I’m posting this here as well as on my own blog, for maximum reach. It’s the People Need Nature response to Michael Gove’s consultation on the future of agriculture in the England.

If you haven’t submitted a response yet, please find an hour over the long weekend to write something. Feel free to make use of what you find here. I cannot overstate how important it is that as many of you as possible contribute. There have been tens of thousands of responses sent in – though I suspect many of those will be auto-generated via 38 degrees or change.org, and they will be lumped together. Individual responses have more clout.

You still have time, either to write something free-hand or use the online form. There is plenty of time – the consultation closes at 1145pm on tuesday the 8th May.

Health and Harmony: the future for food, farming and the environment in a Green Brexit – Response from People Need Nature

Introduction

People Need Nature is a Charitable Incorporated Organisation established in 2015. We are dedicated to promoting the sensory, emotional and spiritual value of nature, the importance of nature on public land and in public decision-making.

We advocate a different approach to how nature is valued and protected, particularly in relation to publicly owned land, public policy making and public expenditure. We aim to influence and drive new policy.

As a Charitable Incorporated Organisation covering England and Wales, we will not be commenting on devolved matters.

This submission has been prepared by Miles King FLS, Chief Executive of People Need Nature.

Overview

People Need Nature welcomes the Defra consultation “Health and Harmony: the future for food, farming and the environment in a Green Brexit.” We produced a report entitled “A Pebble in the Pond: Opportunities for farming, food and nature after Brexit” in January 2017 and it is heartening to see Defra looking at the future of Agriculture, and its relationship with food and nature, from a similar standpoint. We attach a pdf copy of our report with this reply.

Public support for agriculture has to change. Paying subsidies to farmers and landowners with little or no public return can no longer be justified. Food Security may have been a good enough reason to pay farmers to grow more food (at any cost) in 1940, when our food supplies from the Empire and Dominions were threatened during times of war. Those times have long gone, but the environmental consequences of that drive to increase food production are still with us. Now, Society has to help farmers not only slow the continuing loss of wildlife and natural resources, but to reverse that trend.

Some of the responsibility lies with the Common Agricultural Policy, and some lies with domestic farm policy from 1940 to 1973. A great deal of damage was done to farmland wildlife, and to the social fabric of rural England and Wales, during the period before the UK joined the Common Market. It is useful to remember this history, as we consider how to design the first new domestic agriculture policy in 45 years.

It is not our intention to answer every question in this consultation – as many fall outside our remit and charitable purpose. However, there are some areas of policy which we believe have not been covered adequately, and we will attempt to fit comments on these areas as best we can within your framework.

QUESTIONS


1. Agriculture: the case for change

No questions

Moving away from the Common Agricultural Policy in England

2. Reform within the CAP

Please rank the following ideas for simplification of the current CAP, indicating the three options which are most appealing to you:

1. a) Develop further simplified packages
2. b) 
Simplify the application form
3. c) 
Expand the online offer
4. d) 
Reduce evidence requirements in the rest of the scheme
5. e) Other (please specify)

1. e) There is an assumption that the most important thing to do is simplify the current CAP scheme. For nature to benefit, this may not be the best approach. If simplification means that fewer farmers enter Countryside Stewardship – especially those who are managing existing wildlife-rich farmland, then simplification will cause damage to that wildlife, which runs counter to Defra’s stated aims. Conversely, if simplification means Stewardship schemes which are “no brainer” schemes, which require little or no change in the way land is farmed, then they will also provide little or no public benefits for the money paid.

There are already problems associated with farmers in agri-environment schemes, which are finishing in 2018, being told they cannot apply for a new agreement until 2019. The failure to maintain appropriate management for nature even for one year can have devastating results. There is also a risk that farmers will be disenchanted and not renew their schemes – or worse will feel they have no alternative but to convert recovering wildlife habitat back into intensive food production – with the loss of an investment from the public purse over a period of up to 30 years, from the time when the first agri-environment schemes were set up. And none of this has been helped by Natural England, RPA and ultimately Defra’s failure to manage the administration of Countryside Stewardship over the past year, which is now at crisis point.

