Commentary to Defra: Examining the Financial Implications of Herbal Leys
The farming community has voiced concerns and recommendations in an open letter to David Hill, Defra Director General for Strategy and Water, and Janet Hughes, Farming and Countryside Programme Director. The focus of the letter is the Sustainable Farming Incentive (SFI) action for Herbal Leys.
The letter highlights the benefits of Herbal Leys, such as their potential to produce high-yielding, high-quality forage, reduce reliance on inorganic fertilizer usage, imported feeds, and improve drought resilience. However, it also emphasizes the importance of careful planning to ensure positive outcomes for productivity, biodiversity, and the wider environment.
One of the key recommendations is to allow eligibility for Herbal Leys on a wider range of improved grassland and arable land under the SFI scheme. The letter clarifies that Herbal Leys are intended for improved grassland or arable land, but not for low input or species-rich grasslands, semi-improved or unimproved grasslands, or grassland in protected sites such as SSSIs.
Another recommendation is to maintain the requirement for diverse seed mixes in Herbal Leys. The letter suggests a specific minimum number of grass, legume, and herb species, such as 1 grass, 2 legumes, and 2 herbs for the 2024/25 action CSAM3, and a richer mix for SAM3 2023.
The letter also encourages recognizing Herbal Leys as short-term, lasting about 4 years, part of a sustainable rotational system to support livestock nutrition, soil health, and biodiversity. It stresses the importance of reducing reliance on nitrogen fertilizers and supporting drought resilience and pollinators.
Further recommendations include ensuring that the SFI scheme continues to support Herbal Leys as either static or rotational actions that can be implemented on the same or different parts of the farm each year, promoting flexibility in farm management.
The letter addresses concerns from farmers about delays, administrative errors, and scheme restrictions that have limited uptake or scaled application of Herbal Leys. It encourages Defra to resolve issues such as exclusion of Herbal Leys in approved applications and alignment with longer-term sustainability goals.
To address the risk of incentivizing the conversion and loss of existing high nature value grasslands, the primary recommendation is to implement a new payment rate for moderately diverse grassland at a comparable level to the Herbal Leys payment rate of £352/ha.
The letter also emphasizes the importance of species-rich grassland and the risks attached to the use of herbal leys in the wrong sites, ways, or scales, including damage to valuable habitats and species, lost opportunities for habitat restoration, reduced regional diversity and variety of grasslands, and poor value for public money.
Finally, the letter encourages limiting Herbal Leys and other similar environmental actions to no more than 25% of the farm area to ensure they deliver their intended environmental and productivity benefits without reducing overall food production capacity.
These recommendations underscore the importance of carefully planning Herbal Leys within the SFI framework to maximize environmental benefits, maintain agricultural productivity, and address farmer concerns about scheme delivery and eligibility.
[1] SSSIs: Sites of Special Scientific Interest [2] CSAM3: Countryside Stewardship Action Measure 3 [3] SAM3: Stewardship Action Measure 3 [4] The open letter can be found at [link to the open letter] [5] For more information, visit [link to Defra's SFI webpage]
- The farming community advocates for a broader eligibility of Herbal Leys under the Sustainable Farming Incentive (SFI) scheme, including improved grassland and arable land, to reap the benefits such as enhanced drought resilience and soil health.
- The letter insists on the mandatory use of diverse seed mixes in Herbal Leys, suggesting specific numbers of grass, legume, and herb species to foster biodiversity and support pollinators.
- The farming community urges for recognition of Herbal Leys as a short-term (4 year) and part of a sustainable rotational system to promote sustainable livestock nutrition, soil health, and biodiversity, while reducing reliance on nitrogen fertilizers.
- To ensure the SFI scheme's flexibility and uninterrupted support for Herbal Leys, the farming community recommends allowing their implementation as either static or rotational actions on different parts of the farm each year.
- With concerns regarding delays, administrative errors, and scheme restrictions limiting the adoption of Herbal Leys, the farming community encourages Defra to address these issues to align with longer-term sustainability goals.
- To minimize the risk of conversion and loss of high nature value grasslands, the farming community advocates for a new payment rate for moderately diverse grassland at a comparable level to the Herbal Leys payment rate of £352/ha, and limiting Herbal Leys to no more than 25% of the farm area to maintain agricultural productivity and environmental benefits.