Agriculture Bill

Written evidence by Friends of the Earth (AB63)


Friends of the Earth (England, Wales and Northern Ireland) welcomes the opportunity to submit this evidence. We have a vision in which farmers are rewarded fairly in the market for the food they produce with rewards from government to deliver the additional outcomes that society needs, and are innovating and collaborating to this end. It will make economic sense to produce high quality food, whilst delivering high quality environmental outcomes mingling the two throughout every aspect of what a farm does.

In our vision UK farming will also be contributing to good public health, and high standards of animal welfare. The government will need to ensure that the food we import from all over the world is also produced to a high standard. The Agriculture Bill has a role to play in delivering multiple outcomes. However we urge caution in opening up the purpose of the Bill towards delivering outcomes that can be best addressed elsewhere such as in the forthcoming food strategy.

As long as the Agriculture Bill is focused on the delivery of public goods it has huge potential to deliver real benefits for our under threat wildlife, support farmers to restore the ecosystems they rely upon, and give them greater protection against unfair supply chain practices. It also has the potential to help the agriculture sector to play a major role in tackling climate change and invest in activities that help in climate change mitigation and adaptation. But the Bill needs to be strengthened in order to deliver these benefits.

The Government has promised that the Agriculture Bill will "deliver a cleaner and healthier environment for future generations" phasing out payments simply for land owned and rewarding farmers for "public goods", such as better water quality, improved soil health, and enriched wildlife habitats. Friends of the Earth welcomes these ambitions for the Bill and the commitment to phasing out direct payments. However it must be clear that farming of the future has to build in ecosystem resilience, essential to underpinning the sustainability of farming itself.

Long term farming productivity relies on healthy soils and a recovery in the services provided by nature such as pollination and natural pest control. High input farming – including the over use of pesticides – is damaging these vital natural resources.

Farmers should not be paid pubic money for simply producing food with no regard to the likely social and environmental outcomes of this. This would repeat mistakes of the past, leading once more to potentially catastrophic environmental consequences in terms of the depletion of natural resources, and the loss of other aspects of landscapes that people value like hedgerows. Similarly rewards or grants for productivity measures must not be allowed to undermine the over-riding goals of the Bill to deliver public goods outcomes, and this needs to be clear in the definition of productivity, ideally set out in the text of the Bill.

There is also an urgent need for long term, ambitious, and legally binding targets to restore biodiversity and cut harmful inputs such as pesticides . T he Bill needs to establish a mechanism by which the actual or potential contribution of agriculture activity towards achieving such targets can be accounted for , reported against and funded accordingly

But farmers mustbe adequately rewarded in the market place for the food they produce and protected from unfair trading practices. We welcome the inclusion of measures to improve supply chain fairness and want to see these maintained and strengthened in the Bill. It is also essential that there is a decent budget underpinning the delivery of the Bills intention, well beyond the end of this parliament and suitable to the task at hand.

Key changes needed to the Bill

To ensure the Agriculture Bill delivers on its potential, and meets the Government ambition of a cleaner greener countryside, the below amendments will be necessary in the bill.

· Reflection of government policy that public goods are the primary reason for public intervention , ensuring any productivity payments should contribute to the delivery of these and providing certainty and stability for farmers

· Ambitious and measurable targets to restore our natural environment, including delivery on existing international and national commitments for biodiversity and climate change.

· A specific target for reducing the use and impact of pesticides and measures to increase the take up of Integrated Pest Management .

· A mechanism to secure long-term funding for farmers and land managers so that they can have confidence in the new system and have sufficient support to deliver the public goods we all depend on.

· The introduction of duties rather than powers to ensure current ambition is acted on in the future. These should include a duty to have an environmental land management scheme, and to ensure fairness in supply chain dealings .

· The establishment of a strong regulatory baseline with clear enforcement mechanisms to secure essential protections, and underpin taxpayer’s investment.

· Safeguards to ensure international trade deals won’t undermine domestic standards and undercut farmers in future trade deals.

Safeguarding productivity through ecosystem resilience

The June 2018 EFRA Committee report on the future for food, farming and the environment notes that farming productivity in the UK is falling behind many of the UK’s competitors. This is despite an increase in recent decades of chemical inputs, intensive cultivation, monoculture cropping and raising stocking rates above the carrying capacity of land which have increased yields, but often at the cost of lower animal welfare standards, damaged soils, increased flooding, and the loss of habitats and wildlife.

Long term productivity relies on natural resources and services such as fertile soils, pollination and natural pest control. This has been recognised by the Food and Agriculture Organisation of the United Nations (FAO) which has concluded that "while the last half-century has witnessed striking increases in global food production through intensive use of inputs, such practices may deplete natural resources and impair the ability of agro-ecosystems to sustain production into the future." [1] The FAO proposes the concept of "ecological intensification" to maintain or enhance agricultural production through the promotion of biodiversity and associated ecosystem services.

