Y Pwyllgor Newid Hinsawdd, Amgylchedd a Materion Gwledig - Y Bumed Senedd

Climate Change, Environment and Rural Affairs Committee - Fifth Senedd


Aelodau'r Pwyllgor a oedd yn bresennol

Committee Members in Attendance

Andrew R.T. Davies AM
Gareth Bennett AM
Jenny Rathbone AM
John Griffiths AM
Joyce Watson AM
Llyr Gruffydd AM
Mike Hedges AM Cadeirydd y Pwyllgor
Committee Chair

Y rhai eraill a oedd yn bresennol

Others in Attendance

Annie Smith Cyswllt Amgylchedd Cymru
Wales Environment Link
Anthony Geddes Rheolwr Cenedlaethol Cymru, Confor
National Manager for Wales, Confor
Arfon Williams Rheolwr Polisi Defnydd Tir, Royal Society for the Protection of Birds (RSPB) Cymru
Land Use Policy Manager, Royal Society for the Protection of Birds (RSPB) Cymru
Charlotte Priddy Swyddog Polisi, Undeb Amaethwyr Cymru
Policy Officer, Farmers Union of Wales
Rachel Lewis-Davies Cynghorwr ar yr Amgylchedd/Materion Gwledig, Undeb Cenedlaethol yr Amaethwyr Cymru
Environment/Rural Affairs Adviser, National Farmers Union Cymru

Swyddogion y Senedd a oedd yn bresennol

Senedd Officials in Attendance

Elizabeth Wilkinson Ail Glerc
Second Clerk
Katy Orford Ymchwilydd
Lowri Jones Dirprwy Glerc
Deputy Clerk
Marc Wyn Jones Clerc

Cofnodir y trafodion yn yr iaith y llefarwyd hwy ynddi yn y pwyllgor. Yn ogystal, cynhwysir trawsgrifiad o’r cyfieithu ar y pryd. Lle mae cyfranwyr wedi darparu cywiriadau i’w tystiolaeth, nodir y rheini yn y trawsgrifiad.

The proceedings are reported in the language in which they were spoken in the committee. In addition, a transcription of the simultaneous interpretation is included. Where contributors have supplied corrections to their evidence, these are noted in the transcript.

Dechreuodd y cyfarfod am 09:15.

The meeting began at 09:15.

1. Cyflwyniad, ymddiheuriadau, dirprwyon a datgan buddiannau
1. Introductions, apologies, substitutions and declarations of interest

Bore da. Good morning. Can I welcome Members to the meeting? Any declarations of interest?

Yes. I'm a member of the Royal Society for the Protection of Birds.

Okay. That's duly noted.

We've had apologies from Helen Mary Jones, and I don't believe we've got a substitute.

2. Trafod Bioamrywiaeth – Cynllun Nwyddau Cyhoeddus: sesiwn dystiolaeth gyda sefydliadau amgylcheddol
2. Consideration of Biodiversity - Public Goods Scheme: evidence session with environmental organisations

Moving on, then, to the first evidence session with environmental organisations regarding the public goods scheme and biodiversity. Can I welcome Annie Smith of Wales Environment Link and Arfon Williams, land use policy manager of the RSPB. Are you okay for us to go straight to questions?

If I can start: what are the gaps or limitations in the existing legislation and policy that could be addressed through a public goods scheme to improve biodiversity restoration in Wales?

Thanks. I'll go first. The public goods scheme is something that is essential if we are going to restore biodiversity in Wales. It's a critical part of what's needed, but it's not the only thing. We have, in particular through Brexit, the prospect of gaps emerging in the protections that our environment is afforded, and a key gap there is in relation to the enforcement of environmental laws, so the provision of governance and citizens' rights to raise issues around the way laws are implemented. So, that sort of framework, which I know the committee's considered, of establishing new governance arrangements and enshrining environmental principles firmly into domestic law as a kind of overarching framework is really a critical aspect.

Another element of the current framework that can be improved upon, we feel, is in the way that targets for nature's recovery are described, both in the statutory sort of element and within our existing policies and plans. So, the nature recovery action plan, which Wales Environment Link mentioned in evidence, which is a critical instrument for nature recovery on land and sea and which is going through a review at present, needs to really set out what the critical actions are and who needs to be held accountable for those, and that needs to be a plan that's taken to the heart of Government by the environment Minister so that each Minister knows their role in delivering that.

And just in relation to the targets framework, we're really pleased, actually, that in the current consultation on national milestones under the Well-being of Future Generations (Wales) Act 2015, biological diversity is listed as one of the indicators where a milestone should be developed, and that goes back to the work of this committee's predecessor on the environment Bill, where we discussed a biodiversity index, and the committee's advice was that that should be brought into the framework of national milestones. So, that's really positive, but I think, as we approach 2020, with the Convention on Biological Diversity biodiversity international targets, which we can see are going to be missed yet again—and the international community is looking at establishing new targets for nature's recovery—then I think, looking at the key elements of what's needed to drive nature's recovery and how that could be linked more firmly into Wales's statutory framework would be a really positive move.

The final thing I'm going to say, and then I'm going to pass on to Arfon, is that, notwithstanding those gaps, there is an extensive framework for delivery of nature conservation in our statute already, and one of the critical problems we see is implementation. So, the resourcing of Natural Resources Wales to deliver nature conservation, for example, is a key issue, securing management of our protected sites et cetera, and obviously the public goods scheme is a key stream that can work in tandem with those existing provisions that establish priorities spatially and in a more widespread way so it can really enhance the implementation of the framework that already exists.

No, I'm quite happy.

Thank you. What are your views on the delay of the implementation of area statements to March 2020?


You might need to correct my understanding of this, but my understanding is that March 2020 is the date when all statements are expected to be published by. So, that's a bit of a delay from what the Welsh Government originally said would be the end of this year. But I think, to be fair to NRW, that reflects a delay of a good few months in the publication of the natural resources policy compared to the statutory deadline that the environment Bill sets for that. So, I think there is urgency now to getting those processes under way in terms of developing area statements. We're aware of masses of work, but it's mainly behind the scenes so far. So, the stage of discussing plans, processes, and how to bring together those stakeholders and identify priorities is really critical.

The only thing I'd add to that—I think the public goods scheme has to speak to the area-statement approach. There's a concern that if the delays in the area statements somehow have a kind of a negative impact on the development of the public goods scheme, in a way that's a misalignment between the two, then, I think that would be of—you know, we would be worried by that.

Thanks, Chair. Now, if the public goods scheme is going to be effective in restoring biodiversity, it's going to have to be funded properly and, Annie, you mentioned the problems of funding nature conservation at the moment. So, if we think about where the funding could come from, apart from public funding, could it come from other sectors such as those involved in tourism, water and flooding?

Again, I think the answer to that is, you know, the public goods scheme is a big part of the answer, but the answer extends beyond it. So, yes, I think that it's important to explore opportunities for different sectors to channel resources into the restoration of the countryside, which underpins our economy, and you mention tourism, et cetera, the key prong of Wales's economy. I think that opportunities to stitch everything together are immense and precarious; we need to get it right so that—.

Another strand of policy is, of course, the national development framework, which is going to be consulted on later in this year. Integrating the priorities from the natural resources policy, that can help to show a pathway, again, for how, I think, potentially, private sector organisations have a role to play in delivering benefits for biodiversity through the planning system. So, I think that's one critical aspect. And again, going back to area statements, where partners come together—so, the third sector organisations like the RSPB and other Wales Environment Link members, with companies like Welsh Water, national park authorities—we have great potential to design projects that can have an impact on a big scale, and in doing that, to unlock charitable sources of funding from elsewhere, from the Heritage Lottery Fund, for example, that can bring money into Wales to deliver our sustainable natural resources management.

It's worth mentioning the critical role that the EU LIFE nature fund has played in enabling some of those collaborations and really substantial habitat improvement and community benefit products to take place.

Just a couple of additions to that, really, or, perhaps, the context for those. I think there are opportunities for funds to be brought in from outside, in addition to public funding, and there are examples of RSPB and other non-governmental organisations working with water companies and utility companies in the UK. A good example is the sustainable catchment management programme project up in the north of England, where RSPB are working with water companies to improve water quality within catchments, working with farming communities. I listened with interest this morning to the radio, coming into Cardiff, about Edinburgh looking at a tourism tax, and a tourism tax, I think, is something that has been spoken about as a means of helping mobilise economies in a way that benefits those providers. Within that, I would include farmers and land managers who create tourist opportunities for others to enjoy in Wales, so I think there are some quite exciting developments out there that we should be aware of and start pursuing ourselves.

I would also say that, in conversation with private investors, regulation and regulatory baseline are really important to provide confidence to investment, so that's something to be mindful of when we look to any type of investment into securing public goods. And, just to finish off on how much it's going to take to deliver public good benefits or environmental objectives, in Wales, RSPB, working with the National Trust and the Wildlife Trust, have produced some information on the scale of need. I think it's been circulated to the committee already, but it identifies that Wales would require an annual amount—something along the lines of £210 million—to deliver environmental priorities and strategies. Much of that would be through payment to land managers to deliver public goods.


Arfon has developed a little bit of what I was hoping to pursue, in terms of leveraging more private sector investment, because we've been talking about this for years and years and years, really, and progress has been painfully slow, to the point where insurance companies aren't going to come to the table and say, 'We're going to give you money to do this', are they, really? And when we talk about private sector investment, you then said to leverage charitable funding and—. So, really, we are looking at public money and charitable funding to deliver a lot of this, aren't we? What I'm getting at is: is it a little bit pie in the sky to expect, in this current economic climate, private companies to come to the table and say, 'Yes, we'll put £1 million down here'?

