Consultation questions

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1 FDF response to the Defra consultation on the future domestic Agriculture Policy in England: Health and Harmony: The Future for Food, Farming and the Environment in a Green Brexit The Food and Drink Federation wants a successful and profitable food and drink industry that contributes effectively to the economy and environment of the United Kingdom. Food and drink should be an important part of the UK Government s approach to industrial strategy and we welcome the recent creation of the Food and Drink Sector Council as an important step forward. Farming for food production is a critical part of this renewed approach. Our consultation response: Consultation questions Reform within CAP Please rank the following ideas for simplification of the current CAP, indicating the three options which are most appealing to you. Please rank your choices by order of preference (from 1 as your most preferred to 3 as your least preferred): (a) Develop further simplified packages, (b) Simplify the application form, (c) Expand the online offer, (d) Reduce evidence requirements in the rest of the scheme (e) Other (please specify) The Food and Drink Federation wants a successful and profitable food and drink industry that contributes effectively to the economy and environment of the United Kingdom. Food and drink should be an important part of the UK Government s approach to industrial strategy and we welcome the recent creation of the Food and Drink Sector Council as an important step forward. Farming for food production is a critical part of this renewed approach. Food and drink manufacturing sits at the heart of the food and drink supply chain, which employs almost four million people and generates over 112 billion of value for the UK economy each year. Sustainable food production should be the key objective of the UK s future food and agriculture policy. Leaving the Common Agricultural Policy (CAP) presents the UK Government and devolved nations with the unique opportunity to consider the needs of the whole farm to fork industry and create a bespoke policy. The UK s 6,800 food and drink manufacturers operate in increasingly open and competitive international markets. This enables them to provide UK shoppers with a great range of products, available at all price points. We know that our sector will only succeed if we continue to have reliable access to adequate supplies of raw materials that are safe, of high quality and competitively priced and it is therefore vital that we do not see any material reduction in the food produced by UK farmers. The UK s food and drink manufacturers are committed customers of UK farmers, purchasing the majority of the country s agricultural output. For example, Weetabix sources the wheat it purchases each year from farmers located within 50 miles of its factory in Burton Latimer, Northamptonshire. However, UK manufacturers will always need to import ingredients for further processing. In many cases, the raw materials cannot be sourced here (spices, oranges) or the domestic capacity is simply not sufficient to meet demand throughout the year. Food and Drink Federation 6 th Floor 10 Bloomsbury Way London WC1A 2SL Tel: +44 (0) Registered office as above. Registered in London with limited liability. Certificate of Incorporation no VAT number: The Food and Drink Federation seeks to ensure that information and guidance it provides are correct but accepts no liability in respect thereof. Such information and guidance are not substitutes for specific legal or other professional advice.

2 A sustainable food and farming policy must consider the entire supply chain, based on resource efficiency and comparative advantage rather than historical patterns of production. Food security and climate change pose the biggest challenges to the future of the UK supply chain. Managing risk and volatility is an important element of this. As a result, for CAP reform to be successful any option selected as a result of this consultation needs to meet the needs of farmers and to create viable farm businesses. During the transition period, it will be helpful to reduce the burden on farmers. There is so much current uncertainty for farming business that the policy must ensure no further disadvantage as we exit the EU. FDF would also support simplification of the process and the introduction of earned recognition to help achieve this. It is also important that UK reform of CAP understands and takes into account the changing European CAP picture to ensure that our farming and food & drink businesses are able to operate competitively on a level playing field with rest of Europe. Any options chosen must have competitiveness as key outcome. An important part of this will be prioritisation of the maintenance and growth of business and trade between the UK and EU post Brexit. Both the UK Government and the EU have expressed a desire to maintain free-trade. To achieve this, we advocate for the maintenance of UK-EU regulatory alignment, to avoid the possibility of trade frictions arising. The UK Government will also need to be clear how its policy aims in domestic production standards interacts with its international trade policy. Any divergence of UK farm support policy relative to current CAP arrangements would run contrary to these aims, and would present serious concerns to many of our members. FDF welcomes the opportunity to comment and looks forward to further discussion on the developing farming policy over time. How can we improve the delivery of the current Countryside Stewardship scheme and increase uptake by farmers and land managers to help achieve valuable environmental outcomes? We know from our supply chains that complexity of the application process means farmers are less inclined to take up such schemes as would be desired. Simplification, perhaps with an environmental focus on geographically different areas upland pasture/upland arable/lowland grass/lowland arable etc., would allow much clearer and more targeted - objectives. Having clear and worthwhile financial benefits for achieving targets is important, but such targets must also be able to acknowledge work already achieved by farmers, rather than penalising those who have already delivered improvements. It will be necessary for farmers to have sustainable, productive and profitable businesses to underpin the activities required to deliver environmental outcomes under such schemes, as some outcomes will only deliver changes in the longer term. It therefore seems odd that the consultation barely mentions food production as a farming activity ensuring successful farming businesses must be the primary objective of any future UK agriculture policy. An Agricultural transition What is the best way of applying reductions to Direct Payments? Please select your preferred option from the following: (a) Apply progressive reductions, with higher percentage reductions applied to amounts in higher payment bands, (b) Apply a cap to the largest payments, or (c) Other (please specify) Food and Drink Federation Page 2

