Defra's consultation on environmental targets closed on 27 June 2022.
We submitted a full response. You can read it in full here: NFU response to Defra consultation on environmental targets June 2022 (PDF download, 432 KB)
In our response we highlighted the willingness of farmers to continue to play a huge role in meeting the environmental challenges of our countryside, alongside providing food for the nation.
We also set out our concerns about the:
- achievability of the proposed targets
- extent of possible land use change that may be needed as a result of meeting the targets
- heavy reliance on the new ELMs (Environmental Land Management scheme) to deliver the targets
- unaccounted cost to agriculture of achieving the targets
- short timescales that Defra is working towards to have statutory instruments in place, leaving little time for full consideration of the consultation responses.
Our view is that any new targets must:
- have a clear evidence base for inclusion
- have a clear baseline
- be achievable, measurable and affordable
- have the right supportive policy mechanisms in place.
We are concerned about the highly ambitious programme of land use change and management to achieve a number of the targets. This includes woodland cover target (3% land use change) and the long-term species abundance target (by implication a 5% land use change) but particularly the water quality in agriculture target (20% land use change) and the subsequent significant impact on food production, in terms of food security but also land values.
It is concerning to us that these proposals appear to conflict with food production. They would require a long-term or irreversible change to the productive capacity of farmland, such as tree planting and re-wilding.
We note the extent to which Defra places significant emphasis and expectation of participation in ELMs and uptake of different options or measures in ELMs to deliver on the environmental targets. With the SFI (Sustainable Farming Incentive) scheme still at development stage along with the wider ELM offer, all due to be more available in 2024, it is impossible to say if uptake of ELMs will meet the level of ambition to deliver.
It is also of concern to us that the impact assessment does not consider the impact of individual policies, in terms of who would bear the costs and what impact this would have on individual businesses, land use change and food security. These are huge gaps in the analysis. Affordability to the agriculture sector must be a key test, yet it appears to have been ignored.
We are concerned about the tight timescales that Defra is operating within after the close of the consultation. This current timetable does not allow enough time for Defra to give careful consideration to the consultation responses and adequate time to rethink whether these targets are achievable and affordable.