That might be the case. I think there are a couple of routes, though. I mean, the new 'Planning Policy Wales' is clear that new developments should look to provide biodiversity benefit, and the policy framework we have is clear that we want biodiversity benefit in the context of ecosystem resilience, and actually, the area statements should identify how and where we can really invest in that to get the greatest results. And if you think of a planning system that is able to channel investment, if you're looking at renewable energy developments, for example, at the right issues to really help restore biodiversity, I think there is an opportunity. I'll just mention, we've mentioned NRW's declining budget, and I'm sure that the committee's aware of this, but the part of NRW that is most squeezed by those cuts is the part that is responsible for delivering nature conservation and the sustainable management of natural resources.

The forestry income, currently, under the Orders that established NRW, is ring-fenced and channelled back into the forest estate. That's an example of a way in which some of that income could potentially be unlocked and more equitably spent on the wider environment in pursuit of NRW's purpose. 

And just one more thing about the private sector is renewable energy installations that are on the public estate—NRW-managed forests, for example—those companies pay massive receipts for those devices that are installed, and we've said for years, 'Can't we re-channel that money into our natural resources and restoring—?'

Okay. So, just for clarity, then—and I'm not in favour or against expressing a view here—it's regulating the private sector in order to leverage that money. 

Yes, that's a big part of it, yes.

And in relation to NRW, because that's the other thing I wanted to raise very briefly, everybody's telling us, except for the Government, that NRW don't have enough resources to deliver their duties and services. So, what are they not doing now that they used to do, given that they have a reduced budget, compared to what they had when they started five years ago, in relation to biodiversity? Because the Government is saying that it's not having an effect, although it is aware that they're difficult times, but everybody else seems to be telling us that they're not doing their job anymore.

Anecdotally, from discussions within the biodiversity community and from our work on the ground, it's clear that NRW is not able to invest in management agreements for sites of special scientific interest. So, brokering agreements with land managers to deliver the positive management those sites need. To step back from that, there hasn't been a survey or monitoring carried out on the condition of our sites of special scientific interest since 2006, at which point we found that almost 70 per cent were in an unfavourable condition. So, that's one of the fundamental building blocks of our ecosystems and nature—protected sites are almost the powerhouses. If we can get those places right then we have a chance of pushing that nature out into the wider countryside, and that's a key function that's not being delivered.


—just respond to the earlier point Llyr made about concern about investment from outside, and that being kind of pie in the sky? I think there are opportunities. They're going to take time to develop. I think there will be some national-type opportunities around carbon trading. I also think, importantly, we need to start looking at more local arrangements, and we've got examples where we're using sustainable management scheme funding down on the Gwent levels to try and identify what it is that local communities value and what they would like farming and land management to secure for them within that kind of local region. So, that then starts identifying where those relationships, and potentially economic relationships, could exist. So, I think it's important not to ignore the fact that there are probably going to be lots of solutions that might look very different in different parts of Wales, but I agree that we're not there yet, so it does emphasise the importance of retaining budgets, retaining the funding that we've got, but also making sure that it works as hard as possible, and delivers as much value for the public as possible, in order to build a case to retain it going forward.

Could we turn this on its head and could we look at, when we look at tourism, the types of income that nature tourism brings to Wales? If we look at the Gwent levels—I've been there a few times—and the money that comes into that area because of nature; if we look at Cilgerran, Ynys-hir and Lake Vyrnwy, and I could go on, because I've visited nearly all of them, there is a huge financial attraction to those areas purely because people want to see nature, and particularly birds, which is why I go there. So isn't it time—? Do you think it's time that the Government recognised the value of nature tourism, which somehow never seems to get mentioned, when they're looking at the wider economic benefits and reinvesting in that to keep it going, if we just look at pure economics?

I absolutely agree with that and I think the one figure I am aware of, and it goes back a wee while now, but it's a figure in the national ecosystem assessment that gives the value of nature-related activity and tourism in Wales as £1.9 billion. It's the same report that gives the value of food production or farming as £1.6 billion. So, it shows that it's a significantly important economy to Wales—obviously not separate. These are things that integrate and fit together, but I think to ignore the value of that; it's a growing economy as well, and parts of farming, you would argue, are a diminishing economy. So I think it does point to important economies, and it points to how parts of Wales might be able to become more resilient when it comes to the value and importance of land, and how we manage land and what it's important for. But I realise—I see Llyr looking at me there, but I think that integration between land management and tourism and biodiversity—there are clear connections there. So the challenge is not just nature tourism, but nature and land—bring these to the table as equal partners and start talking about the future in a much more joined-up sort of way

I just wanted to go back to companies' corporate responsibilities as a possible source of funding, because if we try and set aside the current existential crisis posed by a Brexit 'no deal', if we hopefully move beyond that, what work has your organisations done to encourage companies to sponsor biodiversity as part of their demonstration of corporate responsibility, because it's something that certainly engages the public. I'm not sure whether enough is being done to do this, and I just wondered if you could tell us what you've managed to achieve so far, and whether you think there's more mileage in it. 


I haven't got a very complete answer to that, because I know that different WEL members have different relationships with companies, and I can't give a proper account of those. I know that, as the RSPB, it's an area that we're always looking at—you know, 'Where are partnerships possible?' The plastic bag money in Wales has given the opportunity for a couple of really great partnerships, like our 'Giving nature a home' project. It's linked to funding through the money raised through the plastic bag levy with Aldi, and we've had a relationship with Tesco in the past. I know that other partners of ours are in similar situations, but beyond that—

But that's an obvious one, and a lot of other supermarkets give money to the local cancer charity, unrelated to the specific eco issue. 

That's true, and you'll remember that the Environment (Wales) Act 2016 does allow for regulations to be made that channel the plastic bag levy into environmental causes.

Okay. Going back, though, to whether we've tapped into—. You know, at what point—? How successful have you been in tapping into companies' corporate responsibilities and directing them towards conservation of our biodiversity before it disappears? 

I think that's an area that's not fully tapped and, as I say, is being explored all the time. There are almost obvious companies that we can work with on the ground, like Dŵr Cymru/Welsh Water, for example—

—Severn Trent at Lake Vyrnwy, and that sort of thing. 

We have to move on, Jenny, I'm afraid. John Griffiths. 

A few questions, really, about how the public goods scheme might operate. Firstly, do you think there should be any element of reward for historical conservation management in the scheme? 

This is a point that comes up regularly. Where you've got good management of land that is delivering desired outcomes and objectives, then that should definitely be rewarded. Otherwise, we find ourselves in a perverse situation where, from a biodiversity point of view, we've got significant and ongoing decline to biodiversity. That requires much better management of land. So, we certainly wouldn't want to see a scheme or a future programme that doesn't reward existing good management. A key starting point is where we've got farmers doing the right things for nature and delivering public goods and biodiversity, we very much want to see that continue. 

How does that sit, then, with additionality—you know, the idea that payments should drive improvement and enhancement of what's currently in place? 

My understanding of additionality—we have a regulatory floor that sets the standard, and then additionality is for activities or management that delivers outcomes above and beyond that. I think where past agri-environment schemes have failed sometimes, they've not always directed the right management in the right places. They've not always incentivised management that leads to change or that maintains habitat in a condition and to an extent that's important to maintain biodiversity. So, it's looking at rewarding the right management in the right places, but then incentivising a change in management where it's required to deliver outcomes. What we've got to avoid doing, and this is a criticism of past schemes—Glastir and Tir Gofal—is using public money to pay for the wrong management in the wrong places, or management, really, that wasn't delivering any real benefit. 


Okay. So, sometimes it was money being channelled to land managers without actually achieving any environmental improvements over and above what was currently the case. 

Yes, and it was a missed opportunity, really, because with the right sort of advice and guidance, possibly the right sort of support, that money could have been channelled to those land managers and those farmers, and with an understanding of what was expected, it could have been used to move things forward, except for the of lack of—and I guess we'll come to this later—support and advice and guidance and people on the ground to give them that help. I think that's led to public money not actually delivering the value that it could. 

Just one other thing, Chair, if I might—just on the regulatory baseline that you mentioned, then, what might a new regulatory baseline look like? What should it look like, do you think?

If this is just biodiversity, and we're just staying within the realms of biodiversity, I think we've got the environmental impact assessment, we've got means of protecting habitat. We are still losing habitat—we're still losing an awful lot of habitat. So, we need to ensure that we have a robust and rigorous means of assessing changes, and if there's a proposal for a change to habitat, we need to ensure that we assess the value of the habitat, and the impact of potential change. And if needs be, the decision has to be, 'No, we stick with the habitat.' So, I think it's making sure that we have a system that doesn't result in less biodiversity and declining biodiversity, and that we have something that leads to the restoration of biodiversity and protection of habitats. 

Thank you. Andrew—. Oh, sorry, I didn't hear you; please go ahead. 

I just wanted to add to that. So, Arfon's talking about using environmental impact assessments to make sure we're not losing more nature. We've mentioned our network of protected sites already, which have associated, clear listed things that are going to be damaging and shouldn't be done. So, I think that should be a part of it. And then the committee will be very familiar with issues around water pollution et cetera, and ensuring that regulations in that regard are adhered to is obviously critical. And that impacts on our marine protected areas, and our wider marine environment, as well as the immediate land environment, of course. 

Sorry I was late, Chairman, and I refer the committee to my declaration of interest as well in this particular matter.

Arfon, I was just interested in the points you were making about Tir Gofal and Glastir, in particular that outcomes were not always secured and basically poor value for money. If you flip the coin the other way, many of the people who participate in those schemes were saying they were too prescriptive, and actually, as I understand them, there were contract, legal contracts, and obligations were placed on the people who had the contracts. So, can you give us a bit more understanding of where you think they were falling down in providing value for money, because, as I said, there's strong evidence to point that, actually, they were far too prescriptive in what they were seeking to achieve?