3 We are disappointed that there is very little mention of food production within the consultation paper. Given the need for food security and stability for farmers we must ensure that food production is integrated with the delivery of environmental outcomes. The future reward system must be simple to deliver against and must not reduce the competitiveness of British growers and supply chains against those in the rest of Europe, who will enjoy different and potentially more substantial support /payments under the reformed CAP. Capping the high payment bands could impact businesses that tend to invest more in environmental schemes, productivity improvements and new technology, with the unintended consequence of reducing such outputs focus on rewarding those that improve productivity, integrated with environmental outcomes, will provide greater benefits that a simple cap that does not recognise where businesses have and continue to improve. The consultation does not recognise the potential risk to supply chains, the potential impact on food production, and the potential for rising food prices. These issues must be considered whilst designing the new system. What conditions should be attached to Direct Payments during the agricultural transition'? Please select your preferred options from the following: (a) Retain and simplify the current requirements by removing all of the greening rules (b) Retain and simplify cross compliance rules and their enforcement, (c) Make payments to current recipients, who are allowed to leave the land, using the payment to help them do so, or (d) Other (please specify) It is important not to create perversities in whatever new system is created. For example, with respect to greening, cover cropping may have more significant benefits than simply growing a greening crop. Such integrated management needs to be incentivised. Future payments could be linked to evidence of investment in innovation, new technology, knowledge and skills, especially for new/young entrants, for a stronger, future-proofed industry. What are the factors that should drive the profile for reducing Direct Payments during the agricultural transition? How long should the agricultural transition period be? This should be agreed once a new system for defining how payments for Public Goods will be measured, monitored and rewarded. Environmental outcome objectives take several seasons to deliver and often require collaboration of several farmers working on rented land, across the rotation. A transition period must be implemented that will allow farmers to adapt to new systems, whilst retaining sustainable and profitable businesses. This should be at least five years. In developing a model for Direct Payments, it is imperative that there is due consideration of farm business profitability as an indicator that delivery of environmental outcomes is underpinned by a sustainable and profitable farm business that is also contributing to improved productivity in the UK. The Government has set an objective for the UK to grow more, sell more and export more British food, to achieve this, farmers will need confidence to invest in their businesses and the time to adopt Food and Drink Federation Page 3

