Thousands respond to Defra’s Health and Harmony consultation

Tens of thousands of individuals and organisations with an interest in food, farming and rural issues are believed to have responded to Defra’s “Health and Harmony” consultation, in the hope of influencing future policy.

The ideas and priorities now submitted to Defra will be pored over in the coming months and some of it will finally emerge as the new policy for British agriculture outside the European Union.

Here we summarise the key points put forward by some of the bodies that have taken part.

See also: Key points to consider in Health and Harmony consultation

Tenant Farmers Association

Tenancies should be reformed to give growers and livestock producers greater security and incentive to invest in their businesses, says the Tenant Farmers Association (TFA).

Farm businesses tenancies, let under the Agricultural Tenancies Act 1995, lack the necessary security of tenure for a vibrant, productive and prosperous farm industry, argues the TFA, which advocates a series of fiscal changes to stimulate a “more sustainable approach to letting land”.

Recommendations include restricting 100% Agricultural Property Relief (APR) from inheritance tax to landlords prepared to let for 10 years or more – or on new tenancies, including successions, with security of tenure under the Agricultural Holdings Act 1986.

The TFA says the government should also clamp down on landowners who use share farming, contract farming, share partnerships and grazing licences as “thin veneers of trading activity and as vehicles for aggressive tax avoidance”.

Arguing that these schemes are promoted by agents and accountants, the TFA says landlords taking advantage of them in practice “take no risk in the business, have little, if any, entrepreneurial input and lack any management control”.

To further encourage longer tenancies, the TFA says landlords prepared to let land for 10 years or more should be able to declare their income as if it was trading income for taxation purposes. Stamp duty land tax should also be reformed to end discrimination against longer tenancies, it adds.

A further issue to be resolved is “dual use”, which allows landowners to enter land into an agri-environment scheme – and receive the benefits from the scheme directly – even if they have let that same land to an agricultural tenant.

“This practice supports the non-active individual and provides the opportunity for landlords to impose scheme requirements on their tenants who often get no return from the scheme itself,” says the TFA. “These practices must be outlawed in any new arrangements.”

Country Land and Business Association 

While favouring a move towards greater environmental delivery, the CLA is especially wary of a sudden change, such as a sharp drop in direct farm payments following Brexit. It has therefore set out three crucial preconditions:

  1. There must be absolute clarity about the long-term EU/UK trade arrangements before there is any transition away from direct payments
  2. There is a clear plan in place for investing in agricultural productivity during the transition period.
  3. There must be clarity on what will replace the Basic Payment Scheme before steps are taken to start dismantling it.

The CLA is totally against the capping of payments to larger farmers and landowners as part of the process of winding down direct payments, saying cuts should be made in small increments (no more than 20% a year) and spread across all farmers equally. A five-year transition is deemed “reasonable”, while the CLA also sees no merit in retaining “greening” requirements.

It also insists that the current budget for agriculture should continue beyond 2022, while payments for a new environmental scheme should do more than just cover “income forgone” and actually provide a profit to participating farmers.

“It must also come with an effective delivery mechanism which has been shown to work,” it says. The CLA is advocating a system of land management contracts, including a non-competitive “universal” element that most farmers can sign up to, and an “enhanced” element, with extra payments for those who want to take the provision of public goods a stage further.

The CLA favours a new system of “rolling application windows”, with area payments, stand-alone grants and a “light touch” from inspectors.

It has welcomed the recognition of improved productivity and competitiveness as a public good worthy of support.

National Sheep Association

Transition and ending direct payments

The NSA wants a minimum transition period of five years to give farmers time to adapt – and this should only start when there is clarity on the terms of trade with the EU, the new Agriculture Bill is on the statute books, and a food policy agreed. As for direct payments, the NSA wants a “fair” percentage cut across all businesses.