I think you've probably highlighted one of the issues as well. If they were too prescriptive—. Basically, there were prescriptions that were built on things like income forgone, costs incurred, and some notion of an average farmer or an average habitat. Well, there's no such thing as an average farmer or an average habitat or an average kind of means of management within Wales. I think we need to, in some cases, move away from a prescriptive approach and start working with farmers and land managers to describe and understand what it is that we are trying to achieve, achieve in partnership, and then provide the kind of freedom and flexibility to farmers, using their stock and their knowledge and their skills, to achieve that. 

The role of organisations like RSPB and other environmental organisations, Welsh Government and Natural Resources Wales is to provide support and guidance, and ongoing support and guidance. I think where Tir Gofal and Glastir—. Certainly, Tir Gofal provided a lot more support and guidance. That dropped off with Glastir. So, there was a lot effort early on going into setting up schemes. However, without the support—. With that support comes the understanding of what you're doing. So, that's essential to include that going forward. I think farmers—. Basically, when you're presented with a 100-page document, full of lists and lists of prescriptions—what you've got to do, when, and how, and how many livestock units—then it's an incredibly tricky thing to understand, and it's a very tricky thing to then implement.


So, your criticism is they were too prescriptive at the start, and not flexible enough as they evolved on the delivery on the farm itself, and things need to be far more individual for specific farms, they do. Is that a fair observation?

I think that's a fair observation. And also, from a biodiversity point of view, and certainly a species point of view, the schemes didn't really think about a species' full ecological requirements—you know, what a species would require to thrive. So, if a scheme—something like Tir Gofal or Glastir—only put in one element of a habitat, or a species requirement, then it won't support that species. And because these farms and these schemes work in isolation—and that's another thing we need to move away from; each scheme was a farm, and each farm was almost an island, really, when it came to what that farm was doing—these farms weren't working in combination, or these farms weren't getting together in order to come up with, say, a land management plan for curlew, or yellowhammers, or whatever. So, until we get to a point where you've got this co-operation, in order to put in place everything a species requires, and farmers understand what it is that's required of them—they're given the freedom to operate within the circumstances of their farm, but what's important in that is they have the help and support to do it—then we are going to struggle to use agri-environment as a way of reversing biodiversity declines.

That takes us on nicely, actually, because I want to look at scale, and at what scale you think the public good scheme could reasonably operate. Because you talked about previous or existing schemes, where farms are working in isolation—so, where do you pitch it, then?

The issue of scale, to some extent, depends on the public good you're delivering. I think there will be some public goods—even some species and some habitats—that you can benefit on a field scale, and possibly within a farm scale. When you get on to the more mobile species, and I've described the need for co-operation when you're working with a mobile species, we're not talking about animals, or individual pairs, or birds, say—it's populations. So, it's having to work on the appropriate scale. So we're up to landscape scale there. An example: the British Trust for Ornithology—an example that's also in 'State of Birds in Wales'—some radio-tracking of curlew up in north Wales. Some of those birds are using the landscape and travelling several kilometres during the course of a day. So, in order to come up with a land management package that works for curlew there, you need to start thinking about how we manage the important components within this landscape at a large scale. And the same would apply to, say, if your objective was improving water quality within a catchment—it's working on that scale.

I'm sounding very cynical this morning, and honestly I'm not—I'm being devil's advocate here somewhat. You've spoken about the need to have a greater flexibility, in response to previous answers, and basically you're looking at a bespoke approach for each individual farm, which comes together, then, on a collective basis, potentially on a catchment-wide scale, in the context or an environment where we have diminishing resources. We all want the best; the reality is that that's undeliverable, surely, across Wales, clearly.

What I'm describing—or what you're describing very well there, actually—is that very targeted approach. So, that needs to be quite strategic. And when we start talking about water quality, there are opportunities then to bring in that funding from elsewhere, as we described earlier on. But if I can back it up a little bit as well, I think there is scope for an element before this targeted approach. And I think there still is this scope for this universally tenable-type scheme, where farmers can possibly go into a more action-based set of habitat management—I think a shorter list than we've had previously, so we need to think about what actually works. If we applied these measures universally across Wales, they have to be things that deliver genuine value for money, but they also have to be things that can be delivered quite easily. So, there is an element of perhaps action or prescriptiveness to those, but they have to be simple, they have to be clear and they have to have a simple approach to monitoring, but they have to deliver genuine benefits. So, there's a challenge there, I think, in Government developing a scheme like that. It's certainly a role for the likes of our organisations to help develop that. I think once you establish that baseline or that approach to improving the quality of the countryside for natural resources and nature, then I think, on top of that, you can then start building your more bespoke, prescriptive, partnership-led work.


So, you'd argue as well that that would take away the postcode lottery fear that many have—that unless you live in a certain area where there's a particular habitat that ticks a certain box, then you don't get access to this really.

Absolutely, yes, because this is about—. I'd say we've got a postcode lottery at the moment, the way public funding is being used. The benefits that that delivers to the public are very much down to chance and down to the way farmers and land managers implement it. So, I think, rather than going towards a postcode lottery, I'd say we're actually moving away from one. 

I think, on postcode lottery as well, there is a risk that the economic resilience scheme could become a postcode lottery for the same reasons that are cited for the public goods scheme. It's important that the economic resilience scheme—and I know we're only talking about public goods here—is equally available to all farmers across Wales as well.

And just finally then, in the absence of a definition of 'land manager', what are your views about who should be able to access this? I think I know, but I wanted to—

I think we're getting to a point now where we're looking at rural land managers and as we develop that, then we will—

As I was going to say, as we develop that, I think it's a general—

It's a work in progress, but I think it has to be those land managers, farmers, and those who are currently engaged in land management in Wales. I think there's scope to broaden that out because there are a lot of people out there who manage land who aren't registered as farmers, and who manage land that's important for delivering public goods—who manage land that's essential for delivering biodiversity targets.

So, it's not solely active farmers, it's not anybody who owns any land; you see it somewhere in between and that you can come up with some sort of definition of people who are active in terms of managing land, but not necessarily fitting into the official category.

Absolutely, and I think this is a conversation that all stakeholders need to be involved with, because we need to get this right.

Isn't it a real concern though that, at the moment, these are conversations we need to be having—and I fully understand that—when we're defining farmers/land managers, because that's going to be critical to the implementation of any successful schemes, namely the criteria of entry into those schemes and the eligibility, and yet, from the senior levels of Government down to NGOs, no-one can really define 'land manager' in the terms of what these schemes might look like. We are under two years away from this scheme being up and running, and no modelling has been done either on any of these proposals. There seems to be a hell of a lot to have to do in two years to have any real understanding of where we're going to be at the springboard time when we jump into these schemes.

I fully agree with you there and I think there's an important role for Government to start facilitating these conversations and to start bringing stakeholders together in order to have these conversations. But we are, certainly within the RSPB, these are the—. We recognise things like who should be benefiting from public policy? Who should we be supporting as key things going forward. But, as I say, the definition of who—. I think the criteria as to who is defined or who receives it, will be—some of it—shaped by what it is we need public funding to deliver for society.

Thank you, Chair. I have to say that, in terms of land management, in my view, we have to look at urban as well and parks. I've been monitoring an area in Haverfordwest in terms of bird species for eight years now and, as it's matured, we're up to 30 species now, where we started with about 15, so I thought I'd just add that.

But, anyway, in terms of who should be rewarded, which is my question, for biodiversity—and we've already touched on that—what outcomes for biodiversity restoration can be realistically measured? Because if we're saying we're going to reward you, we need to know what it is we're rewarding.


I'm looking to you to talk most about this—

I've just realised I've been talking a lot. 

I've talked about protecting sites quite a lot, and those sites have objectives against which success can be measured, and monitoring of those sites is critical to make sure that, where management in those sites is supported by the public goods scheme, it's delivering. I think, in terms of the wider countryside, Arfon has probably a fuller answer.

I guess the simple answer is—. This is something that I know there have been concerns expressed about—payment for lapwings or payment for something—because there are lots of variables. There's no guarantee that they'll turn up, or they might not be successful. So, what we're advocating is that, I think, probably the majority of cases of habitats' extent and conditions should be a kind of prophecy for species. So, if your criteria for success will be defined by how much habitat you're managing, is it in the right condition, is it joined up enough for species—? This is certainly the way that it looks like a number of the Irish schemes evaluate successful management.

Perhaps the one thing that has dawned on me, and perhaps I'd urge a wee bit of caution with, when looking at the example of the Burren—whether you're familiar with the Burren as an example of a results-based scheme—the Burren is very much habitat based, so it's fairly easy to come up with a stepped approach to achieving desired habitat condition and make payments accordingly, if habitat is your target. Species are a wee bit more challenging because you can get 90 per cent of your habitat right for species, but that 10 per cent might be critical to success, so there is a concern about how we make sure that, in managing habitats, we give farmers every chance of succeeding.

I think this now goes back to provision of advice and guidance and support. It's something that Welsh Government needs to seriously invest in when it comes to these more technical elements of scheme delivery, otherwise that lack of investment will lead to uncertainty about success and ultimately a waste of public money, a waste of opportunities. 

If I can, Chair, if we're talking about rewards and targets, there has to be another side to this as well. I'm going to bring in the application of nitrates in the wrong place, and I'm going to bring in the fact that the rivers in Ceredigion and Pembrokeshire have been badly affected by the application at the wrong time and in the wrong place, and the concerns—I don't know whether you've come across them—that the fines are so limited that it's actually built into the practice on some farms, and I mean some farms. Do you have anything to say about that? Because it's great and I think we should be rewarding. We went to see a farm last week, which was fantastic, but we also have to look at sometimes, sadly, implementation of the opposite. 

