The snowstorm of emails asking your permission to stay on mailing lists has finally abated. If you, like me, have also noticed that some of the websites you previously visited are no longer there, that’s also because of GDPR – the General Data Protection Regulation. Mind you, it hasnt stopped me receiving spam about how I can make a fortune from bitchain, or whatever it is (I never read them.)

GDPR is the EU law which will make it more difficult for companies like Facebook, to weaponise your personal data. Sadly it may have been too late to prevent your data from being used to sway the result of the EU Referendum and the US election, which saw President Trump elected.

I for one am a great supporter of it, and of what it illustrates. Which is this.

The EU creates laws to protect its citizens. That is a good thing. Some might argue that the GDPR is just another unnecessary piece of Red Tape – though in truth I have heard few of those siren calls that we all come to expect emanating from the free-market de-regulatory nexus. Perhaps they are waiting to pop out today.

If you signed up to receive an email telling you I have written a new blog, I have not asked for your permission to continue to contact you when I write that blog. This is because I had to read quite a lot about the GDPR recently  – mainly because I wanted to make sure People Need Nature complied with the new law. And it seemed to me that an awful lot of organisations, mostly charities, were panicking and asking people to resubscribe unnecessarily.

This blog is a purely personal matter, there is no money involved and no organisation. It’s literally me (and some guest bloggers) writing about stuff I’m interested in – I’m not providing any form of service and there is no contract between me and you. You’re here because you want to be. And you can unsubscribe from the mailing list any time you want to.

If you’re one of the fantastic people who leave comments on here, then, again, that’s your choice. And if you want all your comments erased now or any time in the future, just let me know and I’ll remove all traces of you from my blog. I don’t do anything with your data, and I won’t do anything with it in the future. It’s saved here on wordpress so you don’t have to fill in your details each time you leave a comment.

Thanks very much for reading this blog, and all the other ones.


Posted in Europe, GDPR | Tagged , | 7 Comments

Natural Capital thinking leads us astray

Balinese water temple.

It seemed appropriate that I should take part in a debate about natural capital and wetlands yesterday, on International Biodiversity Day. I was invited (I think) to be the Natural Capital dissident. It was a good debate and I enjoyed discussing the issues with my old boss Martin Spray from Wildfowl and Wetlands Trust, and Charlie Stratford from CEH.


I understand a podcast of the debate will be made available in future and I’ll let you know when it is.


This is based on an article I wrote for Lush Times yesterday to coincide with the debate – actually this is based on the speech I wrote, though of course I completely deviated from it!

International Biodiversity Day

I have to say I think biodiversity is an ugly word. I much prefer Nature, or Wildlife. Biodiversity is clunky, and not easily understandable. It has its place – in technical discussions – but if you’re going to try and persuade people in different countries, with different cultures, that Nature is important (which I think is what these International Days are about) then it’s not the right word to use. But then biodiversity, as a word, is relatively harmless compared with the term ‘Natural Capital’.

Natural Capital is a relatively new (from about 1988) economic idea. The old notions of Capital referred to things like Land, resources like Coal, and Labour. Over the years, Capital was broadened to include Social Capital and eventually Natural Capital. Natural Capital is now described as the sum of all the things nature provides to people – which are also termed Ecosystem Services. Now there is growing movement to push for Natural Capital to be given a financial value, so that it can be properly accounted for in the economy.

The Language of Capital

Language is always important when working to achieve understanding and then change. And I am always interested to explore where the words we use come from.

Capital derives from the Latin Caput or head. Originally this referred to head of cattle, which was (and still is in some places) the measure of someone’s wealth. This is also where the word chattel as in ‘Goods and Chattels’, comes from.

Naturally, Stock derives from livestock, and the Stock Market was the place to trade your Cattle, long before anyone had the idea of companies or shares.

Less obviously a Fee comes from the Saxon Feoh, which means Livestock or Cattle.

Pecuniary comes from the Latin pecunia which means “wealth in cattle.”

Just for a change, Emolument originally meant “payment to a miller for grinding corn.”

And in a similar vein, Derivative comes from De rivo, literally water drawn from a stream.

The language of capital, and of economics is full of the ghosts of a much closer relationship with, and conscious dependence on, Nature. But these words have been appropriated, altered and yoked to serve other needs.

Natural Capitalism seeks to place a value on Nature, for our own benefit. But are there other values outside the human ones We don’t know whether an Elephant knowingly values an Acacia tree, but it certainly depends on it, whether it knows or not. And the same applies to every other animal, plant, fungi or bacteria that makes up every ecosystem on the Planet.

The ideas of Natural Capital, that value flows from nature to people, is based on the human notion of property rights – if you own a piece of land, or a tree (or an elephant) you have the right to do what you want with it. But does nothing else in Nature have property rights? Who decided that? Even more bizarrely, property rights are conferred on entirely artificial constructions, like companies, or public institutions. Again this ignores everything else.

How do we assign value to the ecosystem services a tree provides an elephant? Elephants have no need of money but that is irrelevant to what the tree provides the elephant. If all species can assign values to the things they need for life, then most of the value in an ecosystem lies in the relationships between the species that comprise it – the value is internal, not external. This could be called intrinsic value.

Natural Capital economists do not like the notion of intrinsic value, because it messes up their equations. Professor Dieter Helm, the leading Natural Capital economist and chair of the UK Natural Capital Committee, described intrinsic value as “dangerous” because it “opens up the possibility that the world might be better off without us.” This sounds a bit hysterical to me.

Natural Capitalists argue that we must adopt the language of the economist in order to persuade businesses, or Government economists, to change their calculations, and include a financial value for Nature. The evidence, such as it is, does not support this approach. One typical economist’s approach is that the needs of the economy have to be traded off against the needs of Nature – and this despite this idea being repeatedly debunked, it keeps turning up. (Just last week I wrote about proposals for a new Green Watchdog, which would balance environmental needs against the economy.)

One recent example shows up the dangers of using this trade-off approach all too well. Economists use a Cost Benefit Analysis (COBA) to look at the environmental impact of an activity, usually development. The costs (financial) of developing a road or a new housing development or whatever are balanced against the economic benefits – so, in order to do this financial figures have to be calculated for the benefits the environment provides (us.) During the Obama administration, an assessment of the value of US wetlands was made, which concluded they provided $450M a year of benefits to the US economy. On this basis Obama created a Waters of the United States (WOTUS) programme to support these wetlands. But when Trump took over, his “environment” man Scott Pruitt ordered are-evaluation and found them to be worth only $50M, far less than the costs to the economy of protecting them, calculated as $300M a year. At the press of a button, those wetlands suddenly had no (net) economic value. The Natural Capital Coalition argued that what Trump had done was terrible – and of course he is the most anti-environmental world leader, the world has ever seen. But all he was doing was showing how the COBA approach loved by the Natural Capitalists is so wrong. Put a financial value on nature, and you put it in peril. Now Trump is also attacking the legal basis for protecting nature in the States, but it will be a much tougher route, through the courts, and up against people using ethical arguments for why it needs protecting.

Evidence from the field of psychology suggests that when people think about the financial value of Nature, these thoughts “crowd out” any ethical or moral concerns for Nature. In other words, you may feel a moral duty to look after a tree, but if someone offers to pay you to do it, you then forget about that moral duty. And if they stop paying, you are more likely to cut it down.

Wealth Creation

Natural Capitalism tells us that the current economic system values natural capital at zero, and therefore ignores it. So, if natural capital is suddenly given a value (where previously it had none), then new economic value will be created. We could call it a magic money tree.

The Office for National Statistics tells us that UK natural capital has a value of £750Bn. This may sound like a lot, but London’s residential property is worth twice that.

One of the reasons why London is worth so much is because of Quantitative Easing: The last time the Magic Money Tree was harvested, £435Bn was created out of nothing – and that capital flowed into many places, not least property – here and elsewhere. How much of it flowed offshore, outside jurisdictions, away from tax payments for public good? Nobody knows. The National Crime Agency estimates that nearly £100Bn a year of stolen money is laundered through the UK (and into UK offshore territories), much of it from Russia.

Capital is always flowing to places where it can’ pool’, away from the grasping claws of Regulators and Taxmen. Land in the UK is a good example of this. Farmland (75% of the UK) has become a massive tax shelter. It’s a tax haven, hiding in plain sight. Tens of billions of pounds a year are lost to the Exchequer via this tax haven. Are all those tax reliefs providing any benefit  – is Nature, let alone Natural Capital, benefitting from them?

