Disclaimer: The text below is a first draft of a personal analysis and should not be interpreted as representing the view from my funders or research institute/partners.
More than a year ago I analysed the future welsh agricultural policy plans presented in the white paper after a long wait the Welsh Government has released a long first draft of the Sustainable Farming Scheme (SFS) in early July, the scheme that is to be the core of the future Agricultural policy. A long-draft not that farmer friendly given its length although couple icons, infographics and simplified pages were available.
General information:
Following the principle of Sustainable Land Management (SLM) it gave us a further glimpse at the future of the Welsh agricultural policy. If I mention glimpse is that the plans showcased remains relatively broad but already attracted some criticism. But many commentators did not highlight that the Welsh government team has stayed true to its word and has tried to design something that combines; environment, social or economic goals and food production among others. As I will try to showcase there are nevertheless a number of elements to iron out for this scheme to live up to its goals.
The overall objectives, principles and structure of the scheme have not evolved that much in one and a half year if I was to do a quick list of the objectives that were in the scheme high in the scheme we find:
- Produce food sustainability
- Mitigate/Adapt to Climate Change
- Maintain and improve the ecosystem
- Conserve and enhance the countryside and cultural resources
Basically, delivering environmental and social outcomes via the adoption of sustainable farming practices there were several key benefits that were expected to be delivered from the scheme
- Clean Environment
- Access to the Countryside
- Greenhouse gases reduction and removal
- Flooding mitigation
- High health and welfare of animals
- Resource efficient sector
- Stronger ecosystems
Among the principles of the scheme; the sustainable farming scheme we find: keep farmers on the land, food production is vital , a prosperous agricultural industry, maximise the outcomes of the SLM, open to all, simplified, stepped approach, and finally a clear link betweenscheme actions and the outcomes of the SLM. Payments will only be awarded to go over the regulatory baseline and notthing to comply with it will be added in the scheme.
Structure and functioning of the SLM
The general structure of the SLM is broadly similar to what was announced in the agricultural policy structure but with slight adoptions and things that have been taken out of the scheme or are not mentioned anymore.
Figure: General structure of the SLM organisation. By the author from the SFS draft
The SFS scheme in general tries to deliver on a wide range of objectives which makes it quite challenging to design and if it must support farmers in a difficult future environment as we can now foresee it. When looking at the scheme framework there are 5 different action stream:
- Resilient and productive
- Reduce, reuse and recycle inputs nutrients and waster
- Reduce on farm emission and increase the carbon dioxide sequestration
- Protect and improve the farm ecosystem
- Benefit people, animal and places…
In each of those categories there are some actions with different incremental layers that would allow you to go up in the scheme sub-options as you pick them up. But inside each action, for example; “Restore Semi-Natural Peatland” there are different sub-options which reflect different level of ambitions and commitment (and potential of the farm);
- Universal actions, anyone willing to enter the scheme has to do the 12 of them for a baseline payment (payable per hectare)
- Optional actions to earn extra payment
- Collaborative option where there has to be a landscape wide interconnexion with farmers and stakeholders
But for each of this 3 categories the payments and support can be of different kinds either management payments, capital payments either for tools/building, technical advice and tools being provided… For optional you fill your basket with options/sub-options up to a point, of which we know nothing for a payment which we know even less about (it will be per hectare for the baseline universal payment - Q&A). But the later is not purely linked to the Welsh government as it depends on funding commitments from the treasury in Westminster.
Q&A add-on: we note that for now the WG is unable to say whether payment rates will be adapted to item prices, it was nevertheless recognised that payment rates had to be attractive. It remained to be seen how the funding evolves and the case made to the treasury. The rates might be based on costs or income foregone or benefits brought to the community. Basically, a clear causality link to make the case.
To summarise one farmer will have 5 yearly contract that would them be reviewed and managed, originating from a sustainability review that he will have to do with its own responsability, this contract can be of different level. To have a baseline level of payment (per hectare) in return for 12 universal actions and additional payment for the optional/collaborative actions you choose that might be of different nature.
Here is a list of all the Sustainable Farming Scheme - Sustainable Land Management Options (Including analysis in terms of options split and sustainability pillars) (PDF)
Attached to this commentary I analysed each option offered in this scheme, commented on it and looked at sustainability pillars it complied with (PDF)
Comments on the scheme: I tried to analyse risks and possible opportunities in the SFS
(-) The biggest flaw I can see so far is the fact that there is little about funding and how to distribute it between the different layers and options of the scheme or what is the goal in terms of how much it should sustain farmers and the general funding goals. Are we compensating on loss of income or adding a management cut to the farmers for each action? For now, we should take stock of the fact that the objective of the SFS/SLM still include “keep farmers on the land” even though we don’t know how. Apart from trees I haven't seen any numbered objectives which in turns makes it more difficult to split funding.