I think that's probably the case in all walks of rural life, really. I think there will be bad practice. My understanding of where we are with water quality and the introduction of new regulation is that the implementation of that regulation and the provision of support and advice and guidance I think needs to get to the point of understanding where the die-hards are. Because, I think, based on Scotland and the introduction of general binding rules for water in Scotland, which looked to contain similar elements as to what's on the cards in Wales, with a lot of ongoing support and advice, they moved non-compliance in Scotland, from—. I forget the figures, but it seemed like from 80 per cent non-compliance almost down to a very small amount of non-compliance. And you were able then to identify where the real issues are. But I think the strengths there and what was recognised as the strengths were, again, boots on the ground, working with farmers and landowners, getting them to understand what the issue was and start implementing good practice. And I guess how successful this will be in Wales remains to be seen. I think we're at the start of that particular journey in Wales at the moment. But, I think, where you get to a point where you've still got polluters polluting, despite all the help and support and advice and guidance that's available to them, then there's a question about whether they should be within the industry.


That follows neatly into the area that I wanted to pursue, which is how we ensure that the economic resilience scheme complements the public goods scheme. Because it seems to be a bit pointless to have farm A doing all the right things and farm B allowing soil to be washed into the river. 

A key element of that has got to be that the regulatory floor and the baseline for receiving payments of whatever sort must be about meeting regulations around protecting water quality, for example, as we've discussed. 

Okay. So, the economic resilience scheme has got to ensure that people do the basics that the uninformed Joe Public would expect.  

I think the economic resilience scheme is an exciting proposal and it's a scheme that has to work with the public goods scheme, because I think there is a danger that Wales is seen as food on the flat bits and public goods on the high bits. But on the highest mountains of Wales, you could still produce an element of food. There will be scope for food production on the highest bits of Wales in the way that there is scope for public goods delivery in the most productive bits of Wales. In fact, the biodiversity losses have been most severe within lowland agriculture. And the same is true for lowland Wales. So, helping farmers restore biodiversity within lowland areas of Wales is critical if we are to meet international commitments.

So, the two schemes have to work together. We have to avoid the perversities of the common agricultural policy where we had pillar 2 payments for planting trees, and pillar 1 payments but only if you didn't have any trees in the area. So, farms were actually removing trees in some places and planting trees in other places, which is a complete nonsense and something that future schemes must not repeat.

So, the economic resilience scheme has a really important job to build efficient farming, efficient food production alongside and integrated with successful delivery of public goods.

Okay. Do you agree with NRW, which says that we've got to change the perception that delivering for the environment is contrary to productive agriculture or forestry and that we have to ensure that public goods isn't just a sideline?

Yes, and I think that's a result of a pursuit of productivity over profitability to some extent as well. I think that something that isn't being captured in these conversations. I'm still attending lots of meeting where productivity has been spoken about as opposed to profitable farming or profitable land management. In order to achieve profitable land management, or resilient, sustainable land management, we very much have to consider environmental quality and condition when it comes to land management, and also restoring and maintaining environmental quality and condition as a product of land management, because of all the reasons we've discussed here, but also to retain our ability to produce food. So, looking after the environment makes good sense for society and makes good sense for biodiversity, but it also makes good sense for farming, because if we're not careful, we'll end up in Wales as other parts of the UK, where—in the east of England, they've got 50 years' worth of soil left to do their cropping. And, whilst we're not an arable country, we do have issues with natural resources in Wales: we have soil compaction, we have water quality issues. So, unless we look after our natural resources, look after our environment, we're going to struggle to produce food long term.


Okay. Is there anything you want to add, Annie, before I move on?

I think Natural England's statement that you read out I certainly would agree with. I think that's—. Arfon's put more flesh on the bones of that, but yes.

Okay, fine. So, we now come to the thorny issue of how we're going to achieve this, because obviously organisations like Fairness for the Uplands, they have excellent expertise in how we achieve biodiversity, as do Slade Farm, which we visited last week. These are farmers who are passionate about the environment as well as making a living, but that's not the case for a large number of people who are farming. So, how are we going to get the advisory services to ensure that all people who are using the land understand the biodiversity issues that we can agree we're trying to achieve?

There are numbers of—. We do have advisory services. We have an advisory network out there, and I think there's a—. We're talking about making changes to land managers and farmers here to think about what they do beyond being food producers—and I don't say this in a way that denigrates what they do, because I think the ask now is becoming increasingly challenging for farmers to become farmers that are also land managers in order to produce food and look after the environment and look after nature. We do need—. Therefore, we need a fit-for-purpose advisory service that's also capable of providing advice that is integrated and isn't siloed. I think there is—. There are—. We do have a kind of siloed advisory service at the moment, because it's the product of the common agricultural policy and so on. It's responded to policy and it's responded to where we currently are.

Going forward, I think there is an obvious role for, I think, the likes of the RSPB and other organisations. I'm not touting for business here, but I think, when we're looking to restore and maintain species, you need the right sort of advice and guidance. Some of that's technical stuff, but there's also a role for agriculture advisers. We have—. We've got the Farming and Wildlife Advisory Group Cymru, we've got Farming Connect. We've got an awful lot of advice out there; it's a matter of bringing it together. What we're finding in—. An example, perhaps—again, down at the Gwent Levels, what we're doing there is almost facilitating that role, that advice. Because there is so much advice out there, I think what's required now, in working with farmers, where the ask is, 'You've got to produce food, you've got to look after the environment, we want you to protect these species, we want you to perhaps improve the landscape'—that then becomes a very complex thing. The help is out there, so we've occupied a space there in which our role, or the role of the project, is to pull in the right advice and guidance and package it up in a way that is helpful as opposed to overwhelming. I think that's a key role, going forward, as well, when you're working on these kinds of landscapes—that there's a means, then, of being able to co-ordinate and facilitate.

What's the conversation you'd have with pheasant farmers?

As in, well, people who are producing pheasants for shooting.

Well, if it's being done in a way that's sustainable, it's not having an impact on the environment, it's being run in a legal fashion, then, you know—.

Okay, fine. So, in terms of who should provide these advisory services, going back to the question that Llyr Gruffydd asked, which is 'Does NRW have the resources?', which we can leave open, that question—I mean, do you think that—? Clearly, there are organisations like yourselves who have great expertise in specific areas, but how do you envisage all these advisory services working together?


Do you want me to kick off, or do you want to—?

Yes. Well, from the strategic end, I suppose, there will be roles for different groups within the spectrum of opportunities and priorities. So, the area statements might highlight some specific areas for habitat restoration, species recovery, and delivering site condition, for example. Within that, NRW is clearly the organisation to advise on some of that; protected sites are theirs to look after. I think, then, looking at those species population issues and that sort of thing, that's where some of the organisations with expertise like us come in. 

So, the key issue is: how are we going to enforce the polluter-pays principles? You talk about establishing a regulatory baseline, but it does actually require people to be able to access the land to ensure—

Absolutely. That requires an investment in officers on the ground or investment in a means of doing this. I mean, it doesn't have to be people; there's all sorts of ways we're monitoring compliance, but it does need the resources to do it. But I think there's also—. If we are going back to the Scottish example, when it comes to water quality, if we're providing that kind of advice and guidance and support, then you're reducing the scale of the issue. It then allows you to take more of a risk-based approach to monitoring. You can then start identifying those areas that you really need to perhaps target in monitoring as well. 

Sorry, but we're coming very close to the end of the time. Can I move on to Andrew Davies? 

Yes. Thank you, Chair. Obviously, the key to this, and you touched on it a little earlier, Arfon, is to be able to monitor the success of any schemes. I appreciate that's almost difficult to answer here today, given that we know little or no modelling's been done of the proposals within 'Brexit and our land'. It's a difficult one to nail down who'll be eligible for the schemes as well, but you did cite in your earlier evidence a lack of mobility to measure success in Tir Gofal and Glastir in particular. If you were to think forward about packing the schemes out so that people could be monitoring the evolution of these schemes, how would both of you, maybe, have an opinion on how that monitoring might be constructed so that we can measure the success of the money going in and the outcomes coming out? 

On that, then, I think there's—. We do have a particular concern, and an ongoing concern, when it comes to monitoring of—. It was Glastir and the Glastir monitoring and evaluation programme, which has now been rolled into the environment and rural affairs monitoring and modelling programme—so, the ecosystem approach for, you know, monitoring ecosystem change—which, I guess, will be the monitoring package that Welsh Government will be using to monitor future land management programmes. Our concern is that the GMEP current approach to monitoring relies on things like the farmland bird index. They rely on indexes. Indexes, the way they work, they're based on distributions of birds that are plentiful enough to pick up in a random monitoring approach. So, past monitoring has been based on surveys that look at populations of common birds, and the problem there is the birds that Glastir was looking to benefit are far from common and they don't even fall in—. They're not even captured by the monitoring packages that were informing Glastir and are currently informing ERAMMP. In fact, as birds become scarcer, they fall out of the indexes, so they're not being picked up at all. So, the concern we've got—and we've raised it repeatedly with Government and those delivering the package—is that—. To us, it's a very basic thing. If you're investing public money into schemes that are meant to benefit curlew or black grouse or golden plover, then you should be able to evaluate that. You should be able to assess the impact of those actions. We don't have that ability at the moment; we didn't under Glastir, and we don't under ERAMMP. We did under Tir Gofal. So, it is possible, and there's a paper been published recently that explains how Tir Gofal worked, the fact that it was able to monitor for species and that this needs to be picked up in future monitoring packages.


Can I add one final point? It's just to say that Wales Environment Link would like to see our statutory framework enhanced by a framework of targets and appropriate measures that look at what we need to deliver to restore biodiversity, so looking at the recovery of species, but potentially the extent of good quality habitat on land and in our seas, the extent of area that's protected for nature and so on. And, within that wider framework, which would form part of the success measures for our wider delivery, I think the public goods scheme could identify its specific role in delivery. So, I just want to leave you with that thought.