If the value of the UK’s natural capital really was converted into financial capital i.e. real money – where would it flow? One thing we can be sure about – it will not flow back to the “providers” of the “services” i.e. nature itself. It becomes just another asset to be traded, and, like QE, it will contribute to asset price inflation.

Ecosystem Slavery

Ecosystem Services is another appropriation, another euphemism for something quite different. The modern word is used to describe a transaction. A plumber provides a service by fixing your boiler, for which they receive payment.

But Ecosystem Services harks back to the original meaning of service  – from the latin servitium “the condition of a slave.” And that is really much more accurate, because we have effectively enslaved large parts of the planetary ecosystem, to serve at our will.

Does the concept of natural capital recognise this injustice? Does it work to emancipate the enslavement of Nature? Slaves had value after all, and the market determined that value – even though that value never flowed to the slaves. The market had no interest in emancipating slaves, indeed some economic historians recognise the central role that slave-driven production had in kick-starting the industrial revolution and creating the wealth of the British and other Empires.

It was political campaigning, driven by moral arguments, plus a few slave revolts, which led to Emancipation. Ironically when Emancipation came, it was the slave owners who were compensated for their loss, not the slaves, who continued to live in penury. Similar campaigns exist today (mainly outside Europe) seeking to give Nature “legal standing”.

Market Failure

Natural Capital is supposed to be the way to address market failure, which describes when the market doesn’t price in the value of Nature to economic transactions. But there are tried-and-tested ways to address market failure: Regulation, Taxation, Subsidies (payments to create public benefits) and Education to reinforce the moral arguments for Nature. None of these approaches have been entirely successful, but they have all been used with some success and without needing to try and place a financial value on Nature.

There is a great danger, with the Natural Capital approach. It is that those who believe the market to be the only true solution to all problems (also known as Neoliberals) will seek to exploit the good intentions of others, and replace all the well-established remedies for market failure, with a market-based solution, turning Nature into just another commodity to be traded.

An alternative future?

We can look at some examples from the past which might help shape a new relationship between people and Nature, of which we are both part of and apart. Commons existed for 1,000 years in Britain. Commons restricted property rights of both owners and commoners, and in doing so required both to use the natural resources provided in a more sustainable manner than purely private property owners would do. Nature thrived on the Commons but the Enclosure Acts saw most of them privatised over a 300-year period.

The peasant poet John Clare mourned the loss of his commons (here’s just a fragment from The Mores)

“…Now this sweet vision of my boyish hours

Free as spring clouds and wild as summer flowers

Is faded all – a hope that blossomed free,

And hath been once, no more shall ever be

Inclosure came and trampled on the grave

Of labour’s rights and left the poor a slave…”

A belief in the sacredness of nature also helps people to work with Nature, rather than against it.  Bali’s thousand year old water temples are a good example of this. The Temples and Balinese rice farmers worked together to ensure harvests were sustainable, water was shared out equally and different communities planted their crops at different times, according to where water was available. Pests were controlled by a system where every community fallowed their land at the same time, starving pests of food. When new crops and agrochemicals were introduced, alongside Government rules which ignored the traditional approach, the system fell into chaos, pests proliferated and rice harvests plummeted. Thankfully the value of the ancient system was recognised before it was too late, and the Temple control reinstated.

Rather than seeking to make more sacrifices to the God of the Financial Market, perhaps we need to find ways to create a new sense of the sacred in nature.


Photo of Balinese water temple by Michelle Maria [CC BY 3.0 (, via Wikimedia Commons

Posted in biodiversity, Lush Times, Natural Capital | Tagged , , | 13 Comments

Losing the Muscle from Brussels risks leaving the environment protected by a Paper Tiger

Now that the consultation over the future of farm support in England has finished, Defra – the UK Government‘s Department for Environment, Food and Rural Affairs – tells us that more than 44,000 responses have been received. So many thanks to all of you who took the time to let Michael Gove know what you think about the right approach for farmers to be supported in the future.

Hot on the heels of that consultation (as if Defra was sitting on its hands and twiddling its thumbs) it has launched the next Brexit-related search for answers – namely, what to do about the “Governance Gap”.

The Governance Gap is the space which leaving the EU will create, because laws derived from Brussels are ultimately enforced by Brussels. When Brussels is no longer part of the picture, who enforces those laws?

You might think, “ah well, we won’t need to worry about that because we won’t be subject to any laws from Brussels any more.” But you would be wrong. Because the Government has committed to transfer all EU law across onto the UK statute book (the book of laws – and no there isn’t an actual book) at least in the first instance. And since most of our environmental laws are derived from Europe, this is a very, very big deal for the Environment.

European Law has helped to reverse or at least slow the continuing decline in our environment – covering everything from birds to beaches, river water to air quality, invasive species to electronic waste.

Leaving the EU (assuming that is actually going to happen) means we either lose all these protections or duplicate them. Some certainly want us to lose them – Tory politician and hard line Brexiteer Jacob Rees Mogg, who is the MP for North East Somerset, for example has suggested that we would be perfectly fine with the same level of environmental protection as India. But Environment Secretary, Michael Gove, who is keen to be seen to be ‘green’, has come under intense pressure to do the right thing.

Last Autumn, during the passage of the EU withdrawal bill through the Commons, Gove promised to bring forward proposals for a new green watchdog which would ‘plug’ the Governance Gap. We could call it the Green Plug. And last week he did just that, launching a consultation asking people’s views on what the Green Plug might look like, and how it would work.

Radio 4’s Today programme (55 minutes in) had a brief report on it last Thursday, in which, typically, anchorman John Humphrys displayed his Brexity credentials by framing the issue as “Brussels decrees and we obey”. This is arrant nonsense, but just the sort of thing Today listeners have come to expect from Humphrys, reportedly causing many life-long Today listeners to abandon the programme in protest. The BBC reported Cabinet arguments over the Green Plug, including complaints that the new Regulator would prevent the claimed Brexit Bonus of freeing up red tape.

There’s a delicious irony here, in that the Tory MP who caused Michael Gove to make the commitment to the Green Plug in the Commons was my own MP, Sir Oliver Letwin. Letwin also set up the supposedly neutral Red Tape Initiative, which was criticized soon after its creation for having a bias against regulation. The RTI has yet to publish its recommendations and it remains to be seen whether it will challenge any environmental protections provided by EU law.

Apparently the Treasury is worried about how much Regulation would cost the economy, while others (perhaps in the Housing Department) feel Ministers should be free to decide policy, unfettered by pesky regulators. And this is a story which has been running for many years, because the EU has successfully protected the environment against house-building and other infrastructure projects – Dibden Bay being a good example. The fact that sensible regulation helps the economy and society, seems to have slipped by the more fundamentalist free-marketeers in the Cabinet – again.

I can see you’re all on tenterhooks now, wondering – tell us, tell us, what will the Green Plug look like? I’m afraid it is, as you would expect, a paper tiger.

Brussels could levy fines totalling tens of thousands of Euros a day for repeated and gross infringements of EU environmental law – and it did. Just the threat of proceedings was often enough to achieve change. Having said that, Brussels could be a lot tougher as an environmental protector.

The epic battle between Client Earth and Defra over the UK’s abysmal air quality continues to run, despite repeated Court judgements against Government inaction. In this case, the EU summoned Environment Ministers from several countries to Brussels in January, giving them one last chance before court action. (It’s worth noting that in Germany, a Court threatened the Bavarian state Environment Minister with prison if he failed to act on Munich’s air pollution).

Could such a thing happen here? Could the Green Plug take Michael Gove to court under threat of imprisonment should he fail to implement an environmental law? Let’s just say that stretches the bounds of implausibility beyond breaking point. No, the proposals are that the Green Plug would issue “advisory notices” for failures. If they were ignored, then, as a very last resort, it could issue “binding notices”. But as there are no Muscles from Brussels waiting in the background to enforce these notices, they will mean nothing.

And actually it’s considerably worse than that.

Under EU law, environmental law could not be ignored on the grounds of simple short term economic interests. The Green Plug proposals seriously weaken this position. The needs of the environment will have to be “balanced” against economic competitiveness, prosperity and job creation. This completely undermines the principles of Sustainable Development, which sees the Environment as being at the heart of the economy, a key element of prosperity and helping create sustainable jobs. The Green Plug then, is a recipe for ignoring the environment when it gets in the way. It takes us back to the point before 1980 when EU environment laws started to apply in the UK.