Barriers to progress

A lack of core profitability due to high business costs and comparatively low product prices is holding businesses back, exacerbated by a culture of cheap food prices. Encouraging young people into agriculture is also constrained by a lack of reward. This must be addressed.


The NSA believes it is beneficial to retain as many individual farm businesses as possible, but to seek scale through collaboration. A new policy should encourage farmers to work together in areas of research, land management initiatives (such as water catchment areas and landscape management), and marketing to increase efficiency and negotiating strength.

Farm support

The current budget for agriculture should be maintained and funding redirected to support capital investment, efficiency improvements (in particular a sheep health scheme), and public goods (including environmental and social goods).

Animal welfare

The NSA does not agree with raising welfare standards per se, as this could raise costs in comparison with production elsewhere. But it does aspire to raise welfare “outcomes” through investment in health measures to improve productivity, efficiency, carbon footprints and welfare. 

Devolved issues

A level regulatory platform between all UK nations is needed, with consistent movement and traceability rules and, within reason, comparable financial support programmes and no trade disruption within the UK.


Sustain, “the alliance for better food and farming”, is the umbrella organisation representing about 100 environmental and agricultural lobby groups. Its members include Compassion in World Farming, the Campaign to Protect Rural England, the Family Farmers Association, the Landworkers Alliance, Friends of the Earth, the National Trust and the Soil Association.

It describes Defra’s 64-page consultation document as “uneven”, but says it has some real strengths, in particular its focus on the public goods that government should support via regulation, advice, rewards and disincentives.

Sustain welcomes the focus on environmental outcomes, and soil and water, as well as biodiversity. But it says Defra needs to go further with “delivering public health outcomes”, including measures based on public procurement, mitigating climate change and organic farming.

“We need to talk more about growing more, and sustainable fruit and vegetables, less sugar and growing for sustainable diets, as well as air pollution, pesticides, access to nature and reducing farm antibiotics,” says campaign co-ordinator Vicki Hird. “It needs to offer much stronger support for higher animal welfare.”

Sustain is especially concerned with ensuring greater fairness in farming matters – with a better regulated supply chain to ensure farmers get a fair price. And it favours “a diversity of farm businesses”, with specific help for smaller farmers.

On the phasing out of direct payments during the transition period, Sustain says cuts should be deep enough to generate sufficient funds for new pilot environmental schemes, but the burden should be spread more widely than just capping payments to the largest farmers. It suggests linking payments to employment levels, with the smallest farms exempt from cuts.

Sustain does not favour the removal of “greening rules” as part of the transition, but payments should be made conditional on delivering public goods.

Generally, Sustain has expressed concern about the long-term commitment of the Treasury to support Defra’s ambitions for delivering public goods and a support structure, including grants, advice and better IT.

It also wants farmworkers to be able to negotiate collectively on wages, “as they can in Scotland, Wales and Northern Ireland”.

NFU Scotland 

Even though the consultation is primarily focused on a new policy for England, it does touch on devolved issues, acknowledging the need for some policy divergence, while ensuring the UK single market works properly.

NFU Scotland says it is vital that future agricultural policy meets the distinctly different needs of Scotland. It is especially interested in the frameworks needed to facilitate intra-UK trade and future funding levels for Scottish farming.

“The UK’s various governments should jointly take every step to retain and protect single market access for food, agricultural commodities, live animals and plant and plant products throughout the UK,” says policy director Jonnie Hall.

NFUS is also seeking a clear statement on future funding levels for agriculture and rural development in Scotland. “At least the same level of public investment in Scottish agriculture must be retained and this budget must be ring-fenced to agriculture and rural support.”

Sustainable Food Trust 

The Sustainable Food Trust says it supports the high emphasis on sustainability, animal welfare and using public money for public goods. “If designed in the right way, such a future support package has the potential to correct the economic distortions which currently exist within food and farming,” it says.