Pesticides are one of the main farming inputs used to increase production (in non-organic systems) but the assumption that using more pesticides always leads to more productivity is questionable. A study in France [2] found that the vast majority (94%) of farms would not produce less crops if they cut pesticides. It found that some of these (two-fifths) would actually produce more. There is a place for pesticides in conventional farming but over use of pesticides is damaging natural resources, posing a long term threat to the resilience of future food production.

Farmers must be supported to protect the vulnerable ecosystems upon which our economy depends, care for our landscape and heritage, look after the welfare of livestock, and help address new and growing challenges like climate change and flooding. If the Agriculture Bill fails to do this it will fail to deliver on the Government’s ambition to "leave the environment in a better state that we found it" or to deliver a "green Brexit".

This approach is supported by farmers. The Nature Friendly Farmers Network sets out the following recommendation for future payments: "We believe that nature friendly farming is not only better for nature, but is also the most productive and sustainable way of getting food from our land. We believe that the many farmers who are already playing an incredible role in helping wildlife flourish on their farms should be better supported and rewarded for their good work". "Future policy should focus on rewarding farmers to provide those benefits, especially environmental benefits that are not normally paid for through the market. This is where the majority of taxpayer money should be focused" [3] .

The approach is also supported by scientists as a way of protecting crucial pollination services. "Ecological intensification involves actively managing farmland to increase the intensity of the ecological processes that support production, such as biotic pest regulation, nutrient cycling and pollination. It means making smart use of nature's functions and services, at field and landscape scales, to enhance agricultural productivity, and reduce reliance on agrochemicals and the need for further land‐use conversion" [4] .

Rewards or grants which would pay farmers to increase productivity by intensifying inputs on the cropped area whilst at the same time paying for greening measures around the edges will not safeguard nature or food production. Instead productivity grants should be for supporting farmers to reduce inputs and could include trials of agro-ecological techniques or new technology where these can show proven benefits and safety.

Why pesticide reduction must be at the heart of the UK’s new farming policy

A reduction in pesticides – and a move towards integrated pest management (IPM) where chemical pesticides are used as a last resort to tackle pest and disease instead of a prophylactic treatment – will deliver on several of the Governments ambitions for farming and should be enabled by this Bill. This would be a significant progressive step following the UK backing of the ban of three bee-harming neonicotinoid insecticides. Bees and other wildlife are still under threat due to the over-use of pesticides.

Where pesticides are shown to be harmful they should be banned but that process can take a long time as was the case with neonicotinoids. Our countryside would be safer for wildlife if all chemical pesticide use was minimized. Defra’s Chief Scientist Professor Ian Boyd, with co-author Alice Miliner recently published a paper questioning the safety of current levels of pesticide use for the environment: "The effects of dosing whole landscapes with chemicals have been largely ignored by regulatory systems. [...]This can and should be changed." The scientists compared the overuse of pesticides to the situation with antibiotics saying that: "Both have been manufactured and supplied to market demand with little care taken to consider whether this is sensible". Both are often used prophylactically when sparing use would be more appropriate" [5] .

Bees are not the only insects at risk from pesticide use. When the massive decline in flying insects in Germany2 hit the headlines in 2017 researchers pointed to pesticide use as a potential reason. "As entire ecosystems are dependent on insects for food and as pollinators, it places the decline of insect eating birds and mammals in a new context," said lead researcher Hans de Kroon. "We need to do less of the things that we know have a negative impact, such as the use of pesticides."

Natural predators are also under threat due to over use of pesticides. For example around three quarters of ground beetle species (carabids) studied are declining. This is of concern to future food production because carabid beetles control insect pests such as aphids, slugs and wireworm9. Scientists attribute the decline to multiple threats including pesticide use and habitat loss. An independent review of available studies of impacts on earthworms (crucial to soil health) [6] concluded that earthworms are negatively impacted especially by insecticides and fungicides

An ambitious target for pesticide reduction is needed to signal the scale of change that is needed and to allow monitoring of progress. A simple target to reduce weight of product used will not be effective. To have a positive impact for the environment and health the target must take into account toxicity and frequency of use. This approach has been successfully used in Denmark [7]

An ambitious target to reduce pesticides and measures to increase take up of IPM are also needed to deliver on commitments in the Government’s 25 Year Environment Plan. The 25 year plan includes commitments to "reducing the use of pesticides in the round" and "Putting IPM at the heart of a holistic approach" to crop protection.

Currently the trends are in the wrong direction with both the area sprayed with pesticides and the frequency of applications going up [8]

Specific changes needed

1. Priority must be given to public goods

Without stating unequivocally that delivery of public goods should be the priority for public money, the Bill lacks a clear environmental purpose. We recognise that under the current system, certain farming sectors such as upland farmers are typically highly reliant on basic payments. However, upland farmers are well-placed to deliver public goods such as improving water quality, maintaining landscapes and managing upland streams to improve water quality and reduce flood risk.

The Bill should reflect the Government’s ambition for future policy, and make it clear that the list of ‘public goods’ in Clause 1(1) is the priority for funding and that any payments for productivity contribute to their delivery.

