Agriculture Bill

Written evidence submitted by Paul Gingell (AB64)

Dear Committee Members,


1. I work on a self-employed basis repairing dry stone walls and traditional buildings - principally in the use of lime mortars. I work mainly in Cumbria and the Yorkshire Dales. My concerns about the Agriculture Bill are as follows:

2. Enforcement. Clause 1 provides for allowing the SoS to give financial assistance in the areas listed; this assumes that assistance will be sought in a time and place that serve the public interest. It may not be. Consequently, the bill is limited by not enabling activities to be enforced, where it would benefit society or future generations to do so.

3. Landscape-led Authorities. Clause 1 seeks to enable expenditure which would have impacts on the quality of the nations landscapes. This includes National Parks, AONBs and other local designations, who's responsible authorities are tasked with protecting for the benefit of future generations. In such areas, those authorities should have powers to determine where and for what such expenditure should be allocated.

4. Third-party businesses. The Government has stated its desire to move away from area-based subsidies and towards payment for activities which serve the public interest and represent good value for money. In many cases, particularly where works are specialist or labour-intensive, these activities will be undertaken by third party businesses. The bill provides little clarity about how these businesses fit within the framework established by Clause 1.

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The threat to our built heritage

5. Field walls and traditional farm buildings form an important part of both the Yorkshire Dales and Lake District national parks, as they do many in many other landscapes. Many are under threat, with roofless and poorly maintained field barns being in very imminent danger. A recent YDNP report (Field Barns, Farmsteads and Change in the Yorkshire Dales) highlighted the scale of decline over the 20th C., and I volunteer as part of a group attempting to survey and record those that survive.

6. At the current rate we are saving fewer than are being lost. Continued decline would seriously degrade the status of several of our most important national parks and limit the opportunities for future generations to benefit from the tourism potential of these area.

7. As with many sustainability adjustments the cost of early action to preserve historic structures is significantly lower than actions taken later. Dry stone walls are comparatively robust, in the sense that they can be rebuilt even if completely dilapidated, so long as the stone remains in-situ. The cost of repairing walls in such a state may be somewhat higher, but is entirely feasible.

8. Traditional farm buildings are far more difficult to revive - especially if inadequate records exists of their lost form. Plant growth and water entering the exposed wall head are normally the most vigourous agents of decay. Repair costs escalate very quickly once the roof of the structure is substantially breached. By contrast, general maintenance costs (e.g. repointing, replacing broken tiles, etc.) offer significant benefits.

9. If it hasn't already done so, the Committee might benefit from seeking the advice of Historic England on these issues.

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10. Whist voluntary schemes may be effective in meeting national targets or delivering objectives which are not location-critical, not all aspects of the environment meet these criteria. This might be because they are of fixed locations (like most heritage structures) or because specific measures are required to meet local priorities - as, for example, in the case of wildlife corridors or visitor trails.

11. In the case of historic buildings, whilst most grants include some form 'scoring assessment', they rely on applications being made by the buildings owner. There is no mechanism for actively bringing forward projects that would serve the interests of the wider rural economy - whether that be because of the high visibility of a building, or because timely intervention would be most cost effective. This inability to direct or enforce where funding is spent can only serve reduce the potential value of such schemes.

12. Mechanisms exist within Local Planning Authorities to enforce remedies to unsafe structures or eye-sores - although I don't think they would apply in many agricultural settings. The mechanisms available through ELMS would be necessarily different. One solution could be to enable a relevant authority to insist that a landowner consent to necessary activities being undertaken in order to voluntarily enter into an ELMS agreement.

13. Solving this problem must surely be a matter for primary legislation, but is not addressed in the bill.

Third-party businesses

14. Government expenditure on agri-environment schemes impacts on third party business, which themselves form an important part of the rural economy.

15. The Government's proposal to withdraw the Basic Payment Scheme inevitably means that 'public goods' will need to provide an income for the land owner and a commercially-sustainable rate for the business undertaking the works. In the case of biodiversity or water resource issues, for example, this might include direct actions on the part of the land owner. The funding model here would accord quite well with the 'getting paid for working' principle.

16. On other occasions, these actions may require labour-intensive work or specialist skills (as might be the case in repairing dry stone walls or field barns). The land owner is very unlikely to be physically involved and the value they could bring to decision-making processes would be limited. In these situations there is a risk of land owners acting purely as a 'middle man', which would be cost inefficient.

17. This poses two risks to third-party businesses. Firstly, if it proves politically palatable to maintain farm incomes at similar levels, downward pressure is likely to fall on these businesses. Secondly, it provides no obvious mechanism for such businesses to engage with the prioritisation and planning stages. In these regards, the framework established by Clause 1 would seem little different to existing schemes under CAP.

March 2020


Prepared 4th March 2020