However, it cautions against getting rid of area payments per se, because of the “social security element” of the current scheme, which keeps many businesses afloat. “Instead, we believe that many of the desired changes in farming practice would be most effectively delivered through a whole-farm support package, based on land area,” it says.

Such a scheme could include a number of options, some applicable on a field scale, or even whole-farm scale, and some of a more tailored stewardship nature.

The Sustainable Food Trust welcomes Defra’s proposed Environmental Land Management Agreement, which is set to become the main vehicle for delivering post-Brexit farm support. But it is wary that such an approach might perpetuate the separation of food production from nature conservation.

“We feel that the continued structural separation of nature conservation from food production – physically, financially and in the public mindset – will fail to reverse the catastrophic declines in biodiversity and natural capital which have occurred over the last 50 years.”

The trust says it is also concerned about the possibility of significant areas of land being taken out of food production and given over entirely to nature conservation.

“For a country which is nowhere near self-sufficient, this will either result in further increases in intensification on the areas remaining in production or increased imports of food from countries where environmental and public health standards are not as high.”

A new system of conditional area payments should reward/encourage:

  • Crop rotations which include a soil fertility building phase
  • A reduction in the use of chemical fertilisers/pesticides
  • Farming practices which build soil carbon and promote biodiversity
  • High standards of animal welfare
  • Increased employment and staff development
  • Greater sales to local processing facilities and markets.

Soil Association 

The Soil Association has expressed its frustration that, while the consultation is entitled “Health and Harmony”, there is “bugger all” in it about human health.

“The need to reduce farm antibiotic use gets a mention, as does the possibility that access to green spaces might benefit our wellbeing, but there is so much more to it than this,” says policy director Peter Melchett.

“The government is keen on the ‘public money for public goods’ principle, but it has, so far, failed to recognise public health as a public good.”

As such, the Soil Association is urging government to pay farmers to change their practices, including increasing vegetable production, reducing antibiotic usage and getting schoolchildren out onto farms and into green spaces.

Lord Melchett also calls for a change in public procurement policy to support British farmers, “particularly those producing to high quality standards, such as high-welfare food that is good for wildlife and organic”.

“There is still time to stop-the-clock on our declining public health by empowering farmers to join the battle for a healthier Britain. Failure to do so will exacerbate the pressures already on the NHS, entrench already dire diet inequalities, and create not ‘health and harmony’, but worsening ill-health and social disharmony.”


The Agricultural Industries Confederation (AIC) says environmental enhancement must be coupled with agricultural production and support for innovation. Specifically, it wants:

  • A greater acknowledgement of the need for productive agriculture
  • Incentives to reward farmers for balancing production and environmental goals
  • Better education and training, to improve farm productivity
  • Continuous professional development that includes environmental management
  • Research and development that is more relevant to farmers’ needs  
  • Increased sharing of best practice between farmers


A focus on public money for public goods – rewarding farmers who deliver environmental benefits such as more wildlife, cleaner water and carbon storage – presents the best case for ongoing public investment into farming, argues the RSPB.

“A significant increase in investment is needed compared to existing agri-environment schemes,” it says. “Defra should retain, but refocus the overall budget associated with the CAP, in order to drive the restoration of nature that we need.”

Alongside this, the RSPB says the government should develop a Sustainable Food Strategy for England – including measures that improve supply chain transparency, help farmers to get a fair return from the market and promote more sustainable, healthy diets.

Recognising the “urgent need” to rebuild the confidence of the farming community in Defra’s ability to deliver Countryside Stewardship, the RSPB says Defra’s proposed new environmental land management scheme should learn lessons and build on the best of previous initiatives.

Recognising the scale of change faced by farmers, the RSPB says Defra should establish a transition fund to help farmers adapt to life after direct payments. This would provide support for succession planning, business management advice and new entrants.

“Securing a stable transition will be essential in making a success of a new, expanded environmental land management system,” says the RSPB. So too will proper enforcement of rules that maintain high environmental standards.

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