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Defra must publish a full impact assessment of farm policies on domestic food production

Julian Sturdy MP

November 2023

Science for Sustainable Agriculture

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Highlighting concerns that a UK policy emphasis on lower-yield farming practices and land use change will inevitably take its toll on domestic food production, Julian Sturdy MP calls on Defra to publish a full impact assessment of its Environmental Land Management (ELM) and Sustainable Farming Incentive (SFI) policies on farm-level yields, national agricultural productivity growth, and domestic food self-sufficiency. It is not too late to adopt a data-led approach to measure and monitor the impact of our farm policies, he argues. The Agriculture Act includes specific provisions to equip farmers with the technology to generate, collect and share data, and to support productivity improvements. Together, these policy tools could and should be used not only to track the impact of government policies, but also to inform and drive sustainable gains in agricultural productivity, and to benchmark and reward farmers for genuine progress in reducing their environmental footprint per unit of food produced. It is vital that we adopt a clear-sighted, evidence-based approach to the development and implementation of future farm policies. Otherwise, we may risk sleepwalking into a food crisis, he warns.  

 

In an increasingly volatile world, with food prices and availability seriously impacted by war, geopolitical instability and a rapidly changing climate, safeguarding our future food security is becoming as important as national security.

 

Significantly, the UK government has made a policy commitment, set out in the June 2022 Food Strategy, to maintain national food production at current levels. 

 

It is therefore important that our food and farming policies follow an evidence-based approach, and that we have a clear understanding of their likely effect on yields and home-grown food production. 

 

In a recent Parliamentary Question, I asked whether Defra had conducted an impact assessment of its Environmental Land Management (ELM) and Sustainable Farming Incentive (SFI) policies on farm-level yields, national agricultural productivity growth, and domestic food self-sufficiency.

 

We need to understand the full implications of SFI options, such as paying farmers not to use approved insecticides, to reduce fertiliser use below optimum productivity levels, to plant wildflower meadows rather than food crops, and to take productive farmland out of production.

 

I am concerned that the policy emphasis on lower-yield farming practices such as these will inevitably take its toll on our domestic food production capacity, and increase our dependence on imports.

 

I am equally concerned that other ELM policies which support the loss of productive farmland to ‘landscape-scale recovery’ schemes are not framed within a coherent land use strategy, or with a clear vision of how national food production will be maintained.

 

Scarcely a week goes by without reports of new solar farm developments, or tenanted farms being taken back in hand by landowners for rewilding or tree-planting.

 

How will all these factors impact our ability to feed ourselves?     

 

Disappointingly, the 209-word response from Defra did not inspire confidence that the department has a grip on how its policies will affect our future food security.

 

It did not point towards an impact assessment, or even sources of evidence and data, to support the government’s policy framework. Instead, the department’s approach appears to be based on NGO-inspired greenwash and wishful thinking.

 

So, according to Defra, a reduction in overall farm output as a result of taking land out of production ‘is likely to be offset by long term improvements in soil health and pollinator abundance, which will support increased yields’.

 

No doubt that’s what the environmental NGOs who designed many of these SFI schemes would have us believe, but where are the facts, data, evidence for this?

 

Similarly, Defra’s suggestion that reducing the use of fertilisers or pesticides will lead to “lower inputs and higher productivity” is just magical thinking.

 

The idea that our highly professional, well-equipped farmers are recreationally applying pesticides and fertilisers, and not already optimising their use to enhance productivity, is groundless, not to say patronising, particularly at recent input price levels.

 

Through its Farm to Fork Strategy, the EU is also targeting lower yield farming policies.

 

Writing in the journal Food Policy in April 2022, Professor Robert Paarlberg of the Harvard Kenndy Business School highlighted the transatlantic policy tensions over ‘green’ farming.

 

He contrasted EU farm policies, including plans to expand organic farming, reduce pesticide and fertiliser use, and reject modern biotechnology, with the US Agricultural Innovation Agenda, which emphasises the use of agricultural innovation with a stated aim to increase production by 40%, while cutting the environmental footprint of US agriculture in half, by 2050.    

 

Paarlberg suggests that Europe’s plan is anything but ‘green’, since more land would needed for food production, with damaging effects on wildlife habitats and the climate.

 

According to an analysis of the F2F Strategy by Wageningen University, the cumulative impact of the Farm to Fork targets would lead to a decline in EU agricultural production by 10-20% on average, with up to 30% drop for certain crops. Meanwhile emissions and negative environmental impacts would be externalised to countries outside the EU due to increased food imports.

 

The potentially negative impacts of F2F on EU food production were further highlighted in a report by the Joint Research Centre (JRC), the European Commission’s research arm, which estimated reductions in the supply of cereals and oilseeds (-15%), vegetables (-12%), meat (-14%) and dairy (-10%).

 

Following the outbreak of war in Ukraine, French President Emmanual Macron suggested that the F2F Strategy should be fundamentally reviewed, acknowledging that it would reduce EU food production by 13% (as per the JRC report cited above), and that the policy was ‘based on a pre-Ukraine war world.’

 

Subsequent policy developments suggest that the EU’s flagship farm policy may indeed be unravelling, with recent decisions to renew EU approval of glyphosate for a further 10 years, to throw out the SUR directive targeting a 50% reduction in pesticide use, and to accelerate the deregulation of gene editing in the bloc all pointing to a rebalancing of scientific evidence over ideology.

 

The UK government, by contrast, has no such evidence base or impact assessment to consult. Instead, Ministers appear to have adopted a ‘fingers crossed’ approach.

 

It is not enough to conduct ex-post assessments of UK food security once every three years, as set out in the Agriculture Act. By then, the trees may have been planted, the solar farms constructed, the tenanted farms rewilded, the farm infrastructure plans cancelled, and the R&D investments diverted elsewhere. 

 

That’s why I am urging Ministers to publish a full ex-ante impact assessment of ELM and SFI policies on agricultural productivity and domestic self-sufficiency in food.

 

It is not too late to adopt a data-led approach to measure and monitor the impact of our farm policies. The Agriculture Act includes specific provisions to equip farmers with the technology to generate, collect and share data, and to support productivity improvements.

 

Defra has already funded a significant body of work on sustainability indicators and metrics as part of the Sustainable Intensification Research Programme, including the prototype development of a first-of-its-kind benchmarking dashboard allowing farmers to assess and compare their performance against those indicators and against a weighted average of up to 25 other farmers.

 

Together, these policy tools could and should be used not only to track the impact of government policies, but also to inform and drive sustainable gains in agricultural productivity, and to benchmark and reward farmers for genuine progress in reducing their environmental footprint per unit of food produced.

 

It is vital that we adopt a clear-sighted, evidence-based approach to the development and implementation of future farm policies. Otherwise, we may risk sleepwalking into a food crisis. 

 

Julian Sturdy is Conservative MP for the York Outer constituency. A regular contributor in Parliament on farming and rural policy issues, he chairs the All-Party Parliamentary Group on Science and Technology in Agriculture, and is a member of the Environment, Food and Rural Affairs Committee.

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