The bill should also ensure that any payments for productivity have a requirement to minimize environmental impacts associated with the activity. A specific addition should be made to the existing definition of productivity 1(4)(C) to require reducing the level of chemical or energy inputs used in, or in connection with it.

1. Need for ambitious targets to drive policy long-term

To provide a framework for future investment, and security for farmers, we need ambitious and measurable targets to contribute to the delivery of relevant national and international targets and goals. The Bill should include targets for existing commitments as well as new ambitious targets that are needed for nature’s recovery and a healthy environment.

This should include a target for pesticide reduction together with measures to support farmers to use effective alternative methods of pest control

The Bill should require Ministers to develop and report on measurable targets relevant to those purposes set out in Clause 1(1) including a target for pesticide reduction .

2. Securing long-term future of funding for the sector

Farmers need certainty over the funding available if they are to engage in the delivery of public goods. The Government has committed to ring-fence the funds from reduced direct payments to fund a pilot for the new Environmental Land Management Scheme, but there is no commitment in the Agriculture Bill to funding in the longer term.

This funding should also provide for good quality, consistent advice accessible to all farmers and land managers. Currently too much agronomic advice to farmers comes from industry agronomists selling products to the farmer – this works against aims to reduce inputs which have a cost to the farmer and the environment.

Small farms are just as well-placed as larger farms to provide the goods that the Bill lists in Clause 1. Large farms are, however, more likely to have access to business planning resources and expert advice; the Bill must therefore include the provision of advice to help those smaller farms adapt to the new system.

The Bill should place a duty on Ministers to set multi-annual budgets that reflect the scale of financial need associated with relevant policy objectives, set the timeframe over which these budgets would be set, and provide a means by which funding would be allocated between the four countries of the UK.

3. The importance of setting duties not just powers

Although the Bill includes a wide range of powers, there are very few duties or requirements on ministers with regard to how these are used, or if they are used at all. This is a major flaw that fails to reflect the ambitious policy prospectus set out by Government, or the urgent need for progress in developing future policies.

The Bill should include duties for ministers to:

· have an environmental land management scheme. Under the CAP, there is a legal obligation for each country of the UK to have an agri-environment scheme. The Bill should build from this starting point, and require ministers to use the powers in the bill to develop an environmental land management scheme for England by a set date.

· actively use supply chain powers to strengthen the position of farmers in price negotiations, with obligations applicable to all agri-food supply chains and to the widest possible extent of the supply chain.

4. Importance of establishing a strong regulatory baseline to underpin taxpayers’ investment

Although recognised as of crucial importance in the policy statement published by Defra alongside the Bill, the Agriculture Bill does not provide the necessary powers to secure a strong regulatory framework for farming and land management.  Without a strong baseline of properly monitored and enforced regulatory standards, regardless of receipt of financial assistance, any public investment will be undermined.

The Bill should provide a requirement and the powers necessary to secure strong regulatory protections for farming, environment, and access to the countryside.

Importance of fair supply chain dealing

We are pleased that the Bill includes provisions to improve fairness in supply chains which is crucial to farmer’s livelihoods. The provisions in the Bill have the potential to address, if given statutory duties and adequately resourced, many of the problems inherent in the UK’s food supply chain. The fact that this includes producers outside of the United Kingdom is welcome. It will be essential that the body undertaking enforcement has adequate powers and resources to undertake the role including recognition of the requirements for absolute confidentiality, own-initiative investigations, and liaison with the existing Groceries Code Adjudicator

· Ensure that international trade deals won’t undermine domestic standards   

The import of poor quality produce with low animal welfare and environmental standards, as a result of international trade deals after we leave the EU, poses a fundamental risk to UK agriculture. Without safeguards against artificially cheap, low quality food, insufficiently scrutinised international trade deals could undercut British farmers and undermine domestic environmental progress in the UK by exporting degradation elsewhere, generating a race to the bottom.

The Government has not acted upon the Committee’s recommendation of June 2018 to "… clearly state that it is Government policy that trade agreements should always contain provision to prevent food which does not meet our environmental, animal welfare and food safety standards entering the UK."

The Bill must not undermine animal welfare and environmental and quality standards in any future trade deal.

Other measures needed

The Bill should not be seen as the totality of government food and farming policy and we know that wider policies are still needed, particularly to address issues like healthy eating, food poverty and food security. Details of how these will be delivered are still needed, including via the forthcoming Food Strategy, Food and Farming Sector Deal, national action plans such as the National Action Plan for pesticides, and consideration of public procurement and on research and development in the sector. Similarly, it is vital that the final Brexit withdrawal agreement does not harm UK farmers’ ability to export to European Union countries.

Friends of the Earth England Wales and Northern Ireland campaigns for everyone to have a right to healthy places to live and for fair shares of our resources in order to safeguard future generations.

November 2018







[7] Danish National Actionplan on Pesticides 2017 - 2021

[8] Analyse of data available at


Prepared 13th November 2018