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Respond to this once-in-a-generation opportunity to enshrine better environmental stewardship into land management policy in the UK.

The government have been running a public consultation on their proposal for the new Environmental Land Management System, which will replace payments to farmers and other land managers now that Britain has left the European Union.

The consultation is currently on pause due to the COVID-19 response – but this consultation is a once-in-a-generation opportunity to enshrine better environmental stewardship into land management policy in the UK. Read our response below, and learn how you can have your say when the consultation re-opens.

How to have your say

You can respond to the consultation directly through Defra’s online consultation tool. Please feel free to refer to our comments to guide your own response.

Consultation questions and The Tree Council responses

To be read alongside proposal found here: https://consult.defra.gov.uk/elm/elmpolicyconsultation/

You can also download our responses.

 (Consultation questions start at number 6)

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

The Tree Council response:

The design principles are sound. The Tree Council has specific comments on principles (d) and (e).

d) The new ELMs scheme gives the UK an opportunity to rethink the fundamentals of environmental stewardship and the responsibilities of land managers of all types to deliver environmental outcomes. The proposal rightly highlights the need to attract a wider range of land managers to the scheme. It would be helpful if the principles could specifically cite local authorities, charities and community interest companies (CICs) as land managers who might be able to achieve environmental outcomes through the scheme.

(e) Greater flexibility for land managers is welcome, provided this doesn’t risk some environmental priorities receiving less focus than others due to land managers opting for quicker wins.

In addition, it is important that farmers and landowners are rewarded for current good practice as well as for adopting new activities. This is especially important in the transition period between the existing scheme and ELMs, when land managers may fear being penalised or losing out financially later if they implement environmentally-friendly measures too early. This fear may encourage them to delay work until after ELM comes into force, wasting valuable time. ELM’s design principles should stress the importance of rewarding current good practice clearly, to ensure excellence continues and is supported.

7. Do you think the ELM scheme as currently proposed will deliver each of the objectives on p8?

The Tree Council response:

This new scheme is an opportunity to encourage land managers of every kind to undertake activities which will benefit the environment. Therefore, The Tree Council would strongly encourage amending the second strategic objective to read:

To help tackle some of the environmental challenges associated with all forms of land management, focusing on how to address these in the shorter term.

The Tree Council thinks the current proposal can deliver the strategic objectives and looks forward to seeing more of the detail as to how exactly this will be achieved. We are particularly eager to see how the scheme will help reach national targets on canopy cover. Whilst the role trees and hedgerows can play in meeting environmental goals has been made clear, the scheme as it currently stands does not demonstrate how planting, protecting and caring for trees and hedgerows will be prioritised. To our knowledge, current tests and trials have included some hedgerow work but not included a specific hedgerow test and trial, which could provide evidence for including hedgerow planting, ‘gapping up’ or ‘filling in’ and management as an output which could be included under Tier 1.

In order to achieve the stated objectives, the number of professionals working in the environmental sector will need to be scaled up. Environment-focused jobs should be marketed as a viable and exciting career to young people from an early age, right through to university level. We would like to see more action to ensure that this happens.

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

The Tree Council response:

The ELM scheme has the potential to improve environmental land management by encouraging participation from a much wider range of land managers and landowners in the UK, including local authorities, charities and smaller land managers. It will be essential to engage land managers who have not participated in previous schemes. A far-reaching communications campaign will help reach these new audiences, directing them to the best place to find further information. 

We also refer to the point made to question seven, about recruiting and up-skilling the next generation of foresters, ecologists, agro-foresters, farmers and other environmental professionals.

Simple systems and application processes (plus help with applications by regional ELM officers, see answer to Q10) will be vital to encourage participation. Also, ensuring payments are made on time. We welcome the focus put on this in the proposal. This will be especially important to smaller land managers and those with lower profit margins.

Reporting back to land managers on the positive impacts their actions can and are having on the nation’s carbon footprint, biodiversity and wellbeing will encourage participation and maintain momentum in the longer-term. This information should be digestible and widely accessible.

Umbrella organisations such as The Tree Council can help get the message out across specific sectors to the right people.

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?

The Tree Council response:

This is an opportunity to help all kinds of land managers achieve local and national environmental outcomes.

We look forward to seeing more specific details on what will be included under each tier. The Tree Council would like to see the following included under Tier 1:

  • Activities to plant, bolster, improve and maintain the nation’s network of rural and urban hedgerows (this is supported by the National Farmers Union)
  • Tree and hedgerow planting in urban and peri-urban contexts
  • Activities to protect and conserve ancient and veteran trees, which offer rich ecological, heritage and carbon-storage value
  • Projects which increase access to and improve local green spaces for community benefit
  • Activities which promote and enhance the rich cultural value of trees, woodland and green spaces
  • Activities which protect and improve the trees, woodlands, orchards and hedgerows land managers already have/manage

Under Tier 2, we would like to include upland tree planting for flood mitigation where appropriate.

It is important that land managers already engaged in activities to protect, improve and enrich the environmental value of their land are rewarded for their current work. This should be made clear immediately, so that farmers and land managers are incentivised to continue positive action and not hold off until clarity on what is covered is provided.

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?

The Tree Council response:

Land managers are not currently set up to work together in this way. They should be supported to make this happen. The Tree Council suggests that land managers will need access to a national, high-level, broad-spectrum, GIS mapping system. This should be managed centrally and specifically make landscape character assessments more easily accessible.

