My experience of anything to do with bureaucracy is that if things are defined in bland and vaguely positive terms that no one could realistically be opposed to, the bureaucrats can then ram through all manner of practical nasties under that banner. I also think its naive to think that State bodies and employees will ever consider that private individuals are their equals, and engage with them on that basis. They have more power and money than 99.999999% of us. Maybe the likes of James Dyson can engage with the State on something approaching an equal basis but everyone else can't. And if the State is handing out money they aren't going to do that without some process for checking its not just being siphoned off and none of the agreed actions taking place. Fundamentally any relationship between private individual and the State is going to be one sided, its the nature of the beast. As my quote you use in you supplementary submission says, when you sup with the devil, use a long spoon!

I know its a bit much to expect 14 private individuals to design and entire agricultural/environmental support system, but I think at least a steer as to exactly how you might see your ideal system working in practise (as opposed to how ELMS is currently designed) would help. Maybe a worked example using your own farms and what measures would help you, and indeed reward you for what you are currently doing, and how such measures would be policed/enforced would be good?

The reality of human nature is that if Defra decided implement a scheme with little or no policing, a large proportion or recipients would take the cash and just continue doing exactly what they do today. How exactly does one square that circle between not being a overly rules and inspection based adversarial system and also not allowing people to take the p*ss?
 

holwellcourtfarm

Member
Livestock Farmer
I applaud your efforts in attempting to influence the ELMS design process in ways that you consider better, and I think you paint a very good picture of what is wrong with the current setup, its obsession with rules and box ticking, its them and us attitude, and the distrust in Defra, the RPA, NE and other government bodies by the farming industry as a whole.

Where I find the submission a bit problematic is in the 'what we should be doing' section. Its very vague, using a lot of 'word soup' of phrases such as 'a holistic approach' and 'partnership between equals' etc etc. It sounds nice, and I'm sure that MPs on the committee reading it will love it, it ticks lots of boxes but I wonder what it actually means in practical terms. My experience of anything to do with bureaucracy is that if things are defined in bland and vaguely positive terms that no one could realistically be opposed to, the bureaucrats can then ram through all manner of practical nasties under that banner. I also think its naive to think that State bodies and employees will ever consider that private individuals are their equals, and engage with them on that basis. They have more power and money than 99.999999% of us. Maybe the likes of James Dyson can engage with the State on something approaching an equal basis but everyone else can't. And if the State is handing out money they aren't going to do that without some process for checking its not just being siphoned off and none of the agreed actions taking place. Fundamentally any relationship between private individual and the State is going to be one sided, its the nature of the beast. As my quote you use in you supplementary submission says, when you sup with the devil, use a long spoon!

I know its a bit much to expect 14 private individuals to design and entire agricultural/environmental support system, but I think at least a steer as to exactly how you might see your ideal system working in practise (as opposed to how ELMS is currently designed) would help. Maybe a worked example using your own farms and what measures would help you, and indeed reward you for what you are currently doing, and how such measures would be policed/enforced would be good?

The reality of human nature is that if Defra decided implement a scheme with little or no policing, a large proportion or recipients would take the cash and just continue doing exactly what they do today. How exactly does one square that circle between not being a overly rules and inspection based adversarial system and also not allowing people to take the p*ss?
Thanks for a constructive criticism.

Personally I think we need a scheme where they tell us what outcomes they want, we each decide which ones we want to deliver and how we intend to deliver them and they then pay us on verified outcomes.

The trouble is that is very complicated to regulate and the money could be years arriving because the outcomes could take years to arrive.

We've tried the prescriptive actions based system for 20+ years now and it simply hasn't delivered for either side.

How would you design it?
 

Goweresque

Member
Location
North Wilts
I think that both approaches are doomed to failure. The current one because we can see it has failed, and the 'pay by results' one because its fundamentally undeliverable in practical terms. It basically requires every single farming business to have a tailored payment system for it and it alone. The costs would be phenomenal. The measurement issue (how you work out whether the outcomes have been achieved) alone makes it unviable. I have loads of brown hares on my farm, if my outcome is X brown hares per acre, and I'm one short do I not get paid? What if hare coursers have just decimated the population the month before the survey, or we've had a terribly hard winter and numbers are way down? I just don't think you can accurately measure nature on a farm by farm basis, not as the basis for handing out large sums of money. And certainly not on an annual basis.