If I may, just one further point just on the monitoring—and I'm stressing this because it is an important point—in 'State of Birds in Wales 2018', there is a graph on page 10 that shows the current farmland bird index, and it shows basically a downward trend. There are wriggles in it; it's a bit like the difference between weather and climate change—you know, we have hot years, we have cold years, but climate change moves in a certain direction. I think that GMEP picked—when GMEP reported on Glastir, it picked up an upturn in the farmland bird index, but it's an upturn in a kind of downward trend. So, it was probably a good year; I think we probably had lots of wood pigeons that year. It is as simple as that. So, basing the state of birds in Wales on the farmland bird index is fraught with problems, and certainly putting a kind of cross at one point on that graph and saying, 'Oh, things are okay, because they're going up' is ignoring the fact that there's this onward downward trend. And basically farmland birds, unless we do something soon, they're going to be disappearing. A lot of these things will actually become extinct in Wales.

Can I thank you very much? Opening up a panel on birds, we could probably talk for another hour on that, but unfortunately time has beaten us. But can I thank you both very much for coming along? I certainly found it very illuminating, and I'm sure the rest of the committee have, so thank you.

Okay. Diolch yn fawr. Thank you very much.

Thanks very much. Diolch.

3. Trafod Bioamrywiaeth – Cynllun Nwyddau Cyhoeddus: sesiwn dystiolaeth gyda chynrychiolwyr rheolwyr tir a defnyddwyr tir
3. Consideration of Biodiversity - Public Goods Scheme: evidence session with representatives of land managers and users

We now move into our second evidence session. First of all, can I welcome Anthony Geddes, national manager for Wales Confor, Rachel Lewis-Davies, environment/rural affairs adviser, National Farmers Union Cymru, and Charlotte Priddy, policy officer, Farmers Union of Wales? Can I thank you very much for coming along and apologise that we are starting a few minutes late? If it's okay with you, can we go straight into questions?

If I can start, what are the gaps or limitations in the existing legislation and policy that could be addressed through the proposed public goods scheme to improve biodiversity restoration in Wales?

Do you want me to—?

Go on, yes.

I would say it's first of all important to consider the context in which measures to improve biodiversity or policy measures to improve biodiversity will be taken, and that is in the proposed future public goods scheme. And in that sphere, it's important to remember that that takes place in the context of the well-being of future generations Act and also the Environment Act. So, I guess, from our perspective, we see the policy as important in driving improvements in biodiversity but also in a range of other measures as well. So, it needs to deliver economic resilience, environmental resilience, social and cultural outcomes, and it's in that context that I think the biodiversity measure needs to be considered.

Yes, so we'd agree with Rachel there. I appreciate this is an evidence session on biodiversity and public goods, obviously, but it does seem a very one-dimensional approach. So, the public goods scheme in itself seems quite one-dimensional, and then to look through the lens of biodiversity seems to narrow it down even further, which, I think, is a step away from the well-being of future generations Act, which implements this holistic view of looking at things.


I think the opportunity in the creation of the public goods scheme—as Rachel was saying, it's the potential to bridge gaps between what may not be considered economically viable or sustainable at the moment, in producing support for diversification, which may be other land uses that would previously have struggled to be pertinent or affordable.

I think I would add to that that it's important to recognise—I've already touched on economic resilience—but actually, in a farming context, that economic resilience is really, really important if we're to achieve environmental resilience. So, as a farmer, we know we spend more on environmental outcomes, we do more investment in environmental work on our farms when we're profitable. So, I think that's a basic fact that needs to be considered.

Thank you. What are your views on the delay of area statements from the end of this year to March next year?

Well, I received an update at the Wales land management forum on the area statements, and I think it's fair to say, from a farming perspective, that some of the language and some of the outputs of the environment Act—so, SoNaRR right through to the natural policy, but in particular, the area statements, they're quite abstract to farmers. I think farmers are very keen to understand what will the area statements do. How will they influence policy? Yesterday, there were conversations about maps that are being developed for different outcomes, and NRW frame those maps as discussion tools. But, actually, if they're decision tools, if you're the wrong side, if you're in a white area on the map instead of, you know, you will end up with a postcode lottery and the haves and the have-nots.

So, with the area statements, I think they can be important, but they have to recognise that the key delivery partner—I think policy needs to recognise—to deliver environmental outcomes, whether they be for decarbonisation, whether they be for biodiversity, your key delivery partner are the people who manage 80 per cent of the land area of Wales—farmers. So, actually, farmers need to be really involved in the development of those area statements; they need to be on the basis of a shared vision, not one that's imposed.

Certainly, I would say it's somewhat of a double-edged sword. We're going through a significant change, we'll see the loss of CAP and BPS for farming support. Such is the size and substance of that change, the delay of a move to area statements may be one too many changes in a raft of many changes—yet another disruption at the end of restructuring of income for farmers.

I would also say that it does give the opportunity for some good consultancy and some good engagement, and that engagement is key, critical, to getting land managers—be they farmers, be they foresters, be they estate owners—on side.

Yes, I would just completely agree that there's so much still unknown for the actual deliverers, the farmers on the ground, about area statements that, I think that, given everything else—all the unknowns that are going on at the moment—it's really beneficial in this case to have this delay, to think things through very carefully and to actually engage farmers on what the best way forward is.

Just to very briefly touch on the point you made, Rachel, about being developed with farmers as opposed to being imposed. Do you feel the journey to date has been a journey of imposition, or do you think they are genuinely developing these statements with farmers and the delay will benefit that development?

I think we've called quite clearly for—. We know the area statements—there are going to be seven across Wales, and for each of those area statements, what we'd be asking for is a local development, or a local engagement plan, by which NRW, who are responsible for developing those area statements, actually go out and reach out to the people who are actually managing the land.

I think there's this idea that because this cuts across to the public services boards, that that, actually, could fulfil that role. I don't believe that fulfils the role at all for the private sector, and in particular, farmers who, at the end of the day, will be delivering the ambition of those area statements, if it's a shared vision. I think it really has to be based on a shared vision, and I think farmers will be seeking reassurances that that area statement, to the extent to which that influences future policy, because we don't want to end up with a scenario of haves and have-nots in the future public goods policy. Actually, every farmer in Wales already is delivering public goods—every farmer in Wales. And the first point for me is, actually, let's understand what those public goods are and seek to value those before we end up just focusing on certain public goods in certain areas and adding a lot of complexity and an element of uncertainty into the future scheme that is there intended to provide resilience and stability to farmers.


Thanks, Chair. The public goods scheme aims to restore biodiversity, but if it's going to be effective, it's going to require significant funding. What are your thoughts on how this funding could be raised, apart from public funding? Could money be raised from other sectors such as tourism, water and flooding? I wondered what your thoughts were.

If I may answer that, the first point I would make is that the public goods scheme is going to deliver outcomes across a range of multiple outcomes. So, biodiversity is just one of them, going back to my earlier point.

Moving on to a point around the budget, I think first of all, we would say that we've heard that Wales must not receive a penny less, so there's that wanting to secure the same level of funds as we exit Europe, and I think, by that, we need to be absolutely clear what we mean. So, we mean the total of the pillar 1 budget and we mean the total of the pillar 2 budget. And that also includes that element of domestic co-financing. So, I think that's the first starting point of the resources, when we say, 'Not a penny less'—that's what we'll be looking for.

Turning to your specific question about others paying for the delivery of biodiversity outcomes, I think farmers are very receptive to the idea if you want to go into the sphere of payment for ecosystem services, I think it's an area that farmers are broadly receptive to. However, this has been a long time in discussion, hasn't it, and we've not seen it mature into any real plausible alternative income stream to date. So, how you mature that I'm not sure—that market.

I think, building on that, my answer personally would be, 'absolutely'. If it's a genuine public good, then it needs to be paid for and delivered nationally, whether that be through water industry boards, or whether that be through industry recharge themes for payment for doing bad, improvement for doing better. Where we have seen this work in forestry is, to a certain extent, through carbon schemes, through carbon crediting schemes and the woodland carbon code. That's an interesting subject; it's not necessarily an effective replacement for Glastir, it's not sufficient to support woodland creation and management, ongoing, but you've got the roots of a scheme there. We know it can work; we would like to see it work better.

If we don't do it better—. This is the sort of question that we've been debating for the last decade, so it's an ongoing issue and in our consultation response, we actually put that there is a need for a policy reform group to really look at this in immense detail. 

And just another issue here with resourcing is costs. The establishment of public goods is a monumental task. We've got a value for carbon—I think it's about £15 per tonne—but, for example, are you going to go through every species in Wales and give a value to it? That's going to be a really monumental task and it is—. Is a curlew, for example, in north Wales, worth the same as one in the Brecon Beacons? And, the English values versus the Welsh values versus the Scottish values; I can't emphasise enough how big the job is there.

Diolch.  In terms of the public goods scheme and the way that it will operate, do you think there should be an element that rewards historical good conservation management prior to the scheme coming into place?

Absolutely, yes. From our perspective, as I've said already, every farmer in Wales is delivering public goods already, and the starting point needs to be to identify and place a value on those public goods. Otherwise, we end up with a perverse outcome, really, where we've got trees growing that are providing a home for nature, they're sequestering carbon, they're delivering that landscape good, all these public goods that we say are important, but if they're not established under a future scheme, they receive no value, and that to me is perverse. Also, that question around additionality—you need to consider our designated sites, where they are effectively in the sphere of regulation, so we could end up with the perverse outcome that, because the management of those sites is supposed to be delivered as part of regulation, you can't achieve adequate payment above, because of the additionality rule. So, I think the additionality principle within proposals is really, really difficult, and one that really, really needs addressing. Because there will undoubtedly be these types of perverse outcomes if they're not addressed.