Once again the public and Civil Society will have to use its meagre resources to advocate what is needed, to try and defend the very hard fought victories of the last forty years. I’ll update you regularly as this campaign develops, so you can all play your part.


this post first appeared in my No Tern Unstoned column at Lush Times

Posted in Brexit, European environment policy, Lush Times, No Tern Unstoned | Tagged , , , | 1 Comment

Five Years….



Yes today I’m celebrating five years of a new nature blog. I can’t quite believe it myself.

Five years seems like a long time, perhaps because so many things have happened in that time, with the big one of course being Brexit. Looking back, I see I have written a great deal about how rubbish the Common Agricultural Policy was  – and now, assuming we are actually going to leave the EU (still a big question mark there), we are going to say goodbye to the CAP.

I’ve also written at length about the rise of the Far-Right in Britain. UKIP has come in for some bashing by me, for various reasons. Indeed, some of the most well-read posts of all time are about UKIP, including this one on their bizarre former environment lead, Doctor Earth.

And then there’s the frankly awful record of the Coalition Government; and then Cameron’s short-lived majority Government, on the environment. Considering just how useless or actually malign characters like Owen Paterson, Liz Truss and Andrea Leadsom were, Michael Gove does appear to be quite good – or at least knowledgeable. Still the proof of that particular pudding has yet to be determined; and we must not forget where he has come from.

I’ve covered in depth a few cause celebres – including Lodge Hill – whose fate still hangs in the balance, and Rampisham Down, which has become a significant victory for conservation. Natural England played their part in both these campaigns, but whether they will survive in their current form for another five years (or even another year) is moot.

And I’ve also looked at particular issues in depth, like flooding, biodiversity offsetting,  biogas Maize and dogs.

Who would have thought, five years ago, that the Government would be seriously considering a widespread reintroduction of the Beaver to England? That perhaps above all symbolises how rewilding has captured the imagination of the public and the media, and therefore politicians. Long may that continue and other species also deserve to return – including the Wisent.

And I’ve also indulged myself with some frankly silly articles, and some think pieces – thinking about how the ghosts of Elephants and Rhinos still stalk our landscapes.

Along the way I’ve had my own fair share of personal triumphs and setbacks. I have set up People Need Nature, and we are starting to make a bit of an impact – especially with the Pebble in the Pond report on farming post-Brexit. How much further we progress will depend on the success of the current fundraising campaign. I lost my brother to cancer at the ridiculously early age of 52 and then had a brush with death myself thanks to a septic kidney.

I had no idea at the time that writing this blog would lead to opportunities for writing (some even paid!) but this is what has happened and it’s been great to write for British Wildlife (where I will continue to contribute occasional articles) and other blogs like Mark Avery’s and Green Alliance. I find I am enjoying writing more than doing conservation now. Should I admit to that?

For the last year or so, I’ve been splitting my time between People Need Nature; and researching and writing for Lush Times. I write a weekly column called No Tern Unstoned (the silliness never quite goes away) which I am really enjoying writing. I’m also working on some other projects for Lush, more of which anon.

So it just leaves me to say a massive thank you to all of you – readers, and especially those of you who leave comments. It’s been great and I hope to continue writing here, and elsewhere.

Posted in blogging | Tagged , | 13 Comments

Sainsburys and Asda’s owners are “in the money”, but the cost is on us.

Sainsburys Boss Mike Coupe sings “we’re in the money”

A shock wave ran through the world of food, farming and shopping last week as news of a plan to merge supermarket giants Sainsburys and Asda was leaked.


Supermarkets now dominate food shopping – and many other parts of the retail world. Tesco takes the largest share of the UK supermarkets’ combined revenue which accounts for £86Bn out of the £185Bn total UK grocery market. Sainsburys and Asda currently rank second and third but together, would overtake Tescos and take nearly one third of the supermarket share of the grocery market.


Sainsburys already bought Home Retail in 2016. And if this planned merger goes ahead, it would create a retail behemoth of 2,800 stores nationwide, ranging from the big Asda and Sainsburys superstores, to local convenience stores, plus an additional 739 Argos and three Habitat stores.


Sainsburys Chief Executive, Mike Coupe, assures everyone that the merger is good news for the consumer; that no stores will be closed, and that everyday goods will be cheaper – perhaps as much as 10% cheaper. But Coupe then went and ruined the moment when he was caught, between TV interviews, singing


We’re in the money, come on, my honey,

Let’s lend it, spend it, send it rolling along!


Which, if you’re not familiar with it, is from the American musical classic 42nd Street (now aptly back on stage in London and featuring the singer Lulu). Set in the Great Depression era of American History, it’s a heart-warming tale of an ordinary young chorus girl from a small town who, against all odds, becomes a Broadway Star. The song was also used in the Hollywood film Gold Diggers of 1933. Perhaps that’s where Coupe got the inspiration. For gold it will indeed shower him with, given the millions of Sainsburys shares he owns (or has options to buy)  – shares which have already jumped greatly in value as a result of the announcement. That’s in addition to his £1m+ salary and bonuses.


Will everyone else be showered with gold though? Asda’s owners will do very well from the merger. Sainsburys’ offer to pay £3bn cash and Asda retains a 42% stake in the new outfit. Asda – which was originally created by a merger between a dairy firm and a chain of butchers in Yorkshire, was bought by US retail Titan Walmart in 1999. So Walmart will get a cash down-payment and a big slice of the new business.


The other big player is the Qatar Investment Authority, which owns nearly a quarter of Sainsburys. Between them, Walmart and the QIA will own more than half of the new business. And of course the lawyers and bean counters, who always profit from big mergers, will be ordering in the Champagne.


So what about the rest of us, or indeed things like the environment, which usually lose out in these deals? Well, despite Sainsburys’ claims, it’s inconceivable that shops won’t close. Will towns, which currently have a Sainsburys, an Asda and an Argos, really will have all three in a couple of years time? Job losses are also inevitable in the “back office” of each company.


And what about the businesses that supply Sainsburys and Asda at the moment. Farmers, whose produce enters the labyrinth that is the UK’s food supply chain, will do badly from the proposed merger. This is because the new company (let’s call it ASSburys) will have even more power to drive down the prices they pay their suppliers  – or even force producers to lose money, on “buy one get one free” offers.


Perhaps the new company, with its increased profits, will pay more tax into the nation’s coffers, to help pay for things like repairing the roads damaged by all the supermarket vans whizzing about delivering groceries. Err, no. Walmart uses a complex web of offshore and shell companies to move its profits around the world, but mainly to places where it doesn’t pay tax.


In 2015, an investigation by Americans for Tax Fairness, revealed that Walmart had stashed $76 billion in overseas tax havens, including the British overseas territory Tax Havens the British Virgin Islands and the Cayman Islands. And while Sainsburys has historically channelled significant amounts of its profit into the many and varied charitable trusts the Sainsbury family has set up, it’s by no means clear how much of ASSburys profits will continue to flow to these Trusts after the merger.


Sainsburys has already been criticized for reneging on a commitment to improve animal welfare standards in the production of its own label chicken – and to such an extent that Compassion in World Farming has withdrawn the “Good Chicken Award” it gave Sainsburys in 2010.


Walmart certainly has no such concerns over chicken welfare, and will presumably be pushing hard for ASSburys to be able to buy cheap, low animal-welfare “chlorinated chicken” after Brexit. Indeed only a few days ago a Parliamentary Committee concluded that it would be madness to rush into a quick trade deal between the UK and USA after Brexit, for precisely these reasons. The National Pig Association has already voiced concerns that Sainsburys’ policy of sourcing British Pork (with relatively high welfare standards) will be dragged down to Asda’s level.


Reducing competition in any market is bad news for consumers and the Environment. In theory, there are Regulators whose job is to prevent monopolies from forming. The Competition Market Authority has, naturally, been urged to investigate ASSburys. But it  has already shown itself to be spineless by approving Tesco’s takeover of Booker last year. This merger reduced competition and squeezed suppliers just as ASSburys will. The Government has also refused to widen the remit of the Grocery Code Adjudicator to investigate the impact of mergers like this. So it is powerless to act to reduce unfair trading practices, despite it being set up, in theory at any rate, precisely to do that very job.


One might think the power to drive down prices paid to the producer is good news for the consumer. The problem is that food prices are already so low that they create a wide range of other problems: Producing food which is nutritious, which is grown in a way which minimises damage to the Environment and which has high animal welfare standards, is always more expensive. Organic food is a good example of this price hike. Forcing farmers to produce cheap food just passes the costs on to farm animals, low paid workers in the food industry, and damage to the Environment.