If you have answered “other (please specify)”; please explain your preferred alternative.

Please give a short explanation as to your ranking preferences.

How can we improve the delivery of the current Countryside Stewardship scheme and increase uptake by farmers and land managers to help achieve valuable environmental outcomes?

The current Countryside Stewardship scheme has proved unpopular with farmers and land managers and aside from providing continuity for those who need support to manage their existing farmland wildlife habitats (as described above) there is no strong argument for attempting a large roll-out when the entire framework for agricultural support is going to change radically in the near future.

The current scheme should therefore focus on ensuring the richest farmland wildlife habitats and heritage features are protected; and also provide support for farmers and landowners who are recreating, or who have successfully recreated or restored degraded farmland wildlife. This should be seen as a “holding operation” to protect this resource during the transition to the new scheme.

Do you have any further comments?

3. An ‘agricultural transition’

What is the best way of applying reductions to Direct Payments? Please select your preferred option from the following:

1. a)  Apply progressive reductions, with higher percentage reductions applied to amounts in higher payment bands *
2. b)  Apply a cap to the largest payments
3. c)  Other (please specify)

We would suggest adopting both a cap and a taper. The European Commission is proposing a cap on payments in the new Common Agricultural Policy of £52000 a year. We would suggest that a taper is introduced on payments above £50,000 a year, with a cap at £75000. This would liberate a sufficient amount of resources to properly fund the pilot projects needed to establish how a “public money for public goods” approach would work. To prevent those avoiding the cap by breaking their farm businesses into several units, a back-dated base-line should be applied – using January 1^st 2016 would ensure that no advantage could be gained from any anticipation of the Brexit referendum result.

If you have answered “other (please specify)”; please explain your preferred alternative.

* please provide views on the payment bands and percentage reductions we should apply.

What conditions should be attached to Direct Payments during the ‘agricultural transition’? Please select your preferred options from the following:

1. a)  Retain and simplify the current requirements by removing all of the greening rules
2. b)  Retain and simplify cross compliance rules and their enforcement 
c)  Make payments to current recipients, who are allowed to leave the land, 
using the payment to help them do so
3. d)  Other (please specify)

1. d) While greening is generally regarded as having been a failed experiment in delivering public goods via the CAP mechanism, it would be very unwise to remove all greening rules without any consideration of that impact. For example, currently the Permanent Pasture rules sit within greening. These have admittedly been very weak at protecting nature in grasslands, partly because of the way they have been applied in the UK. Removing these rules altogether, though, would leave a large area of semi-improved grassland (with a large soil Carbon resource and certainly some value for wildlife) at risk of cultivation.

It is not clear what “retain and simplify” in the context of Cross Compliance, would mean in practice. Cross Compliance is a complex set of rules and could certainly be greatly improved, both in terms of their efficacy at protecting the environment, and the bureaucratic burden they place on farmers. The risk is that simplification actually means the environment will be left more vulnerable than it already is – and that Cross Compliance will be left unenforced.

A better approach would be to focus resources on those aspects of Cross Compliance, which deliver the greatest environmental benefit. Any enthusiasm for chasing farmers who have a bit of scrub in their field corners, or who have allowed their hedges to grow out, to the benefit of farmland wildlife, should certainly be abandoned. Whereas farmers who allow slurry to pollute local watercourses need more enforcement, given the current eutrophied state of so many of the UK’s rivers.

If you have answered “other (please specify)”; please explain your preferred alternative.

Give a short explanation as to your preferences.

What are the factors that should drive the profile for reducing Direct Payments during the ‘agricultural transition’?

How long should the ‘agricultural transition’ period be? Do you have any further comments?