And I think I would reiterate that. If you want a public good to start today, you need to ensure that people who are proactive enough to engage want to drive this forwards in the lull that we are going to experience over the next five years during transition. You will need to look retrospectively to support those people to ensure that the gate is not just shut. There's a very genuine risk.

We could end up with a scenario where people who've really embraced this agenda in the farming community, have been in agri-environment schemes for over 25 years and have done a lot of the public goods delivery that we are trying now to get others to engage in—we could end up with the perverse outcome that they are rewarded the least, and I think there is some perversity in that, because if it's a public good and it's being delivered, it should be valued. I think that should be the basic principle.

It's maintaining the momentum.

Would you have any specific ideas, then, on how that good conservation management on a pre-existing basis might be rewarded?

To step back from that a little bit, I think it's so important to really engage with farmers, who've built up all this knowledge and expertise, and to actually engage with them about how they think it's best to restore biodiversity, for example, on their land. I think so often these decisions are made at a higher level and it's actually to engage the farmer and to work with them.

And I would add to that, in response to your question, I go back to the point: public goods are being delivered on Welsh farms already. What we're actually trying to do is put a value on what we've never valued before, and that to me sounds like quite a good place to start. So, actually, there's a farming system; what public goods is it delivering that are of value to society now in the current sphere, rather than trying to go off and develop—? There is a space for the bespoke, complex contracts I think will need to be developed for certain species, for example, curlew, because it's come up today already. But actually, it's securing that baseline first of all. So, securing the continuation of the delivery of that baseline of public goods, because if they're not paid for, there's no guarantee that they will continue to flow in the context of the challenges brought about by Brexit. So, I think establishing that baseline and trying to seek to value that would be a good start, and a logical place to start, and actually, what we're talking about here are basic human behaviours, aren't we? We're trying to engage with an industry and get them to engage in the agenda of biodiversity restoration, but actually, if farmers had a clear understanding about what is meant by public goods—this is a whole new vocabulary to farmers, let's be honest. Understanding, 'Oh, there are the public goods that I'm delivering on my farm, and that's the value for it, if I continue to deliver it and enhance it', seems a logical place to start for me, and if you do that at a baseline level for all farmers in Wales, then you're securing sustainable agricultural systems on every farm in Wales, which is ultimately what we need—not areas of food production, or areas of biodiversity delivery. We're trying to achieve sustainable agricultural systems.

I think the most substantial challenge that comes out of this is that almost a snapshot approach is great, but I've seen you touch on this earlier today—there is a question of resource or capacity or knowledge in order to do this, and I think there is an opportunity to look externally at what we have as an existing measure, to engage with sources like Crop Health and Protection, Innovate, the Department for Environment, Food and Rural Affairs—bodies who are looking at measurement of the environment for other reasons. If you want to deliver this, you need to be very certain about what you're measuring, and you need to be very clear about the baseline that you're starting from, which I think just reiterates what Rachel's saying. 


Can I just take that conversation a little further? Being a farmer myself, what goes on in my farm is quite different from, maybe, parks—and Joyce was talking about it earlier on—and there's this conflict, almost, I'd see between a farmer and a land manager when you're trying to establish the public goods element, because what you might be developing on—an industrial complex that's got a lot of land around it, or parkland that might be part of the municipality in that area—it's quite different from what the farmer's done, then. So, how do you define what are public goods in quite different arenas? 

I think that you've touched on a really important point, and I'm not sure whether I'm going to be answering directly your question when I say what we are keen to see is defining those public goods and linked to agricultural activity. I think, throughout the 'Brexit and our land' consultation, that's an area that hasn't been well explored. But certainly, if you look to Europe and what they're looking to do with eco schemes, they're very much linking and recognising the intrinsic links between that agricultural activity and the continued delivery of those public goods. So, I think when you enter into that sphere, in a way, you solve lots of problems. So, we know—I think it's well established—that the tenanted sector is particularly vulnerable through reform proposals, because who will have the public goods payment? Can a tenant farmer enter into a public goods agreement, where it could ultimately see a devaluation of the land price? Is a landlord going to allow that to happen? Ultimately, well, if the landowner can secure the payment, why should the tenant?

We're going into realms of huge complexity for tenant farmers, and I think the tenanted land extends to about 25 per cent of—. It's a significant extent, so it is a really important consideration. But I think if you move public goods delivery and the public goods we are wanting to see on Welsh farms into that sphere of public goods linked to agricultural activity, then that becomes a much clearer focus and, like I say, would help to address the question you're posing, I think. 

Just to add to Rachel there, Europe, as they're developing their new CAP going forward, are really strengthening the active farmer rule, and it does seem in the 'Brexit and our land' paper that Wales is stepping further away from the 'active farmer' that— 

Yes, and I think the consultation is clear on that in all the narrative that has built up around 'land manager', and so on and so forth. What it's not clear on at all is to what extent does that benefit who and why. What's the outcome of that change going to be—that fundamental shift? Does it deliver more for the economy of Wales? Does it deliver more for the environment of Wales? Does it deliver stronger social and cultural outcomes? I would want to see the evidence that it does before we embark on such a significant shift, I think.  

We're told that all these questions are going to be answered before the Royal Welsh, so we'll wait and see. [Laughter.] Just to add another layer of complexity, then, we're interested in your views about at what scale you think the public goods scheme could reasonably operate. 

Well, of course, if you take my suggestion of a baseline public goods scheme for all farmers in Wales, what we've achieved is a national approach, haven't we? The ambition needs to be sustainable agricultural systems, wherever they're located. I know there's lots of discussion around farmers collaborating and about operating at landscape or catchment, or different scales. What I would say, for farmers at the grass roots, that is not without its complexity. So, through Glastir commons, a lot of time and effort has been invested into achieving that collaboration for Glastir commons agreements, but it's not without its complexity.

I guess, for us, we would be very, very concerned if that collaboration and achieving that was a prerequisite for entering the public goods scheme. So, there are two extremes there.  

Yes. That said, our inquiry is focusing particularly on biodiversity, so, within that biodiversity context, mindful that it's one element, if your priority in terms of delivering a public good was around biodiversity, then—. Because the impression—well, not the impression—it's clear from the previous evidence that we had earlier today you need that sort of bespoke approach on an individual farm basis that somehow then comes together on a habitat scale or a catchment scale level. And that's not an easy thing to achieve, in terms of that it needs to be big enough to have that sort of wider effect, but it needs to be small enough in order to deliver a coherence and a co-operation that's practical in terms of those partners that are involved in making up that larger area. 


Two quick points there. The first one is: is that not species specific?

So, again, is that a level of complexity that we want to enter into, or is that baseline sustainable agriculture everywhere, where we really focus on habitat connectivity, resilience and that type of thing across a landscape? Is that where we want to be? And the second point I would make is, ultimately, we deliver nothing if we don't get our delivery partners, our farmers, or land managers on the ground, engaged in this. So, to get them engaged, it needs to be really, really—. It needs to be something that appeals. It needs to reduce every barrier possible, and, as I've said, collaboration might be a step too far in terms of presenting a barrier. We need to be reducing complexity so that it's an easy process. 

Let's just look at it from the other end of the prism, then. There could be a huge positive here in terms of a big cultural shift, because, currently, farmers are being told what to deliver, and they have to measure the length of the grass and everything. There's an opportunity here for farmers to take back control. I'm sure Andrew's smiling when I say that. [Laughter.] And there's a big learning curve there—I understand that—for land managers and farmers to understand actually why they're being asked to do this and not just delivering what they're being told to deliver. So, there's a huge opportunity there as well in terms of empowering those farmers to take control of what they're delivering. 

Effectively, we could end up—. We've seen the start of the transition. I think what we've got in Glastir—and Charlotte will vouch for this—is a hugely prescriptive, inflexible, complex thing to engage with, and farmers are falling foul of that complexity. What we've seen through pilot approaches like the SMS—the rural development programme-funded sustainable management scheme—is a position where farmers have shifted from being scheme participants to scheme designers. What I would suggest is that it's far too early to say, 'Take away your pillar 1 and your pillar 2, and you just have that.' It's far too early to say whether that can achieve the goal of economic, environmental, social and cultural resilience that we're looking for. And, actually, I think what hasn't come through—and we've touched on resourcing—is the transaction costs of these schemes. Because we can build in and engineer an awful lot of cost, and ultimately, if you build in that cost, all you're not doing is not delivering on the ground, because, ultimately, if you're a farmer—I'm sure it's the same for a forester—they will measure success on, 'Actually, what has that investment bought me?' and they will be wanting to see something. 

Picking up on that, there's a couple of really important points in there. If it's to be focused challenges that are categorically rolled out across Wales, then I think you're going to struggle to identify those clearly and to deliver those clearly, but what I would say is, within that end of the conversation, there's so much more that needs to be done on education. A farmer will know his land, and will know intimately what happens on his land, but he may not know how that interconnects to the national requirement, the national scale, the desire for things to happen. So, there's a big focus that needs to be upon education and delivery—why should we do this.

The second point I would move onto is, actually, it depends on the scale that you want to deliver this. We talk about public good, we talk about Wales, so we talk about national. And, arguably, you could start delivering public good on a garden-by-garden basis. Simply, you could. I suppose where I look at it from our forestry end is there are different ways, there are different opportunities, there have been different successes, and it may, within small management schemes, in five hectare woodlands, be grant support to help you do things with your wood, but a land manager will gift their time because it's their hobby. Give them the tools to create extra biodiversity corridors or to fence or to support, or to allow regeneration, on a farm level that's long-term management support. So, you're looking at deploying these tools in different ways. And if you're going to do that, and if public good is going to be deployed at more than a farm level, then you need to ensure that you've got the pot to do it, because it's going to be one hell of a pot, without disrupting farm business, but you've got to make it tangible, you've got to make it actionable and you've got to make it worth while.