4 innovative technology to improve productivity sustainably. The CAP must support them in productive farming. Gold-plating of any standards introduced as part of the new system must be avoided and food imported into the UK must meet the same exacting food safety and quality standards that farmers in the UK must produce to, to ensure a level playing field. Any new system of Direct Payments must ensure UK farmers remain competitive against the rest of Europe and other global markets. A successful future for farming: farming excellence and profitability How can we improve the take-up of knowledge and advice by farmers and land managers? Please rank your top three options by order of preference (from 1 as your most preferred to 3 as your least preferred): a) Encouraging benchmarking and farmer-to-farmer learning b) Working with industry to improve standards and coordination c) Better access to skills providers and resources d) Developing formal incentives to encourage training and career development e) Making Continuing Professional Development (CPD) a condition of any future grants or loans f) Other (please specify) Many farmers and processors pay a levy to AHDB or other levy bodies and it is widely thought that AHDB and counterparts should be leading on knowledge exchange with farmers. Their guidance should be independent and evidence-based, industry-led and where appropriate delivered at a local level, with guidance that is tailored on a local/ regional basis (appropriate for local soil types, climate, water availability and crop rotations). The best farmers are just that because they actively chase and embrace knowledge and advice. Rewarding change, upskilling and the adoption of new technology and innovative farming practices could encourage others to adopt this approach; in turn improving productivity and enhancing the environment. A proportion of any future financial support should therefore be focussed on delivering and adopting guidance, training, new technologies and innovation; rewarding improved productivity delivered sustainably and thus leading to environmental enhancement. This needs to be combined with a fair exit plan for farmers unwilling or unable to meet the required standards. What are the main barriers to new capital investment that can boost profitability and improve animal and plant health on-farm? Please rank your top three options by order of the biggest issues (from 1 as your most important to 3 as your least important): a) Insufficient access to support and advice b) Uncertainty about the future and where to target new investment c) Difficulties with securing finance from private lenders d) Investments in buildings, innovation or new equipment, are prohibitively expensive e) Underlying profitability of the business f) Social issues (such as lack of succession or security of tenure) g) Other (please specify) Food and Drink Federation Page 4

5 Availability of cash is a key barrier. Planning and tax restrictions can also be a barrier to capital investment. In some sectors there is a lack of long-term stability and pricing structures. Increases in all fixed and variable costs, against farm gate prices, could create barriers to investment as could a lack of confidence in the outcomes of Brexit. Changes in food trends can also impact on investment confidence. Another barrier can be planning permission, which can create difficulties in farm businesses ability to update farm buildings and infrastructure. Perhaps a tax incentive should be reinstated, like the Agricultural Building Allowance to encourage investment in state of the art storage facilities (critical for the delivery of a consistent, year-round supply of raw potatoes), which could further improve food quality and safety and reduce food waste. New entrants into our industry are vital and the industry needs to be viewed as pioneering in its field; adopting new technologies with a professional approach. Start-up capital could be offered to new entrants with novel ideas to improve productivity alongside the delivery of environmental outcomes? Currently the implications that surround inheritance tax and agricultural property relief can make it difficult for a farmer to retire, allowing a younger entrant to progress. These regulations require careful consideration in the future. What are the most effective ways to support new entrants and encourage more young people into a career in farming and land management? Funding for mini farms/horticulture units in schools has been cut and agriculture/horticulture related learning has been removed from the National Curriculum. This has removed the opportunity to change the narrative around farming and it still has an image of being low skilled, low paid and requiring long hours, and not the career option for the most talented students. We support the suggestions outlined on page 29 of the consultation document aimed at raising awareness of agriculture as an exciting and attractive career path. With reference to apprenticeships for agriculture, these need to flag the many important facets of running a farm business and reflect the need for training in business and marketing skills, public engagement, precision farming, robotics and other technology. There are many disparate organisations and activities focussing on attracting new entrants into agriculture or land-based careers. The Government could do more to join up these activities. Furthermore, partnerships and links to businesses in the food and drink supply chain could be valuable in making careers in food supply more attractive. Career advisers in schools should have better training to ensure they properly promote theses as highly/multi -skilled, diverse and wellrewarded career options. Does existing tenancy law present barriers to new entrants, productivity and investment? No comment A successful future for farming: agricultural technology and research What are the priority research topics that industry and government should focus on to drive improvements in productivity and resource efficiency? Please rank your top three Food and Drink Federation Page 5