It would be wise to allow the transition period to be long enough to avoid a “cliff edge” effect, but the shift to a “public goods” approach needs to happen urgently. Realistically the transition will need to take place over several years.

4. A successful future for farming

Farming excellence and profitability

How can we improve the take-up of knowledge and advice by farmers and land managers? Please rank your top three options by order of preference:

1. a)  Encouraging benchmarking and farmer-to-farmer learning
2. b)  Working with industry to improve standards and coordination
3. c)  Better access to skills providers and resources
4. d)  Developing formal incentives to encourage training and career 
development
5. e)  Making Continuing Professional Development (CPD) a condition of any 
future grants or loans
6. f)  Other (please specify)

1. f) Other. If the main system of support for farmers is to transform into a “Public Goods” approach, then the take-up of knowledge and advice is of paramount importance. The evidence for the success of agri-environment schemes – our best example of prior Public Goods approaches, is mixed at best. One of the key drivers of success is the provision of expert support and guidance from professional staff – mainly those within the Government Agencies going all the way back to the Countryside Commission who created the original Countryside Stewardship; and ADAS who founded Environmentally Sensitive Areas. Former ADAS, FRCA and Natural England senior policy expert Steve Peel wrote about what makes a successful agri-environment scheme in this article (https://anewnatureblog.wordpress.com/2017/09/04/guest-blog-agri-environment-a-need-for-detailed-scrutiny-by-steve-peel/) and his years of experience and studying the evidence deserve close scrutiny. Peel’s view is that successful outcomes are only achieved by substantial investment in project officer time guiding, supporting and advising farmers and landowners.

If you have answered “other (please specify)”; please explain your preferred alternative.

Give a short explanation as to your preferences.

What are the main barriers to new capital investment that can boost profitability and improve animal and plant health on-farm? Please rank your top three options by order of the biggest issues:

1. a)  Insufficient access to support and advice
2. b)  Uncertainty about the future and where to target new investment
3. c)  Difficulties with securing finance from private lenders
4. d)  Investments in buildings, innovation or new equipment are prohibitively 
expensive
5. e)  Underlying profitability of the business
6. f)  ‘Social’ issues (such as lack of succession or security of tenure)
7. g)  Other (please specify)

If you have answered “other (please specify)”; please explain your preferred alternative.

Give a short explanation as to your preferences.

What are the most effective ways to support new entrants and encourage more young people into a career in farming and land management?

It is certainly the case that there are severe limits on the opportunity for new entrants to develop a career in farming. There is a wide range of reasons for this, including the concentration of land ownership in the hands of a small number of land-owners, especially in England. This is in large part due to the fact that farmland is used as a tax shelter. Indeed one expert recently described farmland as the “The greatest onshore tax haven this country has ever seen.” Until the use of farmland as a tax shelter is tackled, farm land ownership will continue to concentrate in ever fewer hands and access to new entrants will be all but impossible. It is also the case that the County Farm network, which once provided opportunities for new entrants into farming, has been substantially sold off by Local Authorities desperate for funds, with little or no objection from Defra.

Does existing tenancy law present barriers to new entrants, productivity and investment?

Do you have any further comments?

Agriculture technology and research

What are the priority research topics that industry and government should focus on to drive improvements in productivity and resource efficiency?

Please rank your top three options by order of importance:

1. a)  Plant and animal breeding and genetics
2. b)  Crop and livestock health and animal welfare
3. c)  Data driven smart and precision agriculture
4. d)  Managing resources sustainably, including agro-chemicals
5. e)  Improving environmental performance, including soil health
6. f)  Safety and trust in the supply chain
7. g)  Other (please specify)

3. e) 1 d) 2 f) 3.

If you have answered “other (please specify)”; please explain your preferred alternative.

Give a short explanation as to your preferences.