Farm subsidies (provided by taxpayers) paid to farmers are effectively taken from them by the supermarkets, in the form of low prices paid to them for the food they grow. These subsidies then (mainly) find their way into shareholders dividends and senior executives’ salaries; they do little to reduce the retail price of food to the consumer. So it’s likely (and depressing) that in reality, this planned mega-merger will lead to food producers being squeezed so far that they go out of business.

this article originally appeared on the Lush Times website.

Posted in Food, Lush Times, No Tern Unstoned, supermarkets | Tagged , , , , | 4 Comments

Health and Harmony: Last chance to respond.

I’m posting this here as well as on the PNN website, for maximum reach. It’s the People Need Nature response to Michael Gove’s consultation on the future of agriculture in  England.

If you haven’t submitted a response yet, please find an hour over the long weekend to write something. Feel free to make use of what you find here. I cannot overstate how important it is that as many of you as possible contribute. There have been tens of thousands of responses sent in – though I suspect many of those will be auto-generated via 38 degrees or, and they will be lumped together. Individual responses have more clout.

You still have time, either to write something free-hand or use the online form. There is plenty of time – the consultation closes at 1145pm on tuesday the 8th May.

Was it coincidence the consultation closes on VE (Victory in Europe) day? Who knows.

Health and Harmony: the future for food, farming and the environment in a Green Brexit – Response from People Need Nature




People Need Nature is a Charitable Incorporated Organisation established in 2015. We are dedicated to promoting the sensory, emotional and spiritual value of nature, the importance of nature on public land and in public decision-making.


We advocate a different approach to how nature is valued and protected, particularly in relation to publicly owned land, public policy making and public expenditure. We aim to influence and drive new policy.


As a Charitable Incorporated Organisation covering England and Wales, we will not be commenting on devolved matters.


This submission has been prepared by Miles King FLS, Chief Executive of People Need Nature.




People Need Nature welcomes the Defra consultation “Health and Harmony: the future for food, farming and the environment in a Green Brexit.” We produced a report entitled “A Pebble in the Pond: Opportunities for farming, food and nature after Brexit” in January 2017 and it is heartening to see Defra looking at the future of Agriculture, and its relationship with food and nature, from a similar standpoint. We attach a pdf copy of our report with this reply.


Public support for agriculture has to change. Paying subsidies to farmers and landowners with little or no public return can no longer be justified. Food Security may have been a good enough reason to pay farmers to grow more food (at any cost) in 1940, when our food supplies from the Empire and Dominions were threatened during times of war. Those times have long gone, but the environmental consequences of that drive to increase food production are still with us. Now, Society has to help farmers not only slow the continuing loss of wildlife and natural resources, but to reverse that trend.


Some of the responsibility lies with the Common Agricultural Policy, and some lies with domestic farm policy from 1940 to 1973. A great deal of damage was done to farmland wildlife, and to the social fabric of rural England and Wales, during the period before the UK joined the Common Market. It is useful to remember this history, as we consider how to design the first new domestic agriculture policy in 45 years.


It is not our intention to answer every question in this consultation – as many fall outside our remit and charitable purpose. However, there are some areas of policy which we believe have not been covered adequately, and we will attempt to fit comments on these areas as best we can within your framework.




1. Agriculture: the case for change

No questions


Moving away from the Common Agricultural Policy in England


2. Reform within the CAP


Please rank the following ideas for simplification of the current CAP, indicating the three options which are most appealing to you:


  1. a) Develop further simplified packages
  2. b) 
Simplify the application form
  3. c) 
Expand the online offer
  4. d) 
Reduce evidence requirements in the rest of the scheme
  5. e) Other (please specify)


  1. e) There is an assumption that the most important thing to do is simplify the current CAP scheme. For nature to benefit, this may not be the best approach. If simplification means that fewer farmers enter Countryside Stewardship – especially those who are managing existing wildlife-rich farmland, then simplification will cause damage to that wildlife, which runs counter to Defra’s stated aims. Conversely, if simplification means Stewardship schemes which are “no brainer” schemes, which require little or no change in the way land is farmed, then they will also provide little or no public benefits for the money paid.


There are already problems associated with farmers in agri-environment schemes, which are finishing in 2018, being told they cannot apply for a new agreement until 2019. The failure to maintain appropriate management for nature even for one year can have devastating results. There is also a risk that farmers will be disenchanted and not renew their schemes – or worse will feel they have no alternative but to convert recovering wildlife habitat back into intensive food production – with the loss of an investment from the public purse over a period of up to 30 years, from the time when the first agri-environment schemes were set up. And none of this has been helped by Natural England, RPA and ultimately Defra’s failure to manage the administration of Countryside Stewardship over the past year, which is now at crisis point.


If you have answered “other (please specify)”; please explain your preferred alternative.


Please give a short explanation as to your ranking preferences.


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?


The current Countryside Stewardship scheme has proved unpopular with farmers and land managers and aside from providing continuity for those who need support to manage their existing farmland wildlife habitats (as described above) there is no strong argument for attempting a large roll-out when the entire framework for agricultural support is going to change radically in the near future.


The current scheme should therefore focus on ensuring the richest farmland wildlife habitats and heritage features are protected; and also provide support for farmers and landowners who are recreating, or who have successfully recreated or restored degraded farmland wildlife. This should be seen as a “holding operation” to protect this resource during the transition to the new scheme.


Do you have any further comments?


3. An ‘agricultural transition’


What is the best way of applying reductions to Direct Payments? Please select your preferred option from the following:


  1. a)  Apply progressive reductions, with higher percentage reductions applied to amounts in higher payment bands *
  2. b)  Apply a cap to the largest payments
  3. c)  Other (please specify)


We would suggest adopting both a cap and a taper. The European Commission is proposing a cap on payments in the new Common Agricultural Policy of £52000 a year. We would suggest that a taper is introduced on payments above £50,000 a year, with a cap at £75000. This would liberate a sufficient amount of resources to properly fund the pilot projects needed to establish how a “public money for public goods” approach would work. To prevent those avoiding the cap by breaking their farm businesses into several units, a back-dated base-line should be applied – using January 1st 2016 would ensure that no advantage could be gained from any anticipation of the Brexit referendum result.


If you have answered “other (please specify)”; please explain your preferred alternative.


* please provide views on the payment bands and percentage reductions we should apply.


What conditions should be attached to Direct Payments during the ‘agricultural transition’? Please select your preferred options from the following:

  1. a)  Retain and simplify the current requirements by removing all of the greening rules
  2. 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
  3. d)  Other (please specify)


  1. d) While greening is generally regarded as having been a failed experiment in delivering public goods via the CAP mechanism, it would be very unwise to remove all greening rules without any consideration of that impact. For example, currently the Permanent Pasture rules sit within greening. These have admittedly been very weak at protecting nature in grasslands, partly because of the way they have been applied in the UK. Removing these rules altogether, though, would leave a large area of semi-improved grassland (with a large soil Carbon resource and certainly some value for wildlife) at risk of cultivation.


It is not clear what “retain and simplify” in the context of Cross Compliance, would mean in practice. Cross Compliance is a complex set of rules and could certainly be greatly improved, both in terms of their efficacy at protecting the environment, and the bureaucratic burden they place on farmers. The risk is that simplification actually means the environment will be left more vulnerable than it already is – and that Cross Compliance will be left unenforced.


A better approach would be to focus resources on those aspects of Cross Compliance, which deliver the greatest environmental benefit. Any enthusiasm for chasing farmers who have a bit of scrub in their field corners, or who have allowed their hedges to grow out, to the benefit of farmland wildlife, should certainly be abandoned. Whereas farmers who allow slurry to pollute local watercourses need more enforcement, given the current eutrophied state of so many of the UK’s rivers.


If you have answered “other (please specify)”; please explain your preferred alternative.


Give a short explanation as to your preferences.


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? Do you have any further comments?


It would be wise to allow the transition period to be long enough to avoid a “cliff edge” effect, but the shift to a “public goods” approach needs to happen urgently. Realistically the transition will need to take place over several years.