6 options by order of importance (from 1 as your most important to 3 as your least important): a) Plant and animal breeding and genetics b) Crop and livestock health and animal welfare c) Data driven smart and precision agriculture d) Managing resources sustainably, including agro-chemicals e) Improving environmental performance, including soil health f) Safety and trust in the supply chain g) Other (please specify) All of the above are important. Plant and animal breeding and genomic & nutrition research, automation, improved use of big data, biologicals and resource efficiency. How can industry and government put farmers in the driving seat to ensure that agricultural R&D delivers what they need? Please rank your top three options by order of importance (from 1 as your most important to 3 as your least important): a) Encouraging a stronger focus on near-market applied agricultural R&D b) Bringing groups of farms together in research syndicates to deliver practical solutions c) Accelerating the proof of concept testing of novel approaches to agricultural constraints the strategic direction for research funding d) Other (please specify) All of the above are part of a holistic approach to farming. Near-market, applied Research & Development is likely to be the most valuable. This should be based on independent and evidencebased research, industry-led. For effective knowledge transfer it should, where appropriate, be delivered at a local level, with guidance that is tailored on a local/ regional basis (appropriate for local soil types, animal herds, climate, water availability and crop rotations). The current system of funding for R&D is complex and designed more to meet the need of academic bodies than to be accessible to farmers and food producers. It would benefit from being simplified and the number of different bodies involved should be significantly reduced. Funding for research and innovation - In support of a world-leading Food and Drink Industry government must secure: Grants these need to be competitive with other regional markets, thus enabling continued investment and growth. EU research grants Horizon 2020 and similar; EU funding for innovation projects needs to be protected and matched in the long-term. EU Collaboration Ensure that UK can continue to collaborate with EU partners, ensuring that funding is not disadvantaged as a result. Samples movement tariff free movement of samples and consumer trials throughout the EU, plus also with US/Canada and other major partners. What are the main barriers to adopting new technology and ideas on-farm, and how can we overcome them? Barriers include the cost of investment in new innovations and technology and the cost of implementation. Could the payment system support this; perhaps funding leader farms where proof of principle could be demonstrated at a farm-scale, but without risk. Food and Drink Federation Page 6

7 Labour a skilled workforce What are the priority skills gaps across UK agriculture? Please rank your top three options by order of importance (from 1 as your most important to 3 as your least important): a) Business/financial b) Risk management c) Leadership d) Engineering e) Manufacturing f) Research g) Other (please specify) All are important, with business and financial acumen critical for a successful farming industry. We are also facing an increasing gap in succession of research expertise in crop science. There is a need to build in rewards for investment in skills and training into the new payments structure and create the training and development pathways to allow this to happen, at all levels. What can industry do to help make agriculture and land management a great career choice? The narrative around farming needs to change. Farming is part of the food and drink supply chain a key sector for the UK s economy. We welcome recent developments like the food and drink sector council, but we need more recognition by Government as well as positive promotion of the food and drink supply industry and the many and varied rewarding careers that are available throughout the supply chain. How can government support industry to build the resilience of the agricultural sector to meet labour demand? Please see earlier responses. Public money for public goods Which of the environmental outcomes listed below do you consider to be the most important public goods that government should support? Please rank your top three options by order of importance: a) Improved soil health b) Improved water quality c) Better air quality d) Increased biodiversity e) Climate change mitigation f) Enhanced beauty, heritage and engagement with the natural environment For industry, a, b, and e, although all have value and a-e have the potential to address both productivity goals and improved environmental outcomes. Food and Drink Federation Page 7

8 Of the other options listed below, which do you consider to be the most important public goods that government should support? Please rank your top three options by order of importance: a) World-class animal welfare b) High animal health standards c) Protection of crops, tree, plant and bee health d) Improved productivity and competitiveness e) Preserving rural resilience and traditional farming and landscapes in the uplands f) Public access to the countryside For our industry, all elements are important, with a natural focus on a to d. Regarding public access to the countryside, whilst this is important, public safety, as well as crop/food safety and security, must also be considered. Are there any other public goods which you think the government should support? It is critical that food production itself is recognised in any future models for delivering Natural Capital/Public Goods. Whilst food production is rewarded by the market and therefore not strictly defined as a Public Good, increasing domestic supply (and food security), reducing carbon footprint of food (by reducing our reliance on imports) and a reduction in the export of environmental issues, should be considered as Public Goods. The paper references the use of Natural Capital approaches to assess the delivery of Public Goods; how will this be achieved. What baselines will be used to measure change? How will Defra monitor that change has happened? How will Defra account for the environmental deliverables that are already ongoing/required by current and future legislation? Natural Capital should allow for profitable agriculture whilst enhancing environmental sustainability. How will new models account for extreme weather events? What happens to the payments in these scenarios? There are several recording systems already in place, which farmers use to manage and monitor their production (Muddy boots, Red Tractor Assurance, etc.), could these be used to support the new system and avoid creating yet another layer of audit burden for farmers? Could new tools such as Blockchain help? Who will be accountable to monitor farmer activity and environmental enhancement? Will the EA, Natural England, River Authorities, NFU, AHDB, industry, Assurance Auditors all be involved? What is the resource requirement, and who will fund this? The document suggests you do not have to farm the land to receive payment - how many will adopt this action and consequently reduce the amount of land available for production and optimal rotations. This is of real concern to our members. Food production must be recognised as part of the matrix developed to deliver the new payments, otherwise an unintended consequence could be the creation of a disincentive to produce food. This brings with it a huge threat to land availability for food production, if productive land is taken out of the rotation in order to prioritise environmental outcomes. Furthermore, land remaining in production may need to be farmed even more intensively to maintain productivity if access to land becomes restricted. Food and Drink Federation Page 8