People Need Nature does not necessarily agree that improvements in productivity is the priority – if productivity means increasing yields of crops per hectare, or litres of milk per cow per annum. This is a very narrow definition of productivity, which creates far more problems than benefits. Productivity for farmland needs to be redefined so it includes the production of public goods like clean water, clean air, healthy wildlife; and well-paid sustainable jobs.

Currently most agricultural Research & Development is spent on improving the narrow definition of productivity. If Defra is really going to shift support towards public goods then it needs to redirect research budgets accordingly.

How can industry and government put farmers in the driving seat to ensure that agricultural R&D delivers what they need? Please rank your top three options by order of importance:

1. a)  Encouraging a stronger focus on near-market applied agricultural R&D
2. b)  Bringing groups of farms together in research syndicates to deliver practical 
solutions
3. c)  Accelerating the ‘proof of concept’ testing of novel approaches to 
agricultural constraints
4. d)  Giving the farming industry a greater say in setting the strategic direction 
for research funding
5. e)  Other (please specify)

1. e) commenting on d) the farming industry already has a great say in how research funding is allocated. Adopting the public goods approach requires Defra to widen the spectrum of contributors to setting that strategic direction – away from a narrow group within agro-industry, bringing in expertise from the environmental, food and health public policy sectors.

If you have answered “other (please specify)”; please explain your preferred alternative.

Give a short explanation as to your preferences.

What are the main barriers to adopting new technology and ideas on-farm, and how can we overcome them?

Do you have any further comments?

Labour: a skilled workforce

What are the priority skills gaps across UK agriculture? Please rank your top three options by order of importance:

1. a)  Business / financial
2. b)  Risk management
3. c)  Leadership
4. d)  Engineering
5. e)  Manufacturing
6. f)  Research
7. g)  Other (please specify)

If you have answered “other (please specify)”; please explain your preferred alternative.

Give a short explanation as to your preferences.

What can industry do to help make agriculture and land management a great career choice?

How can government support industry to build the resilience of the agricultural sector to meet labour demand?

Do you have any further comments?

Implementing our new agricultural policy in England

5. Public money for public goods

Which of the environmental outcomes listed below do you consider to be the most important public goods that government should support? Please rank your top three options by order of importance:

1. a)  Improved soil health
2. b)  Improved water quality
3. c)  Better air quality
4. d)  Increased biodiversity
5. e)  Climate change mitigation
6. f)  Enhanced beauty, heritage and engagement with the natural environment

We do not agree with the idea that public goods should be ranked in order of preference, as this is simplistic and ultimately not helpful in developing policy. Such a ranking might suggest that – for instance, increasing biodiversity, would be more important than better air quality. The evidence shows that better air quality increases biodiversity (eg lichens benefit from improved air quality). And increased biodiversity improves soil health and water quality.

These different attributes are related to each other in a complex web of relationships and a linear approach to identifying priorities will not work.

There are some obvious public goods which are also missing from the list – such as alleviation of flooding; and the benefits that nature on farmland provides people’s mental health and wellbeing.

Please give a short explanation as to your ranking preferences.

Of the other options listed below, which do you consider to be the most important public goods that government should support? Please rank your top three options by order of importance:

1. a)  World-class animal welfare
2. b)  High animal health standards
3. c)  Protection of crops, tree, plant and bee health
4. d)  Improved productivity and competitiveness
5. e)  Preserving rural resilience and traditional farming and landscapes in the 
uplands
6. f)  Public access to the countryside

We would repeat our previous answer, that these public goods should not be considered as in competition with each other, but rather complementing each other, in a web of relationships.

It is highly debatable whether improved productivity (as in increasing crop or livestock production levels or density) is a public good – especially as it historically has created such profound losses of the other public goods listed. While it is unavoidable that some public goods provision will be in opposition to others, all efforts should be made to avoid trade-offs – rather solutions should be sought which minimize trade-offs and maximize opportunities where multiple public goods can be provided together.