It's likely or there may be a situation where it's going to be a mix of all of those really, isn't it—you're going to have a little bit of this, and a little bit of that, according to what the circumstances allow. But in that context, there's a danger—and I know you've raised this previously—of a postcode lottery, where there are clear winners and losers, and where some benefit disproportionately compared to others. So, I'm just wondering if you could talk to that a little bit, but being mindful as well of the possibility that there will be a baseline that everybody needs to meet, so everybody will receive, potentially, some kind of support to deliver something that mirrors cross-compliance, or whatever. So, doesn't that negate any fears of this postcode lottery, potentially?

No, it doesn't negate any fears of a postcode lottery. Together with things like the area statements, the FUW have had a real concern—I see what they want to achieve, but there are still concerns there for this opportunity of a postcode lottery. Obviously, if it was a whole-farm—. If every farm in Wales could engage with this public goods scheme—fantastic. And then perhaps if there's an advanced scheme, and the catchment level—. And if you want to maybe engage on a part-farm, it needs to be flexible enough that you can engage at whatever level, in whatever way you'd like to. But, should you be in a national park, for example, and you have a whole wealth of public goods that you're able to tap into, and then perhaps if you're farming elsewhere and you haven't got these goods—. So, you're instantly making a bias towards those in this priority area, essentially, and I know area statements are going to look at priority areas. But in creating priority areas, you're also creating inadvertently these non-priority areas.

Isn't that inevitable, though, in a sense? If you're looking at habitats and carbon capture, not everybody can do all of that—or parts of that.

Can I just come in there? What I would say is, if you look at the environment Act, that seeks to achieve sustainable management of natural resources. So, that doesn't say, 'the sustainable management of natural resources here, but that's less important there'. So, I think that underlying principle—that's why I keep going back to sustainable agricultural systems, in whatever sector, whatever scale, wherever they're located in Wales—needs to be the ambition. Now, of course, when you're talking about biodiversity, there will be areas—. You know, this is very species specific, but actually it also provides connectivity, habitat. The perception could arise that, actually, one element of the public goods is for the uplands and not the lowlands, but it needs to speak to all farmers in Wales because all have the potential or are delivering public goods, I think. So, I think we need to be very careful that we don't end up with a future land management scheme with two elements—one of economic resilience and one of public goods—that sees Wales, effectively, carved into areas of production of agriculture and areas of public goods production. I think that would not be aligned with what the environment Act tells us.

I think, jumping in on that, also there is a bigger challenge in this—that we are maybe slightly blinkered. We only know what we can measure now. We have this challenge. Ten years ago, if you talked to someone about gut health, they would have stared at you very blankly. I can talk to you today about mycorrhizal systems in forests, and you'll go, 'Pardon?' We are setting out to measure only what we know exists as good practice today. Where we really run into a shortfall, and a short-termism view, is if this scheme does not develop what public good is. That piece of open land may today not deliver public good, but actually, as we learn how this works and how we understand it, it may be one of the most subterraneously biodiverse things that we own. So, I for one am actually very scared that we are entering into something that we don't have a full appreciation of. And that's not a criticism; it's a good starting point. But we've got to have a very open mind about what this is going to develop into and how this may change over the next 10 years.


Building in that flexibility to evolve over time is key, which, again, adds further complexity, but I think, yes, is very important—

But there are some inherent risks, that in—. We've not seen a definition or the extent of what public goods are going to be included. We've not seen the outcomes or the proxy measures that they're seeking to achieve. We've not seen how they're going to be valued. But there is a danger—. We've already talked about how complex this is. The inherent risk is that we go for the things that are perhaps easier to measure or that we have the science available for and so the focus shifts from the broad suite that's being delivered now, and the focus shifts to a whole new direction, and the things that are actually very important—because of a lack of understanding or baseline or knowing how to value them, they get left off the list for now because they're in the 'too difficult to do' box.

I can show you a great historic example of this, which is that conifers have been perceived as a very bad thing in Wales—'These horrible blocks of conifer'—but, actually, when you've gone into them, the RSPB have done some fantastic research work that shows that there may be 20 or 30 different varieties of bird living in there that wouldn't otherwise have survived in that environment. So, we've got to be really careful to challenge our historic concepts. You can't say: 'Conifer bad; broadleaf good'. What you can say is: 'Well-designed, well-integrated sustainable land management good'. 

Well, Rachel was listing things that we haven't seen; we haven't either seen a specific definition of what a land manager is and who exactly would be eligible for these schemes. And I know you have a clear view about active farmers, although I'd be interested to hear what you have to say, Anthony. But I'm just wondering—clearly, there's a view that it's active farmers and those people who are taking the financial risk who should be eligible for this support. There's another view that anyone who owns or runs any piece of land potentially has a stake and an interest in this, so they should be equally eligible.

Arfon from the RSPB suggested earlier that there's something probably in between, isn't there, in terms of people who are land managers—not necessarily farmers, but people who have that sort of active role in managing land. I'm just interested to hear where you are on that sort of spectrum. Well, I know where you are—

I think you've answered the question for me. [Laughter.]

Yes. No, but I'm particularly interested in what Confor might have to say on this, really.

Well, I think in terms of Confor, we have to scope out the challenge that there has been for forestry, because the low value of timber, the lack of support, the lack of interest in the sector, has meant that there are significant numbers of woodlands in Wales that are not managed. The gate was shut in the 1990s and no-one's been back there since.

There is a real opportunity to increase land in management—in active management. So, I feel there's an opportunity here to realise the active land manager—now, whether that be the farmer or whether that be the forest owner, I can't clearly say where that line stops and where that size stops, because—

Is it possible to be clinical, that clinical? I suppose you could come up with something, anyway, couldn't you? Yes, sorry, I—.

You certainly—you can come up with things. There have been the Glastir small woodland grants. That's been quite instrumental in helping people to re-engage with areas of land that haven't been used. Now, could that be scaled up to, for instance, co-operative planning grants, co-operative management grants, which say, 'We feel that we're going to get an active management on a larger scale'? It's great with—. Take something as simple as laurel invasion or Himalayan balsam—you can firefight on your land to keep these invasive problems away. Much like squirrel control, you can work really hard, but, if you don't work on a slightly larger scale, I can take all the money in the world, but I can't necessarily deliver an outcome. So, there does—. At some point there needs to be a value indicator that says, 'This is good value for the public pocket—the delivery of this public good.' I'd be very keen to work on how we devise that structure, because there are woodland owners from half an acre to 1,000 acres. There are farm owners, smallholders, me being one of those—four acres; I'm under any scheme size and dimension, really. My feeling is that there needs to be some tangible guidance that comes out of public goods on this. I think there will always be backlash at the point at which you say, 'This is the line in the sand—below this or above this.' But, if you can say, 'Below this, we will not accept an ongoing management support, but there might be a single item of grant funding, but we will accept co-operatives or we will accept groups of land managers working together with a well-designed plan to deliver a well-designed goal and an appropriate goal', then I think that's very important and that would be a really positive outcome. 


If I can just come in there very quickly, the FUW have long emphasised concern with the rewilding movement, and this ties in particularly here. You can imagine the situation where charities or banks, for example, from London, for example, buy a big swathe of area and they are now the landowners. It's such a big concern that, actually, it's again pricing out the farmer. 

There's a danger that you create the business model that allows that to happen. I think I'd go back to my earlier points about very much understanding the extent, so taking that evidence-based approach. We have some evidence that says every £1 invested in farming at the moment delivers £7.40 to rural communities—or spend—and I think if we can't achieve the same through a public goods scheme we have to understand our rural communities will be poorer as a result. So, that's the fundamental point, and we can't afford to be poorer as a result of the introduction of a public goods scheme.

I don't think it's anybody's intention to make people poorer. We've listened to all the evidence, and, with all those things being taken very much on board, I'm sure that we will deliver that. I did note the comment earlier on that we're looking at biodiversity—well, we are, but this is one part of looking at this Bill, and that's where we are today. We've taken evidence before on the definition of land management; it was quite a lively debate with the Minister. So, all those things are being considered. I just wanted to say that. 

In terms of the reward for the improvements in biodiversity, we've already touched on that some schemes have been good and some have not been so good. We're trying to ensure now some fairness within the system. How do you think that we could perhaps arrive at rewarding those people who are adding public good under this system?

So, I think there needs to be an emphasis on work that's already been undertaken and the effort that's already been done. To evade your question slightly, for which I apologise, I think there needs to be an awareness, for example, about predation, migration, for example—you know, unforeseen problems—so that a farmer doesn't end up being penalised, essentially, for something that's completely out of their hands or out of their control. Predation is a real issue for many species and it's a concern that—it just needs to be flexible enough to understand that this is a real problem going on. 

So, you're talking about that shift to outcome focused, results based, and how those outcomes can be valued. I think Charlotte's absolutely right. Particularly in the sphere of biodiversity, what we're doing is bringing in an inherent volatility into the public goods approach, which is there as well to deliver stability. So, we need to be mindful of that, because there will be many factors, as Charlotte said, beyond the farmer's control that will influence whether that result is achieved, not least what date does the inspector turn up to check what's there, and what sort of spring has it been—you know, very practical considerations. There could be a huge amount of stress on farmers around the delivery, so there is that volatility in that approach. But I think also—very little information has been provided on the methodology by which public goods outcomes are going to be valued, other than what we are told is, 'It will move beyond costs incurred/income forgone calculations', and that is a fact as set out in the Welsh Government myth buster. I'm not an expert in this area, but the extent to which that actually is fact and which it will be governed by World Trade Organization rules I think has yet to play out, but certainly a move beyond costs incurred/income forgone calculations to reward farmers properly for the public goods schemes they are delivering I think would be a positive step. It's just whether, ultimately, that will be allowed. I think there's a huge question mark there still.