4. 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:


  1. a)  Encouraging benchmarking and farmer-to-farmer learning
  2. b)  Working with industry to improve standards and coordination
  3. c)  Better access to skills providers and resources
  4. d)  Developing formal incentives to encourage training and career 
  5. e)  Making Continuing Professional Development (CPD) a condition of any 
future grants or loans
  6. f)  Other (please specify)


  1. f) Other. If the main system of support for farmers is to transform into a “Public Goods” approach, then the take-up of knowledge and advice is of paramount importance. The evidence for the success of agri-environment schemes – our best example of prior Public Goods approaches, is mixed at best. One of the key drivers of success is the provision of expert support and guidance from professional staff – mainly those within the Government Agencies going all the way back to the Countryside Commission who created the original Countryside Stewardship; and ADAS who founded Environmentally Sensitive Areas. Former ADAS, FRCA and Natural England senior policy expert Steve Peel wrote about what makes a successful agri-environment scheme in this article ( and his years of experience and studying the evidence deserve close scrutiny. Peel’s view is that successful outcomes are only achieved by substantial investment in project officer time guiding, supporting and advising farmers and landowners.


If you have answered “other (please specify)”; please explain your preferred alternative.


Give a short explanation as to your preferences.


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:

  1. a)  Insufficient access to support and advice
  2. b)  Uncertainty about the future and where to target new investment
  3. c)  Difficulties with securing finance from private lenders
  4. d)  Investments in buildings, innovation or new equipment are prohibitively 
  5. e)  Underlying profitability of the business
  6. f)  ‘Social’ issues (such as lack of succession or security of tenure)
  7. g)  Other (please specify)



If you have answered “other (please specify)”; please explain your preferred alternative.


Give a short explanation as to your preferences.


What are the most effective ways to support new entrants and encourage more young people into a career in farming and land management?


It is certainly the case that there are severe limits on the opportunity for new entrants to develop a career in farming. There is a wide range of reasons for this, including the concentration of land ownership in the hands of a small number of land-owners, especially in England. This is in large part due to the fact that farmland is used as a tax shelter. Indeed one expert recently described farmland as the “The greatest onshore tax haven this country has ever seen.” Until the use of farmland as a tax shelter is tackled, farm land ownership will continue to concentrate in ever fewer hands and access to new entrants will be all but impossible. It is also the case that the County Farm network, which once provided opportunities for new entrants into farming, has been substantially sold off by Local Authorities desperate for funds, with little or no objection from Defra.


Does existing tenancy law present barriers to new entrants, productivity and investment?


Do you have any further comments?


Agriculture 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 options by order of importance:

  1. a)  Plant and animal breeding and genetics
  2. b)  Crop and livestock health and animal welfare
  3. c)  Data driven smart and precision agriculture
  4. d)  Managing resources sustainably, including agro-chemicals
  5. e)  Improving environmental performance, including soil health
  6. f)  Safety and trust in the supply chain
  7. g)  Other (please specify)


  1. e) 1 d) 2 f) 3.


If you have answered “other (please specify)”; please explain your preferred alternative.


Give a short explanation as to your preferences.


People Need Nature does not necessarily agree that improvements in productivity is the priority – if productivity means increasing yields of crops per hectare, or litres of milk per cow per annum. This is a very narrow definition of productivity, which creates far more problems than benefits. Productivity for farmland needs to be redefined so it includes the production of public goods like clean water, clean air, healthy wildlife; and well-paid sustainable jobs.


Currently most agricultural Research & Development is spent on improving the narrow definition of productivity. If Defra is really going to shift support towards public goods then it needs to redirect research budgets accordingly.


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:


  1. a)  Encouraging a stronger focus on near-market applied agricultural R&D
  2. b)  Bringing groups of farms together in research syndicates to deliver practical 
  3. c)  Accelerating the ‘proof of concept’ testing of novel approaches to 
agricultural constraints
  4. d)  Giving the farming industry a greater say in setting the strategic direction 
for research funding
  5. e)  Other (please specify)


  1. e) commenting on d) the farming industry already has a great say in how research funding is allocated. Adopting the public goods approach requires Defra to widen the spectrum of contributors to setting that strategic direction – away from a narrow group within agro-industry, bringing in expertise from the environmental, food and health public policy sectors.


If you have answered “other (please specify)”; please explain your preferred alternative.


Give a short explanation as to your preferences.


What are the main barriers to adopting new technology and ideas on-farm, and how can we overcome them?


Do you have any further comments?


Labour: a skilled workforce


What are the priority skills gaps across UK agriculture? Please rank your top three options by order of importance:

  1. a)  Business / financial
  2. b)  Risk management
  3. c)  Leadership
  4. d)  Engineering
  5. e)  Manufacturing
  6. f)  Research
  7. g)  Other (please specify)


If you have answered “other (please specify)”; please explain your preferred alternative.

Give a short explanation as to your preferences.


What can industry do to help make agriculture and land management a great career choice?


How can government support industry to build the resilience of the agricultural sector to meet labour demand?


Do you have any further comments?



Implementing our new agricultural policy in England

5. 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:


  1. a)  Improved soil health
  2. b)  Improved water quality
  3. c)  Better air quality
  4. d)  Increased biodiversity
  5. e)  Climate change mitigation
  6. f)  Enhanced beauty, heritage and engagement with the natural environment


We do not agree with the idea that public goods should be ranked in order of preference, as this is simplistic and ultimately not helpful in developing policy. Such a ranking might suggest that – for instance, increasing biodiversity, would be more important than better air quality. The evidence shows that better air quality increases biodiversity (eg lichens benefit from improved air quality). And increased biodiversity improves soil health and water quality.


These different attributes are related to each other in a complex web of relationships and a linear approach to identifying priorities will not work.


There are some obvious public goods which are also missing from the list – such as alleviation of flooding; and the benefits that nature on farmland provides people’s mental health and wellbeing.


Please give a short explanation as to your ranking preferences.


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:


  1. a)  World-class animal welfare
  2. b)  High animal health standards
  3. c)  Protection of crops, tree, plant and bee health
  4. d)  Improved productivity and competitiveness
  5. e)  Preserving rural resilience and traditional farming and landscapes in the 
  6. f)  Public access to the countryside


We would repeat our previous answer, that these public goods should not be considered as in competition with each other, but rather complementing each other, in a web of relationships.


It is highly debatable whether improved productivity (as in increasing crop or livestock production levels or density) is a public good – especially as it historically has created such profound losses of the other public goods listed. While it is unavoidable that some public goods provision will be in opposition to others, all efforts should be made to avoid trade-offs – rather solutions should be sought which minimize trade-offs and maximize opportunities where multiple public goods can be provided together.


It is disappointing that public health is not regarded as a public good in this context. The provision of sustainably produced healthy food for public consumption should be regarded as a public good. Further, farmland provides other health-related public goods – such as the mental health and wellbeing benefits provided by nature on farmland. This is related to, but different from, public access to the countryside.


The notion that food production or food security (thinking specifically of food security in England and Wales, rather than at international/global scales) are public goods should be resisted, as the Secretary of State has rightly done. Fitting food production (where that food is sold to the market), which is a private good, into a public goods framework, would undermine the principles of public goods theory.


Please give a short explanation as to your ranking preferences.
Are there any other public goods which you think the government should support?

6. 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:

  1. a)  Recreation
  2. b)  Water quality
  3. c)  Flood mitigation
  4. d)  Habitat restoration
  5. e)  Species recovery
  6. f)  Soil quality
  7. g)  Cultural heritage
  8. h)  Carbon sequestration and greenhouse gas reduction
  9. i)  Air quality
  10. j)  Woodlands and forestry
  11. k)  Other (please specify)


We would question why this section only focuses on “enhancing the environment.” Environmental protection (maintaining existing highly valuable features of the farmland environment) must be considered as the primary role of public goods provision, with enhancement happening after the resource has gained protection.


For nature, roughly 2/3 of the existing resource of farmland wildlife (habitats) in England is protected in Sites of Special Scientific Interest (SSSI). This is totally inadequate and there is now an urgent need to protect the remaining resource. Natural England needs the resources and the direction to commence a programme to notify as SSSI all remaining examples of habitats, which qualify for protection. This will take several years and require appropriate resourcing but it is the highest priority action which needs to be taken to save what is left of these wildlife-rich treasures of the countryside. People Need Nature welcomes proposals to introduce Conservation Covenants to protect resources, which would not qualify for SSSI status.


We are also interested in schemes which encourage farmers to adopt sustainable farming practices, using for example auctions as Wessex Water are using in their Entrade project.