It is disappointing that public health is not regarded as a public good in this context. The provision of sustainably produced healthy food for public consumption should be regarded as a public good. Further, farmland provides other health-related public goods – such as the mental health and wellbeing benefits provided by nature on farmland. This is related to, but different from, public access to the countryside.

The notion that food production or food security (thinking specifically of food security in England and Wales, rather than at international/global scales) are public goods should be resisted, as the Secretary of State has rightly done. Fitting food production (where that food is sold to the market), which is a private good, into a public goods framework, would undermine the principles of public goods theory.

Please give a short explanation as to your ranking preferences.
Are there any other public goods which you think the government should support?

6. Enhancing our environment

From the list below, please select which outcomes would be best achieved by incentivising action across a number of farms or other land parcels in a future environmental land management system:

1. a)  Recreation
2. b)  Water quality
3. c)  Flood mitigation
4. d)  Habitat restoration
5. e)  Species recovery
6. f)  Soil quality
7. g)  Cultural heritage
8. h)  Carbon sequestration and greenhouse gas reduction
9. i)  Air quality
10. j)  Woodlands and forestry
11. k)  Other (please specify)

We would question why this section only focuses on “enhancing the environment.” Environmental protection (maintaining existing highly valuable features of the farmland environment) must be considered as the primary role of public goods provision, with enhancement happening after the resource has gained protection.

For nature, roughly 2/3 of the existing resource of farmland wildlife (habitats) in England is protected in Sites of Special Scientific Interest (SSSI). This is totally inadequate and there is now an urgent need to protect the remaining resource. Natural England needs the resources and the direction to commence a programme to notify as SSSI all remaining examples of habitats, which qualify for protection. This will take several years and require appropriate resourcing but it is the highest priority action which needs to be taken to save what is left of these wildlife-rich treasures of the countryside. People Need Nature welcomes proposals to introduce Conservation Covenants to protect resources, which would not qualify for SSSI status.

We are also interested in schemes which encourage farmers to adopt sustainable farming practices, using for example auctions as Wessex Water are using in their Entrade project.

Some public goods naturally lend themselves to being provided more effectively when a group of landowners work together. Flood prevention and improving water quality self-evidently need actions taken at a catchment scale, though the catchment for human water abstraction will be different from that where actions to reduce downstream flooding need to be focused. Cultural heritage can only be protected where it already exists. While some historic landscape features e.g. dry-stone walls, will extend beyond farm boundaries, in many cases the public goods need to be protected in specific (and in many cases small) areas of farmland. Conversely, improving soil quality can be applied to all soils everywhere, but it would make most sense to focus on areas and land-uses where soil quality is being drastically reduced, such as areas where Maize growing is concentrated.

If you have answered “other (please specify)”; please explain your preferred alternative.

Give a short explanation as to your preferences.

What role should outcome based payments have in a new environmental land management system?

We believe that wherever possible an outcome-based approach to supporting the provision of public goods should be applied. The Natural England Payment by Results pilots should be extended in 2019 and 2020 to incorporate a much wider range of public goods (this extension to be paid for by the capping/tapering of large CAP payments) such that lessons learnt from these pilots can be applied at the outset for the new support system. Farmers, with the right kind of positive support and advice from project officers, are the best people to innovate and develop new approaches and techniques for the delivery of public goods. A highly prescriptive approach is most likely to put farmers off joining schemes, as has been the case with Countryside Stewardship.

An outcome-based approach does not necessarily mean setting targets for the specific increase in for example population size for a threatened species, or area of habitat. At the Knepp Estate in Sussex, the outcome was for natural processes to become the main driver of change. By allowing vegetation to develop relatively naturally with only minor adjustments to grazing pressure, Knepp has created the conditions for a rich and varied range of different wildlife to develop in surprising and unexpected ways. The Knepp approach is exactly the kind of payment by results approach, which should be encouraged elsewhere.

How can an approach to a new environmental land management system be developed that balances national and local priorities for environmental outcomes?