(+) When presented with the list of options, there seem to be a balance between upland and lowland and between the different layers of actions which is extremely positive. (-) But there is no information on how much one could claim for this, whether it will be paid by the hectare, by farmer per action or for the layer of the scheme. It would have been important to have a political statement around those issues by that point. Simply to be able to forecast what to do and how to adapt.
More simply there is an alluded question about the timeframe for each of the actions, if the scheme is a rolling scheme how do we deal with the options, do we have evolutionnary goal posts, tools... Wat about the contract length/terms... My advice would be for now to take a flexible approach indicating if the actions are short/medium or long terms and clarify the length of their qualifying validity to enter/stay in the scheme and its increments. I don't think the sector needs to know everything but at least have a broad idea of the political orientation.
(-) The second big challenge I can see is the lack of numbers/data to tackle the complexity of the actions or discuss them. Let’s take for example the only number given in this whole document. It is about having 10% of farms acreage under trees or areas of ecological interest. This measurement is flawed as we don’t know what this 10% accounts for, the acreage of the whole tree foliage footprint, a gross area, only the stump, what about orchards or trees in hedges… It is so important and so controversial that it probably antagonized many farmers around only one relatively unrefined detail; but this might be very easy to comply with depending on the T&Cs. Besides depending on the size of the farm it can have a massive impact in terms of how the food production/output generation capacity of the holding is impacted. A very undifferentiated approach could be risky. We need trees as they bring many benefits to farms but in the right place, at the right time for a purpose, no need to replace a rich flower meadow by conifers. No need to fence out livestock all the time. Talking about afforestation it is immensely specific to the place it takes place in I saw many experiments and farmers experience showing it, integrated approaches work best (VoC, Powys, Bala or Pembroekshire).
Figure: General process of registration and contract preparation. From the SFS draft
(-) Which takes me to the third risk, the complexity and the number of actions and the need to design for each farms a dedicated plan. Within the draft document we see two organizations taking the lead Farming Connect as the advisor and Rural Payment Wales (RPW) as the administrator of the scheme. But even if it was clear from the onset that this scheme would be digital heavy – relying on it to ease the process – now we know that farmers will be handling/designing their farm’s scheme (or an advisor paid at their expense).
(-) These were the only two named organizations named within the draft, given the complexity and the scale/scope of the scheme Farming connect does not have the resources to handle the scheme as it is designed. Besides farming connect has so far had a limited play and size in working on habitats and there will be a lot of work related to them. Likewise the vision taken with RPW taking the lead in administering the scheme and a penalty based operating system in case of non-compliance is reusing one of the least liked element of the former CAP. With so many options/sub-options it is possible that many mistake will be made and that the scheme will seem quite repulsive to many farmers that lack time or may not be used to digital tools.
(+) It might not push people out of farming but might put them of from the scheme, though the good thing is that the former RPW tools are retained meaning that many farmers/advisors will already be used to it. Overall, we are lucky in Wales to have a strong community around farming with many bodies that could help/support/play the role of farming connect after an accreditation process therefore easing the pressure on them. In the end I think the scope needs to be a bit broader there.
Q&A add-on:
- FC will need to be recontracted (last contract was done 7 years ago), as it represents the advice brand of the WG it the one that has been retained in the scheme so far but it is likely that other organisations will be able to take part.
- Farmers were advised to gradually prepare for now to do the sustainability review and application process.
- The opportunity to synchronise RPW with other services that will be needed to play back to farmer and capture more easily the data was aknowledged. But it was said that it was important for the government or farming business but not research. (Cf point later)
(-) Then, we talk about a sustainable farming system and as a result a rather holistic scheme but all the actions seem quite compartmentalized. Many actions need to be joined up together to provide greater benefits and it felt as if it does not need much at all to go in this direction – e.g. hedges, health and safety, tree-planting… Therefore I am wondering if it has been a conscious choice. In the same vein I felt that sometimes the language used in the draft was a bit unadequate; “rejuvenate grass” or “pest-resistant”, using words that carry a value-judgment and give a very dualized vision of the farming system; production on one side, environment on the other quite in opposition to the route set. Additionally some omissions in actions make us wonder how far the systemic/holistic vision is going; for example in the action “reduce the use of antibiotics”; adding anti-thelmic would have been positive given the goals of the scheme (yes I know they are mentioned a bit later). Another example: in the section on rich-on farm biodiversity/Preserving native breeds; Looking only at breeds of livestock when considering a natural farming environment without linking crops and grass seems quite compartimentalized…
(-) Something that I felt would be a problem in this scheme is maybe the need for a lot of information about the land, about processes and a lot of localized element/knowledge to adapt as best as possible. But there will also be a need to develop new tools, select crops and breed cattle to make it better suited to the Welsh localized contexts, investigate habitats, adapt carbon tools to the Welsh context… Many elements in this draft would require some research according to me as there is either no consensus, some of the knowledge/capital (biological…) has been lost or it’s simply never been implemented.
