We asked David Morley, Environmental Advisor for H & H Property based in Carlisle about his views on Countryside Stewardship and how it will work on common land and hill farms. In David's opinion the scheme is not well tailored for the uplands. David writes:
I have been helping the Foundation for Common Land with technical advice on the new Countryside Stewardship Scheme. Having been through the first year of applications, we now have some experience of how the Scheme works in practice and were asked to provide some feedback to DEFRA and Natural England. Not all the comments below relate specifically to common land (which can only go into Higher Tier), but they do affect upland farmers more generally.
Mid Tier.
1. The lack of option availability makes the Mid Tier scheme all but impossible to access for upland farmers. On most upland farms, “very low input grassland management” (GS5) is the only option available and, at £16 per ha, a farmer has to do a lot of it to get over the £1000 per annum minimum threshold. If a farm is less than 60 ha, even using GS5 across the entire holding is insufficient to meet the minimum. That means small upland farms are effectively excluded from the scheme altogether.
2. There are a lot of issues with the GS5 option, including:
a) low payment rate
b) onerous application requirements (a botanical survey plus soil sampling for every field)
c) restrictive eligibility criteria
d) Does not allow any supplementary feeding
e) Can only be used on whole-fields
In combination, these things make GS5 almost unusable, which is not ideal when it is often the only option available in the uplands
3. There were several options that were in UELS that delivered significant environmental benefits that are absent from the new scheme, including:
a) Haymaking
b) Cattle grazing
c) Dry stone wall maintenance
Adding such options to Countryside Stewardship should be considered a priority to make it more attractive to upland farmers.
4. The absence of a Wild Pollinator & Farm Wildlife Package (WPFWP) in the SDA significantly disadvantages upland farmers. Undertaking the WPFWP increases the chance of an application being accepted, an opportunity being denied to upland farmers. However, there is no reason why an upland WPFWP could not be designed using existing options in the Scheme.
5. The eligibility criteria on SW options prevent their use in the uplands. For example, “buffer strips” (SW2) and “grassland management next to watercourses” (SW8) can only be used with very high current fertiliser rates, which are highly unlikely in the uplands. I believe an “upland” version of SW8 is needed to address this gap in the scheme.
6. Restrictions on land that can be used for arable options is a further issue in the uplands. A lot of upland farms grow one or two fields of barley each year on a long rotation, such that most fields going into crop have been permanent pasture. This makes them ineligible for any of the arable options.
7. There are two issues with “Rush Infestation Control” (GS16). Firstly, it is restricted to only 3 years of payments. In severely rush-infested pastures in the uplands, it is highly likely that ongoing control will be needed beyond 3 years. Secondly, it makes no sense that weed-wiping is permissible only for Higher Tier agreements and not Mid Tier. Weed-wiping is a targeted and effective way of initially controlling rushes and is far more likely to have the desired effect than a combination of cutting and grazing alone.
8. Traditional farm buildings are a high priority in all upland areas and appear in all the associated Statements of Priority. However, they do not contribute to scoring in Mid Tier, which gives rise to the perverse situation where including option HS1 to manage high priority buildings can reduce the chances of being accepted for an agreement. This clearly needs to be addressed.
9. I am concerned that, in the uplands, GS5 and HS5 (“Management of historic features on Grassland”) cannot be co-located. GS5 and HS5 are doing different things and their prescriptions are perfectly compatible, so there is no “dual-funding” issue. Therefore, I can see no reason why they cannot be co-located. Otherwise, applicants are being asked to choose between conserving habitats and historic features.
With Mid Tier, it is the combination of factors that effectively render the scheme inaccessible to most upland farmers. I am concerned that many farmers who have been in schemes for many years will no longer be able to access them. Upland farmers depend more than anyone on environmental payments; without them, I believe many farmers will either intensify or sell up. Neither is likely to be beneficial for biodiversity or the upland landscape.
Higher Tier
1. The timescales for the Expression of Interest process are a problem with regard to common land. As all the negotiations, internal agreement and (if applicable) Secretary of State Consent for any fencing works must be concluded before the application can be submitted, a lead time of at least 12 months is needed. This year, the gap between Expression of Interest and the application deadline was only 4 months. With common land, the commitment of Natural England staff is needed at a much earlier stage. There is a risk that commons agreements will always end up starting a year late, with a potentially significant gap between the old agreement and the new one.
2. “Livestock exclusion supplement for scrub creation” (WD9) is not available above the moorland line. Most Higher Tier commons agreements will require areas to be fenced off and planted. Usually, the landowner takes the payment for the planting itself, as the commoners do not have the right to plant trees. However, the graziers need to be compensated for the loss of grazing on planted areas.
3. “Wood pasture management” options (WD4 to WD6) are only available for “lowland” wood-pasture but upland wood-pasture is an even rarer habitat and very valuable, especially on common land.
4. I don’t understand why “scrub management” (WD7) is restricted to land next to existing areas of scrub. That makes little sense, certainly in relation to common land.