Priorities should be set locally wherever possible, using a wide range of expertise from within statutory agencies, local authorities, NGOs, and the farming/landowning sector.

How can farmers and land managers work together or with third parties to deliver environmental outcomes?

Farmers, landowners and land managers will only be able to successfully deliver the wide range of public goods, which Society expects and needs from farmland, by working together and working with organisations from the statutory sector, Local Government and Civil Society. This would best be achieved through local forums which have some form of statutory basis, which can support farmers and landowners to identify what public goods they can provide, and how best to achieve that provision.

7. Fulfilling our responsibility to animals

Do you think there is a strong case for government funding pilots and other schemes which incentivise and deliver improved welfare?

Should government set further standards to ensure greater consistency and understanding of welfare information at the point of purchase? Please indicate a single preference of the below options:

1. a)  Yes
2. b)  Yes, as long as it does not present an unreasonable burden to farmers
3. c)  Perhaps in some areas
4. d)  No, it should be up to retailers and consumers
5. e)  Other (please specify)

If you have answered “other (please specify)”; please explain your preferred alternative.

Give a short explanation as to your preferences.

*if you answered ‘perhaps in some areas’, please elaborate.

What type of action do you feel is most likely to have the biggest impact on improving animal health on farms? Please rank your top three choices from the below list, in order of importance:

1. a) Use of regulation to ensure action is taken
2. b)  Use of financial incentives to support action
3. c)  Supporting vets to provide targeted animal health advice on farm
4. d)  Making it easier for retailers and other parts of the supply chain to recognise 
and reward higher standards of animal health
5. e)  An industry body with responsibility for promoting animal health
6. f)  Research and knowledge exchange
7. g)  Transparent and easily accessible data
8. h)  An understanding of animal health standards on comparable farms
9. i)  Other (please specify)
10. j)  N/A – Cannot rank as they are all equally important.

If you have answered “other (please specify)”; please explain your preferred alternative.

Give a short explanation as to your preferences.

How can the government best support industry to develop an ambitious plan to tackle endemic diseases and drive up animal health standards?

Do you have any further comments?

8. Supporting rural communities and remote farming

How should farming, land management and rural communities continue to be supported to deliver environmental, social and cultural benefits in the uplands?

There are a number of challenges facing rural communities and businesses. Please rank your top three options by order of importance:

1. a)  Broadband coverage
2. b)  Mobile phone coverage
3. c)  Access to finance
4. d)  Affordable housing
5. e)  Availability of suitable business accommodation
6. f)  Access to skilled labour
7. g)  Transport connectivity
8. h)  Other, please specify

If you have answered “other (please specify)”; please explain your preferred alternative.

Give a short explanation as to your preferences.

With reference to the way you have ranked your answer to the previous question, what should government do to address the challenges faced by rural communities and businesses post-EU Exit?

Do you have any further comments?

Referring back to previous comments about balancing competing public goods, the Uplands provides a case study where support for rural communities (human ecology is a phrase the Environment Secretary has used) could potentially be in direct opposition to protecting nature. Upland sheep farming has had a profound and negative impact on the wildlife of upland England and Wales, particularly in the last 70 years. Sheep numbers are, in places, still at levels which cause damage to upland landscapes and habitats, or prevent habitats from recovering from previous damage. Some would try and draw a direct relationship between intensive upland sheep farming and sustaining upland and other rural communities. Yet it was only in recent decades that upland farms switched from mixed enterprises with cattle, sheep and small scale arable production, to almost exclusively sheep-dominated farming. It was those mixed farming enterprises which supported the wide range of public goods (including but not restricted to wildlife) provided by the Uplands. If public support is extended to supporting rural communities, this support should be conditional on adopting sustainable farming systems, including mixed systems.

9. Changing regulatory culture

How can we improve inspections for environmental, animal health and welfare standards? Please indicate any of your preferred options below.

