EFA rules – changes and options explained

The European Commission’s decision to “simplify” greening rules by introducing a ban on the use of plant protection products (PPPs) on Ecological Focus Areas (EFA) is forcing many farmers to re-evaluate how best to meet their 5% EFA requirement.

The ban covers all in-field EFA options – fallow, catch and cover crops and nitrogen-fixing crops.

According to the Rural Payments Agency, it will apply from the time of sowing, through to harvesting and growers will also be prevented from using any seed dressings for crops grown as an EFA.

Some of the other EFA options have also been tweaked (see panels).

See also: Grant to help fund livestock and arable precision kit

Edward Hutley, farm consultant in the St Albans office of Strutt & Parker, says the ban on PPPs in England is encouraging people towards the hedgerow, buffer strips and new field strip options, with fallow or catch and cover crops being used to make up any shortfall.

This is a big change to previous years. In 2017, more than half of the BPS applications needing to meet greening requirements submitted by his office had nitrogen-fixing crops as an EFA. Next year, it is looking likely that none of them will.

© Tim Scrivener

© Tim Scrivener

Low impact options

Growers are looking at the options with the lowest impact on current farming operations and ones with a strong weighting when it comes to the coefficient used to calculate the final EFA area.

Peas and beans have been a popular choice since the EFA requirement was introduced – Defra statistics show the area of peas and beans grown in the UK rose from 139,000ha in summer 2014 (pre-EFA) to nearly 230,000ha by 2016.

However, a good proportion of this area would have been planted in order to meet the three-crop rule rather than simply for EFA purposes.

Pulses grown solely for the purpose of meeting the EFA rule are inevitably less attractive if they can’t be treated with PPPs.

However, some growers will be keen to keep peas and beans in the rotation, even if they are no longer used as a greening option, and they will still count towards the three-crop rule.

Management factors

Farmers will make their EFA choices depending on agronomic, management and financial. factors.

For example, cover crops may be the right choice if growers are looking to build soil organic matter or tackle an erosion problem, despite the lower EFA weighting of cover crops, and their establishment costs, which can make them less attractive on paper than some of the alternatives.

Fallow can offer an early entry for the following crop and some may be attracted by the ability to sow a wild bird seed mix as the cover, which has benefits for shooting.

Its strong EFA weighting can also enable businesses to grow two larger areas of more productive crops – useful if the farm is a small acreage, contract farmed or with limited storage.

Check eligibility

Farmers looking to move towards hedges or field strips because their EFA will need to make sure they meet the strict eligibility rules. The guidance notes are lengthy so growers may prefer to seek advice.

Now is a good time to think about which hedges are eligible and whether you can count one side or two. For example, hedges and buffer strips must be adjacent to – or within five metres of – arable land.

Get your calculations done sooner rather than later so you can plan for what you are going to put on your 2018 BPS claim.

It is relatively easy to measure hedges or buffers using Google maps, or other mapping services and this will at least provide an indication of greening values.

When it comes to filling out next year’s claim form, anyone using hedges or buffer strips for the first time should test run the system by adding one hedge into the RPA’s online system initially and then checking that it appears on the greening system correctly before completing the rest.

For full details of EFA options, consult the RPA’s official greening guidance booklet (the 2017 version is yet to be updated for the 2018 scheme year).

In the meantime, the options available to farmers in England for the 2018 Basic Payment Scheme year are broadly as shown in the panels.

This article is based on an RPA update issued in August. and should be treated as guidance only until full official guidance is issued in the autumn.

Fallow Land

This is land which has no crop production or grazing on it, but which is maintained in a state suitable for grazing or cultivation.

Fallow land © Tim Scrivener

Fallow land © Tim Scrivener

EFA period: 1 January to 30 June

Weighting: 1 ha of fallow = 1 ha of EFA

Advantages

Disadvantages

  • Can help control problematic weeds, using cultivations / mowing / topping, which may be important on land affected by blackgrass.
  • Areas are easy to measure when submitting BPS forms.
  • It can be used to take out difficult to manage field corners that are not conducive to modern machinery or less productive parts of fields.
  • Strong weighting when converting to EFA
  • Maintenance costs low if not establishing a sown seed cover – may be as little as two applications of glyphosate (one in December and one at the end of the fallow period in July). But also may be expanded if weed burden requires topping or cultivation.
  • Without the ability to use non-selective herbicides (because of the PPP ban) control of problematic weeds is largely going to be achieved through cultivations or mowing/topping so there may be an increase in maintenance costs. There is no restriction on when cultivation, mowing or topping can take place.
  • Potential complications with land in Entry Level Stewardship and Countryside Stewardship to avoid ‘double funding’ problems.
  • Can affect the yield of the following crop.
  • Can be costly to establish and to buy the seed for wild bird mixes / nectar mixes. Wild bird mix seed can start at £50/ha.

Buffer strips and fields strips

Farmers have thus far been limited to using buffer strips of land next to a watercourse or parallel with and on a slope leading to a watercourse as EFA.

However, for the 2018 scheme year the definition has been extended to include field margins. They can be separated from arable land by a man made feature (fence), landscape feature (hedge) or an ineligible feature (track).