9 Enhancing our environment From the list below, please select which outcomes would be best achieved by incentivising action across a number of farms or other land parcels in a future environmental land management system: a) Recreation b) Water quality c) Flood mitigation d) Habitat restoration e) Species recovery f) Soil quality g) Cultural heritage h) Carbon sequestration and greenhouse gas reduction i) Air quality j) Woodlands and forestry k) Other (please specify) b, c, f, d and e delivered within both a regional and rotational context. What role should outcome based payments have in a new environmental land management system? How can an approach to a new environmental land management system be developed that balances national and local priorities for environmental outcomes? How can farmers and land managers work together or with third parties to deliver environmental outcomes? Forestation will remove land from any food production for foreseeable future. A drive towards taking land out of production for environmental schemes rather than encouraging rotationally based environmental schemes, will have a major impact on the already diminishing land base we have available for agricultural production. It would take several years for land to be restored to agricultural use after forestation. It will be essential to have an overarching plan for the UK, that considers the impact of such schemes on the land available for production and the ability to farm within optimal rotations. The creation of incentives for large landowners to plant vast areas of forest on land, whilst continuing to farm the remaining land intensively, should be avoided. There is no mention of the importance of crop rotations in the paper, which are key to productivity and environmental improvements and to the delivery of Integrated Crop Management (ICM), biological control of pests and diseases, soil health and ultimately, improved food productivity. Many UK food manufacturers and retailers work in partnership with UK farmers to produce products in ways that have positive environmental impacts in order to differentiate their brands and meet consumer demand for products that meet specific standards of quality or provenance. It would be counterproductive if any future changes to UK agriculture policy did not leave space for this type of production, which adds value throughout the supply chain. How will the polluter pays principle be monitored and managed? How will the polluter be identified - as a water pollution from sediment and chemicals, can occur upstream/downstream of a particular farm business? How will government decide on level of pollution versus the penalty, what base level will be used? Is the current status of every water course known? Food and Drink Federation Page 9

10 Land is disappearing at an alarming rate and is set to disappear even faster, 25,000 Ha are required to build the promised 300k extra homes a year, 17,000 Ha are needed for industrial, road and retail construction. The government have committed to planting 180,000 Ha of woodland and to the creation/restoring of 500,000 Ha of wildlife habitats outside of the existing protected site network. None of this land will ever come back into production and the remaining land will have to even more intensively managed. Animal Welfare Do you think there is a strong case for government funding pilots and other schemes which incentivise and deliver improved welfare? The UK already boasts high animal welfare standards. The case has not yet been made that consumers across the UK would be willing to pay for higher standards, and indeed the changing nature of trade deals during and after EU Exit could potentially impact the financial viability of even current standards. No-one wants to see standards drop, but there is no evidence that higher standards will be commercially justifiable. Should government set further standards to ensure greater consistency and understanding of welfare information at the point of purchase? Please indicate a single preference of the below options: a) Yes b) Yes, as long as it does not present an unreasonable burden to farmers c) Perhaps in some areas d) No, it should be up to retailers and consumers e) Other (please specify) * If you answered perhaps in some areas, please elaborate. No, it should be up to food manufacturers, retailers and consumers. What type of action do you feel is most likely to have the biggest impact on improving animal health on farms? Please rank your top three choices from the below list, in order of importance. a) Use of regulation to ensure action is taken b) Use of financial incentives to support action c) Supporting vets to provide targeted animal health advice on farm d) Making it easier for retailers and other parts of the supply chain to recognise and reward higher standards of animal health e) An industry body with responsibility for promoting animal health f) Research and knowledge exchange g) Transparent and easily accessible data h) An understanding of animal health standards on comparable farms i) Other (please specify) j) N/A Cannot rank as they are all equally important B, c, e, f,g and h are all important, with b, c and h most likely to provoke real change. How can the government best support industry to develop an ambitious plan to tackle endemic diseases and drive up animal health standards? Food and Drink Federation 10 Page