Q&A add-on: On the carbon calculation tool there seems to be a debate at the moment and it is not clear if the WG will pick a standard tool or create a bespoke designed one.
(+-)Linked to that I mentioned the amount of information collected to do a sustainable audit of the farm (that farmer would have to do themselves and requiring a lot of information) it was mentioned that the industry could use the anonymized data for research purpose. In the farming market we currently have a huge asymmetry in terms of publicly and easily available information across farming. The stakeholders of the supply chain clearly lagging well-behind farmers. Therefore, it would be helpful to make access to the data for stakeholders in return for their own relevant information or preferential contracts for farmers. Secondly, independent researchers should have access as much as possible to the data to limit solicitations of farmers. For research purpose it could be useful to add a scheme action around research participation (engage and access…). Given the fact that the data from the annual audit will be collected by the farmer every year there are questions around how fine they will be and how interesting they will be from a research point of view. If farmers must agree with this part of the program, it is important that they see a clear return out of it; be it from benchmarking, market information, independent research produced out of it, or pieces of software available for them to use.
(+) As a researcher in farming sciences, I often deplore the fact that time series of farming data are quite disjointed, the Welsh Government could make sure that we have the possibility to continuously have access to consistent indicators through time before and after the scheme regardless of adaptation to maximize results. Finally, there is the question of how fine to anonymize the data, I would argue that the small agricultural area statistics could be an adequate publicly available starting point.
Q&A add-on: (+) A big plus is that there seems to be a lot of flexibility and goodwill around the scheme, in case of problem it would be possible to adapt the contract or get exemptions. A lot of exemptions seem not to have been designed yet and you can make your voice heard (e.g. need to adapt to tenant farmers, SSSI and National Park-located farms...) through the process of co-design. Finally, the collaborative element has been designed with the possibility to have flexible actions out of the scheme limitations albeit we don't know the eligibility as of yet.
Q&A add-on: (+) There is a will to target active farmers quite agressively with the scheme. The 12 universal actions are designed in that regard and would render some subsidy claimant unable to do so directly. Althought they might still do it undirectly given the tensions on the land market (Cf Lenormand et al. 2021). The 3ha limit is a bit more challenging all the more given how hard it is to access farmland in Wales and the will to develop horticulture. The WG wants these eligibility tools of the SFS as a whole to filter out the non-active farmer and large corporation buying farmland for afforestation purposes. It seems that it is a part of the scheme were they want some input through the co-design. While this scheme is supposed to be open to all there seem to be a lot of opacity around the lower threshold of farmer but also tenants and no recognition of sharefarming models for the scheme.
To conclude this commentary, I would like to note the missing element of the schemes compared to what we have now: Young farmer scheme – Organic farming. So far nothing has been said about those while they represented useful elements of the former schemes and provided benefits in line with the SFS targets (environment and socially economic). Maybe it will be included in further developments, or I missed an announcement. More importantly, the scheme draft does not mention the Welsh language and very little Welsh family farms two elements that represented an important par of the White paper, while one can see that they can fit in the SFS draft there is no specific mention of it, something I find concerning.
Q&A add-on: There are no plans to continue the young farmers scheme, a working group will be creating to try to adapt the SFS to all including new entrants. I think that it might not be enough given the scale of the challenge in generation renewal. The welsh language not mentioned in the video and no link available in Welsh for now while there were important elements clarified in this video.
What about the timeframe:
My conclusion on this draft would be that it is positive, but one would have liked to have a bit more commitment to the funding split orientation. The emphasis on some components given the actions of the scheme is high (e.g. Water) it will remain to be seen whether it impacts negatively the other parts of the scheme, because for it to be sustainable it will be important to have a balanced approach.
Théo Lenormand, July 2022