Field margin © Tim Scrivener

EFA period: All year

Weighting: 1m of buffer strip = 9m2 of EFA

Advantages

Disadvantages

  • Help with compliance with LERAP requirements.
  • The 1m buffer strip for EFA can be the same as the ‘1m from the top of the bank’ required under cross-compliance.
  • Cannot be used where a hedge is performing the role of the buffer strip.
  • If adjacent to EFA fallow, the two must be visually distinguishable (eg, different vegetation height).

Hedges

The hedge must be located on or within five metres of arable land, along the longest edge which is at the claimant’s disposal. 

It may be separated from the arable land by a feature that is ineligible for BPS (eg, a track). 

A hedge must be a continuous length of at least 20m but this can include any number of gaps (including gateways) so long as each individual gap is not more than 20m.

From 2018, the EFA option for hedges is also extended in definition to include trees in a line.

Hedges © Tim Scrivener

Hedges © Tim Scrivener

EFA period: n/a

Weighting:

1m of hedge = 10m2 of EFA where both sides of hedge are eligible

1m of hedge = 5m2 of EFA where only one side is eligible

Advantages

Disadvantages

  • Any width or height of hedge can be included, including newly planted hedges.
  • Few obligations in terms of management of the hedges (provided they are not included in a Stewardship agreement).
  • No double funding – EFA is for the presence of the hedge, Stewardship is for the management.
  • More complicated to measure accurately.
  • If the hedgerow adjoins with fallow / nitrogen-fixing crops / catch and cover crops then the area of the latter needs to be reduced by 2.5m2 per metre length of hedge to account for the overlap.

Catch and cover crops

These must be a sown mix of at least two different cover types – one a cereal, the other a non-cereal. 

These mixes should establish and grow quickly to achieve good ground cover.

Grass can be used as a catch or cover crop as long as it was undersown in the previous crop and it is sufficiently established by the start of the EFA period.

Catch and cover crops, Black oat and phacelia © Tim Scrivener

Catch and cover crops, black oat and phacelia © Tim Scrivener

EFA period:

  • EFA catch crops must be maintained for a minimum of 8 weeks starting on 20 August 2018 and must be retained until at least 14 October 2018.
  • EFA cover crops must be maintained at 1 October to 15 January of the following year.
  • Sowing takes place in the summer/autumn after the BPS claim, eg, October 2018 for BPS 2018.
  • Note, the dates for 2017 catch and cover crops for 2017 remain the same as they have been (31 August 2017 to 1 October 2017 for catch crops and 1 October 2017 to 15 January 2018 for cover crops).

Weighting: 1 ha of cover or catch crop = 0.30 ha of EFA

Advantages

Disadvantages

  • Does not take land out of production.
  • Where there is insufficient EFA this can be declared in the May of the claim year and sown after harvest.
  • Can improve soil condition and organic matter as well as help prevent soil erosion.
  • Can help control problematic weeds if a highly competitive mix is sown that covers the ground and uses available nutrients.
  • Good way to conserve soil moisture and even protect it from evaporation by the sun and wind.
  • Possibility to fix nitrogen in the soil by using leguminous species.
  • Only requires a short period to grow the crops so weeds unlikely to come to head, and crop can be destroyed once outside of the EFA period.
  • Short EFA period means a second crop can be grown that can then be harvested to offset the costs of establishment.
  • Undersowing grass could be useful for some farmers.
  • Establishment can be challenging and seed expensive (especially when labour is included).
  • Depending on equipment available and choice of mix establishment costs may be up to £100/ha.
  • Some of the crops that are permitted are prone to pressure from pests (eg, oil radish to cabbage stem flea beetle).
  • Release of biochemicals from some of these crops can have consequences for successive crops.
  • Crop residues can be difficult to incorporate within the soil especially if they have got particularly well established and contain a large amount of material.

Nitrogen-fixing crops

These include crops grown as arable crops (e.g. beans and peas) and pasture legumes (e.g. clover, lucerne and sanfoin).

In addition to pure stands of a nitrogen-fixing crop growers are allowed to use mixtures of different nitrogen-fixing crop species; or mixtures of nitrogen fixing crops and other crops, as long as over 50% is nitrogen-fixing crops.

Nitrogen fixing clover © Tim Scrivener

Nitrogen fixing clover © Tim Scrivener

EFA period: 1 May to 30 June  (although the ban on plant protection products applies to the entire duration of the crop)

Weighting: 1 ha of nitrogen-fixing crop = 0.7 ha of EFA.

Advantages

Disadvantages

  • Benefits the following crop by raising nitrogen levels in the soil – uplift can typically be in region of 30kg/N/ha in following crop.
  • Little change to rotations as these crops are already grown.
  • Additional income generated as crops can be harvested.
  • Without plant protection products, it will be challenging to keep the crop free from pests, disease and weeds. So yields likely to be impacted and end market for produce limited as may struggle to capture human consumption quality without insecticides.
  • In the longer term, potentially higher levels of soil-borne diseases could affect legume crops grown as part of a rotation.

Scotland, Wales and Northern Ireland

While the EFA options in Scotland, Wales and Northern Ireland come under many of the same headings, the management rules which apply vary quite widely from those in place in England

For example, minimum widths and the dates on which crops must be in place differ between the different countries.

Claimants in the devolved countries will need to check with the relevant authorities for an update on how EFA rules will change in 2018.

See the main changes for Scotland’s EFA requirements.

This article is based on an RPA update released in August – full guidance is yet to be released.