11 Supporting research, knowledge exchange and pilot projects in geographical areas. In addition learning from other countries and parts of the UK where novel and effective approaches have been taken. Supporting rural communities and remote farming. How should farming, land management and rural communities continue to be supported to deliver environmental, social and cultural benefits in the uplands? There are a number of challenges facing rural communities and businesses. Please rank your top three options by order of importance (from 1 as your most important to 3 as your least important): a) Broadband coverage b) Mobile phone coverage c) Access to finance d) Affordable housing e) Availability of suitable business accommodation f) Access to skilled labour g) Transport connectivity h) Other (please specify) Access to Broadband and mobile phone coverage will help with the communication and implementation of innovative new approaches. Access to skilled labour is vital to all farming, but all of the above are relevant. With reference to the way you have ranked your answer to the previous question, what should government do to address the challenges faced by rural communities and businesses post-eu Exit? As the development of Precision Farming grows there will be an increasing need for farmers in rural communities to have broadband access and access to satellites etc. Changing regulatory culture How can we improve inspections for environmental, animal health and welfare standards? Please indicate any of your preferred options below (Select as many options as you wish). a) Greater use of risk-based targeting b) Greater use of earned recognition, for instance for membership of assurance schemes c) Increased remote sensing d) Increased options for self-reporting e) Better data sharing amongst government agencies f) Other (please specify) All of the above would help to reduce the additional burden on farmers and lead to more efficient audit and payment systems. Which parts of the regulatory baseline could be improved, and how? How can we deliver a more targeted and proportionate enforcement system? More joined-up thinking. There could be better connectivity between different departments/agencies and across devolved issues. We would support earned recognition reducing the audit burden, as long as food safety can be secured. Food and Drink Federation 11 Page

12 Risk Management and resilience What factors most affect farm businesses decisions on whether to buy agricultural insurance? Please rank your top three options by order of importance (from 1 as your most important to 3 as your least important): a) Desire to protect themselves from general risks (e.g. revenue protection) b) Desire to protect themselves from specific risks (e.g. flooding, pests or disease) c) Provision of government compensation for some risks d) Cost of insurance e) Complexity and administrative burden of insurance f) Availability of relevant insurance products g) Other (please specify) What additional skills, data and tools would help better manage volatility in agricultural production and revenues for farming businesses and insurance providers? How can current arrangements for managing market crises and providing crisis support be improved? Avoid the creation of a system that rewards poor performance. However, if other countries in Europe have systems to bail out farmers, how we can we ensure competitiveness and a level playing field? Suppliers have also commented that farmers deal on commodity markets controlled by the weather, the primary way to reduce risk is to secure forward business. Ensuring fairness in the supply chain How can we improve transparency and relationships across the food supply chain? Please rank your top three options by order of importance (from 1 as your most important to 3 as your least important): a) Promoting Producer Organisations and other formal structures? b) Introducing statutory codes of conduct? c) Improving the provision of data on volumes, stocks and prices etc.? d) Other (please specify) Promoting Producer Organisations and co-operative structures, and improving the provision and uptake of data. The cost and bureaucracy of properly implementing statutory codes of conduct for tens of thousands of farming and food businesses would be prohibitive and ineffective. What are the biggest barriers to collaboration amongst farmers? All collaborations need activation, energy and support. Intermediary organisations such as the Scottish Agricultural Organisation Society (SAOS) in Scotland - are able to provide that specialist support. They and others like them should be supported to champion and deliver cooperation and collaboration. What are the most important benefits that collaboration between farmers and other parts of the supply chain can bring? Food and Drink Federation 12 Page