Land managers would benefit from local/regional officers who can help connect them with their community, disseminate clear information and provide meeting admin and face-to-face support. Similar outreach works well in managing the nation’s forests. Regional officers working closely with land managers has led to an increased number of applications and fewer set-backs.

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?

The Tree Council response:

While it is important to give local stakeholders a role in deciding local environmental priorities, the scale of the national and international environmental crisis means that we must retain a sharp focus on tackling the key issues of the climate crisis, climate resilience and tackling biodiversity loss. This will require setting and monitoring ambitious national targets.

At a local level, The Tree Council suggests a model based on expert panels, including expert groups such as Hedgelink, local conservation groups and volunteers such as Tree Warden Networks. Their knowledge of the area, its heritage and ecology can help avoid mistakes such as planting the wrong thing in the wrong place. Such groups already exist in many areas and the role of these existing organisations could be extended to include helping determine local ELM priorities. Examples include the Devon Ash Dieback Resilience Forum, which has shown great success in bringing together a wide range of stakeholders to manage the impact of ash dieback disease: www.devonashdieback.org.uk

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?

The Tree Council response:

Outcomes relating to trees should be funded properly, including asset after-care and management.

  • For example, hedgerow funding should include management and rejuvenation of hedgerows over a ten/fifteen-year period.
  • Tree planting funding should include long-term aftercare and management, calculated on the benefits of trees and woodlands over a period of at least one hundred years.

This can include the calculation of quick-wins (such as planting fast-growing species to bolster carbon sequestration or improve flood resilience) as long as this is not done at the expense of the rich, long-term benefits of increasing tree canopy and hedgerow coverage.

A balance of the short- and long-term is needed, coupled with a range of diverse approaches, which is the best long-term defence against pests and diseases.

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

The Tree Council response:

Blended finance has the potential to help us achieve ambitious, landscape-scale goals through larger funding pots and access to technology and innovation. We welcome partnerships with committed private sector partners, alongside charities, communities and government, working towards the same goal of increasing environmental outcomes. These partners can help us achieve things that might not otherwise be attainable with public finance.

However, the principle of ‘public money for public good’ must remain at the centre of the scheme. Blended finance needs to be controlled to ensure programmes achieve the greatest possible public good. Care should be taken to ensure any private sector partners show real commitment throughout the life of the project. ‘Green-washing’ should be avoided at all costs.

Contracts with private entities should be rigorously assessed, based on real-world benchmarks and examples, to ensure the government and taxpayer get the best possible result from the public-private partnership. There is a danger of ‘under-selling’ income opportunities if blended finance initiatives are led by those with no commercial experience.

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 Tree Council response:

The Tree Council agrees that the right advice is essential in making this scheme a success and must be ‘built-in’ not ‘bolt-on’. This should include:

  • face-to-face guidance on critical issues such as aftercare
  • a friendly person to talk to if things start to go wrong, to help get a project back on track
  • advice to those new to ELM re: how to apply and how to report (for example, smallholdings, charities, peri-urban and urban applicants)
  • regional officers to connect disparate stakeholders, organise initial meetings (see Q10)
  • on-line case studies and advice for land managers to learn from the experience of others

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?

The Tree Council response:

The Tree Council believes the best investment in self-assessment would be a centrally-managed mapping system, linked to geolocation and available to land managers in real time. For example, such mapping could quickly and easily allow land managers, or those assessing land managers, to measure indicators such as increase in canopy cover.

An example of how centrally-managed GIS mapping might be applied is the measurement of hedgerow health. GIS mapping can measure the amount of blossom on satellite imagery linked to GIS mapping in early summer. Lots of blossom suggests a healthy hedgerow benefitting from the recommended three-year hedgerow management plan (with positive benefits for the hedgerow and for wildlife), rather than a less positive annual one.

GIS mapping can also help tailor indicators for each activity to the local context by giving assessors the chance to pinpoint local variations with accuracy. This is particularly important in the context of hedgerows, where variations give landscapes their local character.  Once these local variations have been recognised different management practices can be brought together and cross-compared. It would also bring all the different streams of ELMs activities together in one place.

 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?

The Tree Council response:

The National Pilot should include woodland establishment and hedgerow establishment and management (including hedgerow carbon sequestration above and below ground), plus projects which seek to plant and care for urban and peri-urban trees.

The National Pilot also provides an opportunity to demonstrate the broad range of benefits achieved through tree planting, management and protection, for example air quality and levels of soil organic carbon, and biodiversity indicators such as the population numbers of species including butterflies, pollinators, song birds and hedgehogs.

17. Do you have any other comments on the proposals set out in this document?

The Tree Council response:

The new ELM scheme is a fantastic opportunity to incentivise landowners and managers of every kind, large and small, professional and semi-professional, rural, peri-urban and urban, to take care of the land which is the heritage of all British people, and to achieve greater environmental outcomes through good land management.

We welcome the intention to target and include a wider range of land managers than previous schemes. We strongly support the suggestion that urban and peri-urban land should be included, as these spaces could greatly benefit from and contribute to increased tree, hedgerow and woodland cover. We are also keen to see how ELMs could protect and enhance existing landscapes as well as create new ones.

The proposal is a good start. However, more detail is needed to give complete confidence that the scheme will address the climate and biodiversity crises.  ELMs should set specific targets for environmental outcomes, such as what contribution to the 30,000 hectares of trees per year by 2050 target could be provided through this scheme. The ELM scheme is an ideal mechanism by which to help achieve the National Tree strategy, and we would like to see how the two schemes/strategies are married together.