My approach would be to remove all subsidies (agricultural and environmental) entirely, and make the polluter pay. The polluter in this case is the consumer. The consumer is fundamentally hypocritical, it wants fluffy bunnies and wild flower meadows, but doesn't want to pay the food prices that farming on that basis would entail. I would introduce a legal link between import standards and UK standards. If the UK consumer/voter wants high environmental and food production standards it can vote for them, and enforce them on UK farmers. But it will pay because imports would then have to meet that standard too, driving up prices. Profitable UK farming will result. And profitable farming will be far more able to afford higher environmental standards. Indeed it will just pass the costs of them onto the consumer, much as virtually all other industries in the UK do with increased regulations.
 

holwellcourtfarm

Member
Livestock Farmer
I think that both approaches are doomed to failure. The current one because we can see it has failed, and the 'pay by results' one because its fundamentally undeliverable in practical terms. It basically requires every single farming business to have a tailored payment system for it and it alone. The costs would be phenomenal. The measurement issue (how you work out whether the outcomes have been achieved) alone makes it unviable. I have loads of brown hares on my farm, if my outcome is X brown hares per acre, and I'm one short do I not get paid? What if hare coursers have just decimated the population the month before the survey, or we've had a terribly hard winter and numbers are way down? I just don't think you can accurately measure nature on a farm by farm basis, not as the basis for handing out large sums of money. And certainly not on an annual basis.

My approach would be to remove all subsidies (agricultural and environmental) entirely, and make the polluter pay. The polluter in this case is the consumer. The consumer is fundamentally hypocritical, it wants fluffy bunnies and wild flower meadows, but doesn't want to pay the food prices that farming on that basis would entail. I would introduce a legal link between import standards and UK standards. If the UK consumer/voter wants high environmental and food production standards it can vote for them, and enforce them on UK farmers. But it will pay because imports would then have to meet that standard too, driving up prices. Profitable UK farming will result. And profitable farming will be far more able to afford higher environmental standards. Indeed it will just pass the costs of them onto the consumer, much as virtually all other industries in the UK do with increased regulations.
Ironically, your suggestion is as undeliverable as mine. :rolleyes: :(

The WTO prevent you restricting imports like that (and so would the rabid free trade parliamentarians). The retail trade would refuse to pass the cost up the system too.

We agree that the old system is damaging though.

I do believe that payment for results will become progressively more deliverable though: there's huge work going into measuring nature and it will slowly pay off.

As for the complexity of individual agreements, how else can it be fair? The cost of delivering any particular improvement varies hugely between farms. Why should they receive the same reward?

We mustn't let the regulators get away with ignoring these issues, including that much of the damage that's been done to our environment was at their bidding.
 

Goweresque

Member
Location
North Wilts
The WTO prevent you restricting imports like that (and so would the rabid free trade parliamentarians). The retail trade would refuse to pass the cost up the system too.

Do they prevent standards on imports? They prevent formal tariffs, but I can't see they stop you determining what standards may be imported. You can't import goods painted with lead paint for example.

And anyway, the legislation would not have to mention imports at all. It could just make it an offence to retail any food item that was not produced to X standard, regardless of where it comes from.
 

holwellcourtfarm

Member
Livestock Farmer
Do they prevent standards on imports? They prevent formal tariffs, but I can't see they stop you determining what standards may be imported. You can't import goods painted with lead paint for example.

And anyway, the legislation would not have to mention imports at all. It could just make it an offence to retail any food item that was not produced to X standard, regardless of where it comes from.
Not sure.

How do you sufficiently define the standards though? How do you measure the level of animal welfare in an imported item? Or the biodiversity impact? It would be a lawyers field day.......
 

Goweresque

Member
Location
North Wilts
How do you sufficiently define the standards though? How do you measure the level of animal welfare in an imported item? Or the biodiversity impact? It would be a lawyers field day.......

Precisely. And what would the retailers want to do? They'd want to avoid having Friends of the Earth or Greenpeace taking them to court for breaking the rules in some way, so would have to operate well inside the law, not only to be legal but be seen to be legal as well. Which would mean sourcing their food predominantly from UK sources. The corporate love of certainty and avoidance of risk would work in our favour for once. The retailers won't care about new rules, as long as they apply equally to all players in the marketplace. If they all have to put their prices up to cover the additional costs everyone is still in the same place they were, competition-wise. Just the consumer has to pay more. Which is only fair because they (via the ballot box) are the ones requiring the higher standards.........
 

SFI - What % were you taking out of production?

  • 0 %

    Votes: 80 42.3%
  • Up to 25%

    Votes: 66 34.9%
  • 25-50%

    Votes: 30 15.9%
  • 50-75%

    Votes: 3 1.6%
  • 75-100%

    Votes: 3 1.6%
  • 100% I’ve had enough of farming!

    Votes: 7 3.7%

Red Tractor drops launch of green farming scheme amid anger from farmers

  • 1,292
  • 1
As reported in Independent


quote: “Red Tractor has confirmed it is dropping plans to launch its green farming assurance standard in April“

read the TFF thread here: https://thefarmingforum.co.uk/index.php?threads/gfc-was-to-go-ahead-now-not-going-ahead.405234/
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