Some public goods naturally lend themselves to being provided more effectively when a group of landowners work together. Flood prevention and improving water quality self-evidently need actions taken at a catchment scale, though the catchment for human water abstraction will be different from that where actions to reduce downstream flooding need to be focused. Cultural heritage can only be protected where it already exists. While some historic landscape features e.g. dry-stone walls, will extend beyond farm boundaries, in many cases the public goods need to be protected in specific (and in many cases small) areas of farmland. Conversely, improving soil quality can be applied to all soils everywhere, but it would make most sense to focus on areas and land-uses where soil quality is being drastically reduced, such as areas where Maize growing is concentrated.


If you have answered “other (please specify)”; please explain your preferred alternative.


Give a short explanation as to your preferences.


What role should outcome based payments have in a new environmental land management system?


We believe that wherever possible an outcome-based approach to supporting the provision of public goods should be applied. The Natural England Payment by Results pilots should be extended in 2019 and 2020 to incorporate a much wider range of public goods (this extension to be paid for by the capping/tapering of large CAP payments) such that lessons learnt from these pilots can be applied at the outset for the new support system. Farmers, with the right kind of positive support and advice from project officers, are the best people to innovate and develop new approaches and techniques for the delivery of public goods. A highly prescriptive approach is most likely to put farmers off joining schemes, as has been the case with Countryside Stewardship.


An outcome-based approach does not necessarily mean setting targets for the specific increase in for example population size for a threatened species, or area of habitat. At the Knepp Estate in Sussex, the outcome was for natural processes to become the main driver of change. By allowing vegetation to develop relatively naturally with only minor adjustments to grazing pressure, Knepp has created the conditions for a rich and varied range of different wildlife to develop in surprising and unexpected ways. The Knepp approach is exactly the kind of payment by results approach, which should be encouraged elsewhere.


How can an approach to a new environmental land management system be developed that balances national and local priorities for environmental outcomes?


Priorities should be set locally wherever possible, using a wide range of expertise from within statutory agencies, local authorities, NGOs, and the farming/landowning sector.


How can farmers and land managers work together or with third parties to deliver environmental outcomes?


Farmers, landowners and land managers will only be able to successfully deliver the wide range of public goods, which Society expects and needs from farmland, by working together and working with organisations from the statutory sector, Local Government and Civil Society. This would best be achieved through local forums which have some form of statutory basis, which can support farmers and landowners to identify what public goods they can provide, and how best to achieve that provision.


7. Fulfilling our responsibility to animals


Do you think there is a strong case for government funding pilots and other schemes which incentivise and deliver improved welfare?


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:

  1. a)  Yes
  2. b)  Yes, as long as it does not present an unreasonable burden to farmers
  3. c)  Perhaps in some areas
  4. d)  No, it should be up to retailers and consumers
  5. e)  Other (please specify)


If you have answered “other (please specify)”; please explain your preferred alternative.


Give a short explanation as to your preferences.


*if you answered ‘perhaps in some areas’, please elaborate.


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:

  1. a) Use of regulation to ensure action is taken
  2. b)  Use of financial incentives to support action
  3. c)  Supporting vets to provide targeted animal health advice on farm
  4. d)  Making it easier for retailers and other parts of the supply chain to recognise 
and reward higher standards of animal health
  5. e)  An industry body with responsibility for promoting animal health
  6. f)  Research and knowledge exchange
  7. g)  Transparent and easily accessible data
  8. h)  An understanding of animal health standards on comparable farms
  9. i)  Other (please specify)
  10. j)  N/A – Cannot rank as they are all equally important.


If you have answered “other (please specify)”; please explain your preferred alternative.


Give a short explanation as to your preferences.


How can the government best support industry to develop an ambitious plan to tackle endemic diseases and drive up animal health standards?


Do you have any further comments?


8. 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:

  1. a)  Broadband coverage
  2. b)  Mobile phone coverage
  3. c)  Access to finance
  4. d)  Affordable housing
  5. e)  Availability of suitable business accommodation
  6. f)  Access to skilled labour
  7. g)  Transport connectivity
  8. h)  Other, please specify


If you have answered “other (please specify)”; please explain your preferred alternative.


Give a short explanation as to your preferences.


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?


Do you have any further comments?


Referring back to previous comments about balancing competing public goods, the Uplands provides a case study where support for rural communities (human ecology is a phrase the Environment Secretary has used) could potentially be in direct opposition to protecting nature. Upland sheep farming has had a profound and negative impact on the wildlife of upland England and Wales, particularly in the last 70 years. Sheep numbers are, in places, still at levels which cause damage to upland landscapes and habitats, or prevent habitats from recovering from previous damage. Some would try and draw a direct relationship between intensive upland sheep farming and sustaining upland and other rural communities. Yet it was only in recent decades that upland farms switched from mixed enterprises with cattle, sheep and small scale arable production, to almost exclusively sheep-dominated farming. It was those mixed farming enterprises which supported the wide range of public goods (including but not restricted to wildlife) provided by the Uplands. If public support is extended to supporting rural communities, this support should be conditional on adopting sustainable farming systems, including mixed systems.


9. Changing regulatory culture

How can we improve inspections for environmental, animal health and welfare standards? Please indicate any of your preferred options below.


  1. a)  Greater use of risk-based targeting
  2. b)  Greater use of earned recognition, for instance for membership of 
assurance schemes
  3. c)  Increased remote sensing
  4. d)  Increased options for self-reporting
  5. e)  Better data sharing amongst government agencies
  6. f)  Other (please specify)


This is one of the areas of the consultation, which gives People Need Nature most cause for concern. Effective protection of the farmland environment, and the wider environment where it is affected by activities on farmland, requires a robust and enforced regulatory baseline. This needs to include protection of nature (species and habitats) and natural resources (air, soil, water quality.) This can only be done effectively by state agencies. Outsourcing to private assurance companies such as Red Tractor will not be sufficient, and will lead to a decline of public trust in the system. Applying the “polluter pays” principle, as proposed in the consultation, means that polluters need to be caught and punished as a deterrent to others. Equally, punishing the polluters also helps those who not comply with the letter of the law, but go above and beyond it, to feel that they are vindicated in their efforts.


Effective regulation is needed to underpin the public payments for public goods approach. Failing to create and maintain an effective baseline, risks public money being spent on public goods, which can and should be being provided by law. If resources are wasted on public goods below the base-line, less will be available for the wide range of public goods which sit “above the base-line.” Given that it is likely there will be fewer financial resources available in any future farm policy budget, setting the right base-line is critically important.




If you have answered “other (please specify)”; please explain your preferred alternative.


Give a short explanation as to your preferences.
Which parts of the regulatory baseline could be improved, and how?


How can we deliver a more targeted and proportionate enforcement system?


Do you have any further comments?



10. 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:

  1. a)  Desire to protect themselves from general risks (e.g. – revenue protection)
  2. b)  Desire to protect themselves from specific risks (e.g. – flooding, pests or 
  3. c)  Provision of government compensation for some risks
  4. d)  Cost of insurance
  5. e)  Complexity and administrative burden of insurance
  6. f)  Availability of relevant insurance products
  7. g)  Other (please specify)


If you have answered “other (please specify)”; please explain your preferred alternative.


Give a short explanation as to your preferences.


What additional skills, data and tools would help better manage volatility in agricultural production and revenues for (a) farm businesses and (b) insurance providers?


How can current arrangements for managing market crises and providing crisis support be improved?


Do you have any further comments?


11. 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

  1. a)  Industry, woodland owners and others to respond collaboratively and swiftly to outbreaks of priority pests and diseases in trees?
  2. b)  Landscape recovery following pest and disease outbreaks, and the development of more resilient trees?
  3. c)  The development of a bio-secure supply chain across the forestry, horticulture and beekeeping sectors?


Please give a short explanation as to your preferences


Where there are insufficient commercial drivers, what role should government play in:

  1. a)  Supporting industry, woodland owners and others to respond collaboratively and swiftly to outbreaks of priority pests and diseases in trees?
  2. 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 bio- secure supply chain across the forestry, horticulture and beekeeping sectors?


Do you have any further comments?


While we have no comment to make in response to the questions, People Need Nature does strongly support the comments made in the consultation document about pesticides. We agree that strong regulation of pesticides is essential and that their use should be reduced as far as possible, with much greater emphasis on use of crop rotation, biological control and encouraging natural predators. Defra’s support for the EU’s decision to ban the three main Neonicotinoid pesticides is welcome. Defra also needs to reduce the extent to which Glyphosate is used – especially its pre-harvest use. There is no justification for the widespread use of Glyphosate in crops when there are so many questions still to be resolved about its impact on soil health.