13 Knowledge transfer, positive learning that is industry/peer-led. Government could help to enable this through support networks to independently forge collaboration in regional areas, but outcomes must be tangible. Farmers could also be rewarded for being part of a grower group, where it can be demonstrated that knowledge has been shared and implemented. Protecting crop, tree, plant and bee health Where there are insufficient commercial drivers, how far do you agree or disagree that government should play a role in supporting (Agree/disagree): a) Industry, woodland owners and others to respond collaboratively and swiftly to outbreaks of priority pests and diseases in trees? b) Landscape recovery following pest and disease outbreaks, and the development of more resilient trees? c) The development of a bio-secure supply chain across the forestry, horticulture and beekeeping sectors? Where there are insufficient commercial drivers, what role should government play in: a) Supporting industry, woodland owners and others to respond collaboratively and swiftly to outbreaks of priority pests and diseases in trees? b) Promoting landscape recovery following pest and disease outbreaks, and the development of more resilient trees? What support, if any, can the government offer to promote the development of a biosecure supply chain across the forestry, horticulture and beekeeping sectors? One of the biggest challenges facing the production of crops is the future availability of Plant Protection Products (PPPs). The restrictions imposed by regulation (such as 1107/2009, Water Framework Directive and the Sustainable Use Directive) is likely to add pressure to reduce the numbers of available actives to control pests and diseases. Furthermore, efficacy is being squeezed by increasing resistance as the tools available for control are reduced (AHDB, Horizon Report on Plant health and Plant Protection regulations). This means we urgently need investment in new chemistry, alternatives, new approaches to Integrated Crop Management (ICM) and Precision Farming to better target pests and diseases. Farmers only use chemicals where absolutely necessary. Any restrictions on actives should be based on a risk mitigation approach and on solid, scientific evidence. Loss of key actives will have a significant impact on productivity and could put us at a disadvantage if our competitors still have access to these chemicals. The AgriFood Industry needs strategic research investment to develop new actives based on improved chemistry alongside the development of innovative alternative approaches to pest and disease control that could form part of Integrated Pest Management (IPM) approaches. We need a cross-sector strategy for identifying the pests and diseases for which there are few or no alternative management tools currently available and a plan for investment in R&D that will deliver new tools for control (chemical or alternatives), enabling the production of quality crops. This strategy should include a forward thinking approach to investment in R&D to also develop new IPM approaches, which may include an enhanced understanding of how the range of crops grown in a rotation, and the order in which they are grown, impacts on pest and disease pressure. The new payments system could be designed to help drive innovation and adoption here. Food and Drink Federation 13 Page

14 Devolution: maintaining cohesion and flexibility With reference to the principles set out by JMC(EN) and listed in the devolution chapter, what are the agriculture and land management policy areas where a common approach across the UK is necessary? FDF are strong advocated on all regulatory matters for a UK framework to be agreed by all four administrations, respecting devolution and allowing the relevant (and currently available) opportunity for legitimate variance to reflect the differing farming, environmental, geographical and economic conditions found in the different nations of the UK. What are the likely impacts on cross-border farms if each administration can tailor its own agriculture and land management policy? This is of course, currently the case within the EU framework of CAP, and has been the case since well before devolution. So while it could be argued that this will add complexity and cost, it is not beyond the wit of UK and devolved Governments to deliver a joined up approached. International Trade How far do you agree or disagree with the broad priorities set out in the trade chapter? How can government and industry work together to open up new markets? How can we best protect and promote our brand, remaining global leaders in environmental protection, food safety, and in standards of production and animal welfare? FDF wants to ensure that food and drink are at the top of this Government s agenda when it comes to trade and our international presence. Food and drink is a fantastic way to sell the United Kingdom abroad with whisky, cheese, meat and luxury treats. Farming is a fundamental part of this image, and Government should be relentlessly promoting these messages including traceability, safety, low carbon footprint, top quality, local jobs, some of the world s finest grade 1 growing land. Not aiming to produce the cheapest food, but rather sustainably farmed in harmony with the environment and wildlife. We agree the priorities, within a context of remaining competitive and maintaining a focus on productivity. The food and drink industry is supportive of free trade and a tariff-free agreement with the EU post- Brexit. It is hard to comment on this section until we know what the final arrangements will be. Different standards will add complexity and cost. Legislation: the Agricultural Bill How far do you agree with the proposed powers of the Agriculture Bill? (Agree/disagree) What other measures might we need in the Agriculture Bill to achieve our objectives? Food and Drink Federation 14 Page

15 Basic compliance across all farms, with a focus on skills and training. Support for the management of big data in rural areas (delivering on connectivity commitments) and a view towards climate change and emergency protocols. Legislation around automation and robotics in agriculture will also be needed. Food and Drink Federation 15 Page