Yes, and I think the question of reward—it's a very difficult word; it's a very emotive subject. The reward, surely, is that you've got continued support under this scheme so that, if you have a setback, if you have a difficult summer where 50,000 trees die due to drought—you know, it's a factor outside your control, and we've seen it this year.

But I think there's actually a fundamental thing in here as well that is about recognition of what people are doing and what people are delivering. I don't necessarily mean, to be slightly flippant, they get a gold star on the board, but this recognition that what someone's life's work is turning into is improvement of our nation means that we need to stand by them when the scheme starts, as the scheme runs and as the scheme continues. This short-termism, measurement of result and outcome, has to move on to longer term assessment, and whether that will be through the person coming through the farm gate—actually, I don't believe that. NRW are already working on mensuration schemes. They currently inspect less than 20 per cent of schemes at year 5 for restocking. The work they're doing with Aberystwyth uni on mensuration and digital tracking means that they'll be able to check 100 per cent of that in five years' time. So, the technology will move on, and, as the technology moves on, we may see a dip in what we think we've been measuring. Don't jump to chastise—jump to support and to provide long-term support and long-term education, because, if someone's getting it wrong, I guarantee they're not getting it wrong on purpose. 

I think that takes us back full square to the education, to the support and all of that. And, with all that—with other schemes, those things have been in place, although we've heard evidence that they've been better in place in some areas than in others, and for some people than others. So, that will certainly be something we will feed back.

But I suppose, when we're trying to look at public good and biodiversity, we are trying to help those land managers, farmers, whoever they are, to increase the biodiversity and sustainability—which I'm sure everybody's signed up to—in situ. So, that being the case, how would we measure that and what would it look like? And is it the case—? Because we've talked about piecemeal legislation, delivering certain targets in certain areas, but we did talk about these area maps, so that we can measure biodiversity within a given zone. So, how is it that we could measure it? And what do you see biodiversity looking like—enhanced biodiversity?

I think this is a hugely complex area, how do you measure outcome, and I think the work—. Certainly, the little bit of research I've done in this area is, if you look at outcome-based or results-based schemes, which have been operational in Europe for some time—. You know, it's not new, but what is new is that they tend to be for the payment of one outcome or a single biodiversity outcome—or it could be an outcome for water. That's what they tend to be. They tend to—. Farmers tend to like them. They do. Because there's a clear signal there—payment on results sort of thing. So, they tend to like them. But what we're trying to do here, from what I can read from proposals, is add huge complexity into this, because what we're trying to deliver is multiple outcomes, and farmers currently who are engaged in those results-based schemes, like the Burren project—that's taken 10 years to get to where it is in Ireland. So, it's taken a long lead-in time to get to where it is, and they're very positive around that now and they are delivering outcomes there for biodiversity, but they're still continuing to receive their direct support, as that sort of baseline resilience thing. So, what we're asking this new scheme to do is to operate in quite a different context, and we don't know. I don't think there is an example anywhere of just a purely results-based scheme, delivering multiple outcomes, for values that we've not yet determined, for outcomes that we've not learnt to measure yet. We're in very unchartered territory.


And this is part of the concern that we've had all along with the public goods scheme: how on earth is this going to be measured and recorded? This is a real concern, I think, for both unions—how is this going to actually pan out?

I think we can embrace—. We can begin this road to transition. But, you know, I'll touch on Glastir now, and the Minister's announcement to extend some of those Glastir contracts to 2021. When you look at the scale of the task in front of us, to get something like this up, operational, piloted, and to understand impact—we can't afford for this to go wrong. To do that in the time frame that we have, to me, seems hugely, hugely, hugely ambitious in the context of everything else that we're going to be faced with. We don't know where negotiations are going. There's a huge amount of complexity and uncertainty out there, and this is a massive—. Do not underestimate the scale of the challenge, is what I would say, because it is untested—it has not been done anywhere. Results-based schemes have been, but operating in a very different context.

And on top of that, at a time when BPS is, in theory, wedi bennu, no more, this is such a dangerous time. It's a volatile time, and this huge transition at a really uncertain time just seems extra alarming.

I think, to push that back, maybe initially what we need to look at is not measuring results, because as we pointed out we're not sure what those results are going to be. What we do have a fairly good handle on at the moment is what might be best practice, so what constitutes farming well, what constitutes forestry management of a good quality. There is excellence out there that we see delivered and recognised and rewarded. So, I suppose my take on this is more—initially, you need to move away from results-based, because there'll be spikes, there'll be dips, there'll be changes. It may take us 10 years to come off the bottom of the bell curve for declining species. But if you encourage people to do the right thing, to farm in a sustainable, high-quality way, you will start to get those results, even if you can't quite measure them yet. That's certainly our hope. All we've got at the moment is our hope.

Yes, so I would add, going back to that earlier point about that baseline public good that everybody, all farmers, are delivering—that would get you sustainable agriculture across Wales. On top of that, there is the scope for that additional tier, where actually you could be exploring a results-based approach for the curlew, for certain outcomes for biodiversity that you're wanting, and that's operating in a far safer space than pushing everybody off a cliff at 2021.

Just one point I feel I need to say on the transition: I think the GMEP work—you know, we've looked at that, but the GMEP work does talk about how that long-term commitment to outcomes is needed if we're going to deliver, and I think the prospect of a lot of agri-environment schemes ending at 2021—some of those have been involved in agri-environment for 20, 25 years—I think that, to me, would be disappointing, if there's nothing to take its place. We wouldn't want to see that cliff edge, that gap, in terms of delivering environmental outcomes, as well as for the resilience of those businesses. 


I think, to give an example of that, you only need to look at the lack of planting in Wales due to the lack of Glastir that has been missing for forestry in the last 18 months—and I'm advised that's not going to be until December now, this year coming—there's a gap in forestry, and, as a result, the planting figures have just gone down and down and down, and you're not achieving what you want to achieve. It's a public policy. 

Thank you. I wanted to look at the relationship between the economic resilience scheme and the public goods scheme. So, would you agree that the economic resilience scheme needs to underpin the public goods scheme, in the sense that we would expect a minimum level of respect for the environment for anybody in receipt of the economic resilience scheme?

I think, firstly, I would say economic resilience measures as they're currently described—I mean, I don't know what will come in July—but measures in terms of investment in farm infrastructure and things like that actually will deliver for the environment as well. So, if a farmer is investing—as we're seeing through the sustainable production grant currently—£40 million-worth of investment is what farmers want to invest on water quality on Welsh farms. That was the total value of the bids. It's an investment in infrastructure that will improve both their economic and their environmental performance and will deliver. So, what I would see is actually being portrayed at the moment as operating in two very different spheres, and what we need is far greater integration, or else we'll end up with that scenario where we have areas of production and food and one set of advice for that, and we'll end up with areas of public goods production and one set of advice for that, and never the twain will meet, and I think that's not what any of us want to achieve.

Right, I don't think that's what we would envisage at all. But do you accept the polluter-pays principles—that those who allow the soil to be washed away into the rivers or who pollute the waters that we all—? You know, it's a public good—. Clearly, they shouldn't be in receipt of the economic resilience payments if they're not going to bear these important issues in mind. So, the most basic level.

So, what you're talking about is the gateway into schemes, and I think the consultation is clear that the gateway into schemes is that regulatory baseline. Now, where that regulatory baseline will sit is going to need to be the focus of considerable work. What I would say is what we want is a regulatory baseline that removes costs and complexity—hugely complex landscape in terms of regulation—so that it's clear and easy to understand, but, ultimately, delivers outcomes and not process. 

Okay, but everybody can understand the importance of conserving the soil—

Absolutely, and I can understand that—

—but I think what we would need—. What we need is we need far more engagement about where that baseline sits and that it has to be in a sensible place, because I think that's where the next, sort of, debate is going to take us, and if the baseline is up here, then there's very little scope to do anything over and above that. So, I think the crux of the matter is: where will that baseline sit? And that's going to be a fairly contentious area. But in terms of that principle of it being the gateway, I can understand why it would be the gateway, but if you end up with a very draconian regulatory baseline that is very prescriptive and is about process and ticking boxes and things like that, then that's going to inhibit—

We're not suggesting that. I'm just trying to establish some principles that you understand—

Yes, absolutely. 

—and that your members understand, that, clearly, if we're going to be providing particular businesses—in this case, farmers—with financial support, there's going to have to be a baseline of adherence to the environment Act. 

And I think they understand that. I think it's how that is framed so that it works for farming. Because, as I say, if it goes back to the very process-driven—

That's fine, that's good.

We just agree on the principles. Is that right? Would the FUW agree on that? Excellent. Right. So, moving on from that, how do you think that advisory services should be designed to enable all land managers to engage with this? And it will be at different levels, depending on where they are and what they're doing at the moment. I'm particularly interested in how we support tenant farmers who want to do the right thing, who may have landlords who have no interest in the environment. So, could we just explore how we're going to get over that one, given that we're talking about 25 per cent of the current land managers?


I think advice in that situation will be inadequate to solve the scale of that issue, if I'm honest—

The tenanted farming sector—we need to do something very, very specific to ensure that they can be in receipt of public goods payments. There are significant barriers that are in law currently to them, so I think that will need a different approach.

On the area of advice, and Charlotte will have views on this I'm sure, there are good examples from previous schemes. So, if you take Tir Gofal, that was a good example where there were project managers and advice—you can advise forevermore but, ultimately, it comes down to a word that you used earlier: 'relationships'. It comes down to a trusted relationship with the person that you build up over time to give you that advice. Now, what we don't want to see is a scenario where we've got lots of projects giving lots of advice, lots of advice from different places, and, you know, we've already