We have no further comments to make in response to the consultation questions.


Posted in Agriculture policy, Brexit, People Need Nature | Tagged , , , , | Leave a comment

We are what we Eat

The old adage “We are what we eat” is only partly true, at best.

We eat vegetables but we are not vegetables. Similarly, those of us who eat meat are, in a real sense, meat – but we are not chickens or pigs. And almost all humans would recoil at just the thought of eating another human.


Perhaps it would be more accurate to say that what we eat defines who we are, what we feel and how we see our place in the world. As I explored in a previous column, whatever we eat has some kind of environmental and social impact. But it is also self-evident that some kinds of food have a greater impact than others.


The Caviar industry, for example, has led to the extinction of the Sturgeon in large parts of its native range – especially in the Black Sea. Elsewhere prawns are mass-produced using slave labour, as well as destroying Mangrove swamps, which are some of the most important habitats for wildlife on the entire planet.


Closer to home, the relationship between what we eat, the kind of food grown by UK farmers, and how those farmers will be supported by the Government, is one of the most important debates taking place now as a result of Brexit. So it should come as no surprise that I will continue my exploration of this debate in this column – an exploration I started here. 

Reports are being published almost weekly now, by various groups seeking to influence that debate in the run-up to Environment Secretary Michael Gove publishing a new Agriculture Bill – which we now understand will appear in “the second half of 2018” – which to me means the Autumn.


At a recent consultation event Gove laid out his views on what sort of food should  be being produced and consumed. He talked about food production being about “health, living longer more fulfilling lives, and a greater connection with the natural world.” He asked (rhetorically) whether farmers should be producing food that was healthy and good for the environment. And he emphasised the impact of the food we eat on our wellbeing, noting that diet and lifestyle were now the biggest factors affecting our health.


Given Gove’s politics it was obvious he was going to talk about how individuals have to make their own choices – whether to eat healthily or not, but he also recognised that Government, while not being the Nanny State, has a role to play – including as “an instrument to remove perverse incentives” – presumably referring to incentives that encourage people to eat unhealthily. He reiterated that he wanted to see a new agriculture policy support high quality food production but importantly, added a caveat


food that’s good for us is good for the planet.” Now this is an interesting idea – and one that can be moulded to a variety of different viewpoints.


The Vegan Society recently published a report “Grow Green: Solutions for the farm of the future” in which they argued that farmers should be specifically supported to grow far more pulse crops  – that is peas and beans, for human consumption.


Peas and beans are very healthy foods – high in protein and also plenty of other essential components of a health diet. Producing them avoids many of the problems associated with animal protein, even aside from the animal welfare issues. Pulses also have a very low carbon footprint and require little or no Nitrogen fertiliser, which is responsible for so much environmental damage, here and worldwide. As the Vegan Society study shows, we used to grow far more pulses that we do now – so some sort of incentive is needed to reverse that trend.


And if you think veganism and the wider issue of people reducing or stopping eating meat is a fringe issue, think again. A recent survey found that 12% of the UK population has given up eating meat. 12%. That’s nearly 8 million people. With a further 25% planning to reduce their meat consumption over the next 12 months. Taken together, that’s over a third of country. And even meat-lover and former vegan-baiting celebrity chef Gordon Ramsay has said he is going to give “this vegan thing” a try.


Others are advocating that people reduce the amount of meat and dairy in their diet, and to be much more selective about how the meat and dairy they do eat, is produced. The Eating Better charity recently published its Eight Principles for better eating, covered here in the Guardian. Eating Better is as sceptical as I am about the use of Red Tractor as an indicator of anything, other than legal compliance; and recommends looking for labels from LEAF, and the Organic certification system. The organisations also looked at what “free range” really means and how important it is to find out where your meat/dairy is produced and under what conditions, if you are going to continue eating it.


The Dairy industry immediately hit back at the report, as you would expect, but it shows they are worried. And it’s not only the statistics on changing diets outlined above, that should make them worry. Recent stories such this one, where a dairy farmer was fined for illegally supplying water contaminated with nitrate fertiliser to his tenants; or this one – where effluent from a dairy farm killed wildlife in a local stream, do the industry no favours.


Nor does the increasing use of Maize instead of grass, to feed dairy cows. Maize, if not grown very carefully, can cause immense environmental problems – from the loss of farmland wildlife, to nitrate pollution, even leading to vital top-soil being washed off fields exacerbating urban flooding downstream. Lush has already highlighted the damage caused by growing Maize for biogas.


The debate around the future of farming in the UK continues to hot up. If you’re interested in contributing your views on how farmers should be supported in future, please send your views to the Environment Secretary Michael Gove at Defra. Various organisations have created easy to use portals to help you send in your views  – sustainable food charity Sustain has one here and RSPB has one here.


If you care what you eat, make your voice heard.

This article first appeared in Lush Times.

Posted in agriculture, Agriculture policy, Brexit, Lush Times, Michael Gove, Uncategorized | Tagged , , , , | Leave a comment

Writing elsewhere

It will not have escaped your powerful observational skills, dear reader, that there has been little going on at “a new nature blog”, for the last few months. Have I given up writing, developed a terrible case of bloggers block, or lost the use of my hands, I hear you wonder.

None of these  – in fact I have been writing as much as ever, but in a different place. It started about a year ago when I started writing pieces for Lush Life – then last September I moved across to Lush Times. Since the beginning of January I have been writing a weekly column – called No Tern Unstoned.

This week I look at the Red Tractor food standard and ask whether it really gives us any assurances about the way uk food is produced.

You can find the article here.


Photo via Wikimedia commons, by Ole Husby from Melhus, Norway – Red tractor (Hanomag C115 Greif), CC BY-SA 2.0,

Posted in Brexit, Food, Lush Times, Red Tractor | Tagged , , , | 2 Comments

The death of Sudan the Rhino points us towards a future for Nature

Albrecht Dürer: Rhinoceros.

Sudan, the last male Northern White Rhino, has died at the Ol Pejeta Conservancy in Kenya. He was 45 and, as part of an unsuccessful breeding programme, had been moved to Kenya in 2009, from his previous home. at the Dvůr Králové Zoo, in the Czech Republic, where he had been living ever since he’d been taken from Sudan when he was two.

Northern White Rhinos had once ranged across Kenya, Uganda and the Central African Republic, but the last wild ones were killed by poachers in the Democratic Republic of Congo, in 2004. Poaching caused the extinction of this particular sub-species of Rhino, with poachers driven by the huge financial returns for Rhino horn, due primarily to its use in Chinese Traditional Medicine, and also for dagger handles in Yemen.

Poaching isn’t the only reason why Rhinos, across the world, are declining and some other species are approaching extinction. The other reason is space – Rhinos need a lot of space; and they don’t fit well into land used by people for farming. They are also renowned for their strength and people tend to think they are dangerous – a threat. Even now there are occasional deaths due to Rhinos, but these are rare. And as the number of Rhinos declines, and surviving populations are confined to protected areas and National Parks, there are few opportunities for Rhinos and humans to come into contact, minimising the risk of accidents.

To an extent, the plight of the Northern White Rhino is emblematic of the disappearance of natural areas, and wildlife populations, across the world. Scientists are increasingly of the view that we are now in the midst of the 6th Great Extinction. The previous five Great Extinctions happened thanks to events such as asteroids impacting the Earth, or great geological cataclysms. This one has been created by our own hands – it is being called the Holocene or Anthropocene Extinction, anthropocene – because humanity’s actions are responsible.

While we in Europe tend to think of Rhinos as exotic animals which only live in the Sub-Tropical and Tropical forests of Asia or the Savannahs of Africa, this was not always the case. The ancestor of Rhinos appeared by 50 million years ago, and by 25 million years ago the planet was “practically teeming with Rhinos”.  Rhinos and other “Megaherbivores” ruled the planet.

During the last interglacial (the period between ice ages), several species of now extinct Rhino even lived in England, along with other giants like the Straight-tusked Elephant. These Megaherbivores were the ultimate Ecosystem Engineers. They created the conditions from which many species of wildlife in England, Britain and Europe evolved.

Woolly Rhinoceros roamed the icy wastes of Ice Age Britain – with one particularly well-preserved set of remains dating to 42000 years ago. Beetles and midges preserved with the animal indicate that the Woolly Rhino was living on Mammoth Steppe – a habitat which occurred across large parts of Europe, Asia and North America during the last Ice Age. Mammoth Steppe was a kind of grassland, different from but related to Arctic Tundra.