1. a)  Greater use of risk-based targeting
2. b)  Greater use of earned recognition, for instance for membership of 
assurance schemes
3. c)  Increased remote sensing
4. d)  Increased options for self-reporting
5. e)  Better data sharing amongst government agencies
6. f)  Other (please specify)

This is one of the areas of the consultation, which gives People Need Nature most cause for concern. Effective protection of the farmland environment, and the wider environment where it is affected by activities on farmland, requires a robust and enforced regulatory baseline. This needs to include protection of nature (species and habitats) and natural resources (air, soil, water quality.) This can only be done effectively by state agencies. Outsourcing to private assurance companies such as Red Tractor will not be sufficient, and will lead to a decline of public trust in the system. Applying the “polluter pays” principle, as proposed in the consultation, means that polluters need to be caught and punished as a deterrent to others. Equally, punishing the polluters also helps those who not comply with the letter of the law, but go above and beyond it, to feel that they are vindicated in their efforts.

Effective regulation is needed to underpin the public payments for public goods approach. Failing to create and maintain an effective baseline, risks public money being spent on public goods, which can and should be being provided by law. If resources are wasted on public goods below the base-line, less will be available for the wide range of public goods which sit “above the base-line.” Given that it is likely there will be fewer financial resources available in any future farm policy budget, setting the right base-line is critically important.

If you have answered “other (please specify)”; please explain your preferred alternative.

Give a short explanation as to your preferences.
Which parts of the regulatory baseline could be improved, and how?

How can we deliver a more targeted and proportionate enforcement system?

Do you have any further comments?

10. Risk management and resilience

What factors most affect farm businesses’ decisions on whether to buy agricultural insurance? Please rank your top three options by order of importance:

1. a)  Desire to protect themselves from general risks (e.g. – revenue protection)
2. b)  Desire to protect themselves from specific risks (e.g. – flooding, pests or 
disease)
3. c)  Provision of government compensation for some risks
4. d)  Cost of insurance
5. e)  Complexity and administrative burden of insurance
6. f)  Availability of relevant insurance products
7. g)  Other (please specify)

If you have answered “other (please specify)”; please explain your preferred alternative.

Give a short explanation as to your preferences.

What additional skills, data and tools would help better manage volatility in agricultural production and revenues for (a) farm businesses and (b) insurance providers?

How can current arrangements for managing market crises and providing crisis support be improved?

Do you have any further comments?

11. Protecting crop, tree, plant and bee health

Where there are insufficient commercial drivers, how far do you agree or disagree that government should play a role in supporting

1. a)  Industry, woodland owners and others to respond collaboratively and swiftly to outbreaks of priority pests and diseases in trees?
2. b)  Landscape recovery following pest and disease outbreaks, and the development of more resilient trees?
3. c)  The development of a bio-secure supply chain across the forestry, horticulture and beekeeping sectors?

Please give a short explanation as to your preferences

Where there are insufficient commercial drivers, what role should government play in:

1. a)  Supporting industry, woodland owners and others to respond collaboratively and swiftly to outbreaks of priority pests and diseases in trees?
2. b)  Promoting landscape recovery following pest and disease outbreaks, and the development of more resilient trees?

What support, if any, can the government offer to promote the development of a bio- secure supply chain across the forestry, horticulture and beekeeping sectors?

Do you have any further comments?

While we have no comment to make in response to the questions, People Need Nature does strongly support the comments made in the consultation document about pesticides. We agree that strong regulation of pesticides is essential and that their use should be reduced as far as possible, with much greater emphasis on use of crop rotation, biological control and encouraging natural predators. Defra’s support for the EU’s decision to ban the three main Neonicotinoid pesticides is welcome. Defra also needs to reduce the extent to which Glyphosate is used – especially its pre-harvest use. There is no justification for the widespread use of Glyphosate in crops when there are so many questions still to be resolved about its impact on soil health.

We have no further comments to make in response to the consultation questions.