Then, around 50,000 years ago, something started to change. Some believe that early humans hunted the Rhinos and other Megaherbivores to extinction. Others point to natural variations in the climate; or perhaps it was a combination of the two. Whatever the reason, by the time the last Ice Age had ended, there were no Rhinos left in Europe to recolonise Britain once the ice had gone.

No Rhinos, no Straight-tusked Elephants, No Megaherbivores. The loss of Megaherbivores happened across the world – in Europe, parts of Asia, and America. What was left was a very restricted fauna, left in a far smaller area of the Earth – the Elephants and Rhinos of Africa and Asia that we think of now as having been so common 50 or 100 ago, were already just a tiny relic of the previous range and diversity of Megaherbivores.

A period of the Earth’s history spanning hundreds of millions of years, when Megaherbivores dominated Europe and the rest of the world, had ended. And as those Rhinos and Elephants and other giants disappeared, a whole range of open-ground species – plants, butterflies, birds and fruit-producing trees, suddenly lost the Ecosystem Engineers that created the conditions those species depended on. Some trees, for example, had depended on those giants to eat their fruits and spread them around, but had now lost the way their seeds were dispersed.

So how did these species of open ground, of grasslands, survive after the Engineers that created their habitats disappeared? Some scientists are suggesting that it is us, humans, who stepped into the footsteps of these giants, and created similar conditions. How? Through the invention of agriculture.

Humans across the world, independently of each other, invented agriculture around 10,000 years ago. The idea is that by clearing the forests and ploughing the soil, the early farmers inadvertently created the same sort of conditions that had previously been created by the Megaherbivores. The actions of Rhinos grazing, rolling around in the dust, or Elephants knocking down and uprooting trees and Hippos creating wallows were all recreated, to a some extent, by farmers.

This has big implications for the future and what we can do, if anything, to stop the 6th extinction, or at least, ameliorate its effects. Rewilding is a big exciting idea to free up landscapes (across Europe) by removing human impacts –  impacts like the effects of agriculture, allowing forest to develop; and reintroducing extinct animals like Beavers, or, more controversially, predators like Lynx or Wolves.

While this approach will restore some natural processes, it will not replace the impact of the Megaherbivores, like Rhinos – whose loss has been partly compensated for by agriculture, over the past 10,000 years. And, of course, agriculture today – with its emphasis on agrochemicals and intensively bred varieties of crops – is not the same as those earlier traditional approaches which could create the conditions where species of open ground could flourish.

What this highlights is that we need to develop a rewilding approach, in tandem with developing  a new kind of agriculture, one which is more sympathetic to nature, works with not against nature and one which incorporates the space and creates the conditions needed by those species which previously depended on Megaherbivores.

This might be a fitting memorial to Sudan, to all of the White Rhinos, and to all the other Rhinos that the Earth has lost.

this article first appeared in Lush Times.

Posted in No Tern Unstoned, rewilding | Tagged , , , | 2 Comments

The Pillar 2 Coup: Rural Payments Agency poaches Countryside Stewardship from Natural England.

Agri-environment scheme farmland near Dorchester. ©Miles King

Last week the Government launched its long awaited “what on earth are we going to do about paying farmers, after Brexit” consultation, called Health and Harmony. At the heart of the new policy lies the principle of “public goods for public money”. No longer will bagless vacuum cleaner billionaires and Saudi princes be able to hoover up subsidies “just for owning land.” There will be a transaction – taxpayers will pay landowners and get something in return – some public goods in the economics jargon.

This is not a new idea. Schemes which paid farmers to look after wildlife or archaeology on their land, or create new areas for wildlife, have been around in Britain since the 1980s, starting with Environmentally Sensitive Areas and Countryside Stewardship. These evolved from modest beginnings, into the Entry Level and Higher Level Schemes (in England) from 2003. These in turn evolved into Countryside Stewardship Mid-Tier and Higher Tier schemes in 2013.

Each scheme in turn had its pros and cons. Entry Level spent a great deal of money across a large area of land delivering very little benefit for nature. Countryside Stewardship has been overly bureaucratic, complex to administer and put a lot of landowners off  joining. Former Natural England agri-environment expert Steve Peel recently wrote eloquently on here about what makes a good agri-environment scheme and what makes a bad one. Let’s hope the Government takes note of this advice before designing the new “One Agri-Environment Scheme to rule them all”  system, which will replace CAP payments once we leave the EU (or some time afterwards.)

Yesterday’s news does not bode well that the advice Steve (or anyone else) offered is being read. Farmers Guardian’s Abi Kay reported that Countryside Stewardship is going to be taken away from Natural England and given to The Rural Payments Agency.

“Natural England staff who worked on Environmental Stewardship and CS delivery will move to the RPA so their knowledge and expertise is maintained.”

According to some people commenting today, staff working on Higher Tier Stewardship schemes (eg on SSSIs) will stay at NE. So the idea that this move is about simplification doesn’t wash. It also begs the question of whether the staff working on Stewardship at NE will have any authority to over-ride decisions made by RPA staff.

But isn’t it a good idea to have all of the admin for Stewardship under one roof? Yes, in theory, but it depends on which roof.

The Rural Payments Agency is notorious among farmers as the organisation which comprehensively screwed up the payment of the as then new Basic Payment Scheme back in 2014. A highly complex new IT system was commissioned to enable farm payments to be moved online. 7 years later the system is still not working properly.

Parliament was scathing in its criticism of the RPA’s failure to effectively distribute basic farm subsidies – criticizing its culture and revealing internal in-fighting. Given the RPA’s central role in making Countryside Stewardship work (they provided the scheme maps) it is perhaps not that surprising that Stewardship also fell over. But this time the blame has been laid at Natural England’s door.  It doesn’t seem inconceivable that, after the beating the RPA received over Basic Payment Scheme, they were going to make sure NE took the punishment for Countryside Stewardship.

This is what seems to have happened now. But this is part of a bigger turf war between Defra agencies. Once Brexit had happened it became very clear to everyone that there was going to be some fundamental reorganisation of Defra agencies – getting nearly £4Bn a year of farm subsidies out of the door is a massive bureaucratic exercise. Once we leave the EU – and the CAP – that job disappears. Since the end of June 2016 the race has been on, to see which Defra agencies come out on top. This news is a strong indicator of who has won.

This hasn’t been helped by the fact that Natural England bosses weren’t prepared to fight the fight  – especially after they took a verbal beating for Countryside Stewardship in front of the EFRA committee (Guy Thompson subsequently left Natural England and now works for Wessex Water). And let’s not forget that the RPA is a much larger organisation than Natural England, and is much more closely aligned with Defra – it could be seen as an arm of Defra. The RPA never had that independence of spirit that characterised Natural England when it was first created – though that spirit has been comprehensively crushed since 2010. So perhaps it’s not surprising that, in having to choose between the two, Defra has chosen to go with RPA.

As far as getting Agri-Environment schemes to create better farmed landscapes for wildlife, or anything else, it’s a huge error. RPA’s culture is administrative, bureaucratic. It’s all about process and compliance. Farmers complain about the excessive administrative burden of receiving farm payments or applying for Countryside Stewardship – they have the RPA to thank. The idea that RPA culturally (regardless of whether their staff are interested, or indeed qualified) will be able to work closely and flexibly with farmers to achieve improvements for nature on farmland is a fantasy. Their motto may as well be “computer says no.”

Meanwhile once Natural England has had its Countryside Stewardship function (and staff) surgically removed, what remains will be on life-support, because that has been a large part of the organisation’s role. Further, the fabled one-stop shop, single point of access approach that Natural England had been required to develop, has just been abandoned. Natural England staff tasked with ensuring Sites of Special Scientific Interest (SSSI) are protected, are now potentially lined up against RPA staff delivering agri-environment schemes on those SSSIs. You can imagine who will win those tussles.

Does all this matter? Isn’t it time to abandon Natural England as a failed quango? Commenting this morning, George Monbiot suggested as much.



Perhaps George is right.

If so, then what is also vital is that the Rural Payments Agency is also abolished before the introduction of the new England Agriculture Policy. We need a publicly-funded independent champion for nature (as Natural England was intended to be when it was set up); and we need a new body which will deliver the public goods for public money approach being advocated by Michael Gove.


Posted in Agri-Environment Schemes, Brexit, Defra, Natural England, Rural Payments Agency, Uncategorized | Tagged , , , , | 6 Comments