Environmental Impact Assessment Regulations in Welsh Horticulture

Did you know, in Wales, if you want to plant an orchard, establish a vineyard, or set up a market garden, you might need permission from the Welsh Government?  Really? Yes, really.  Even if the land is yours; even if it’s been in your family for donkey’s years: you’re not free to just do as you may wish with it.

There are lots of reasons why this is the case, this post focuses on the snappily titled “Environmental Impact Assessment (Agriculture) (Wales) Regulations 2007”.  Environmental Impact Assessments are generally referred to as EIAs.  And in fact, these Regulations (in the context of horticulture in Wales) actually rarely deal with actual Impact Assessments.  They deal more with assessing whether or not an Assessment is required.

Whether you agree with the Regulations or are outraged by them and see them as an infringement on your liberties, they are something you need to know about if you’re planning to start-up in horticulture. 

The Welsh Government provides quite comprehensive advice and guidance on the regulations and their interpretation at http://wales.gov.uk/topics/environmentcountryside/consmanagement/conservationbiodiversity/eiahome/eiadocs/?lang=en.  You can also speak to Welsh Government officers who deal specifically with EIA and are generally very helpful (yes, honestly, they are).

In brief, the rules say that if you are “intensifying” production on an area of “semi-natural” or “uncultivated” land, you need to ask permission first.  However, the definitions of these land types are specifically rather vague.

That may be it: you might ask, the Welsh Government might say, ‘no problem’.  Or, they might want to look a bit harder at your land and your plans, and then say it’s ok for you to go ahead.  Or, they might say that you need to carry out a “scoping” exercise to identify the likely impacts of your activities and produce an Environmental Impact Assessment of them.

Tiresome as complying with these requirements may seem, it is in your best interests to do so.  Failure to comply could be costly in the long run.

You may wonder how the Welsh Government would ever know what you’re up to, especially if you’re halfway up a hill in the middle of nowhere.  But the Welsh Government has extensive and detailed aerial and satellite images and data for the whole of the country.  And an army of interested parties is always ready to report any potential breaches to the officials.  The chances are that at some point in time, your new orchard, vineyard, field of potatoes or whatever, is going to come to the attention of a Government official.  The worst case scenario could mean that you have to rip up all your planting and reinstate the land to the condition it was to previously (insofar as that is possible…).  All at your own expense, and with no compensation.

So, the lesson of this rather dry story is be aware and beware.


Why is Hoplia philanthus called the Welsh chafer?

Welsh chafer (Hoplia philanthus) on Miscanthus

It seems to be a bumper year for chafers of all types. 

The emergence of these beetles always seems like a blessing to the birds who flock to devour them with gusto and to take them back to their greedy broods.  In the garden, they are a favourite fast food for blackbirds and even dunnocks and robins are happy to have a go at them, although they make a mighty mouthful for those little guys. 

Out in the fields and down on the dunes the air is literally buzzing with the little beetles and flocks of gulls, rooks, jackdaws and crows are making the most of them.

So, I got to wondering, why is the Welsh chafer so called?  The fab interactive map provided by the National Biodiversity Network (http://www.searchnbn.net/imt/?mode=SPECIES&species=NHMSYS0001718473) shows that they are not particularly prevalent in Wales, and indeed are widespread throughout England.  And descriptions of their life habit state that they prefer sandy soils – which aren’t that abundant in Wales.  So far, I haven’t been able to find the answer.

In general, these chafers are not a serious pest.  The bumbling adults will chomp on the edges of almost any vegetation, but they’re not around for long and don’t really do much damage (especially if the birds have their way).  Sometimes, but not usually, the grubs which develop in the soil and munch on plant roots, especially grasses, can be a bit of a nuisance, but on balance, if possible, try to leave the birds to sort them out.  They emerge just when the birds need a hearty feed for their hungry broods.

Also, beware if you pick a Welsh chafer up for a closer look, they are very quick to sink their jaws into anything that comes their way, including fingers.  It doesn’t really hurt, but it is quite a shock to feel the little guy chomping down on you and it will then hang tenaciously from wherever it has sunk its jaws!

Grafting fruit trees

Spring is stirring and it’s time to get grafting.  More particularly, to get on with grafting apple trees.

Grafting has been going on for thousands of years.  Possibly originating in China, it was certainly commonplace in ancient Greece and the Roman Empire. 

Simply put, grafting involves splicing a rootstock and a scion (or shoot) together.  Provided it is done correctly, the cambium (the actively growing part) of the rootstock and the scion will readily fuse together and produce new phloem and xylem (the tubes that transport food and water in a plant) that run smoothly between rootstock and scion.

The scion wood comes from the tree that you wish to grow – e.g. a particular variety of apple.
Rootstocks are chosen for the characteristics that they will confer on the scion wood.  The main focus is on the size of tree the rootstock will produce, but much work is also done to develop rootstocks that confer some degree of disease or pest resistance through to the scion wood.  The rootstock also has a strong effect on the longevity of the tree: in general, rootstocks that produce a dwarf tree (e.g. M27) will be shorter lived than full-sized standard trees.  Most rootstocks used commercially for apples in the UK are known by an M number – e.g. M27.  The M refers to the East Malling Research Station where the rootstocks were originally bred and developed.  

Why bother?  As mentioned, grafting to a rootstock gives you control over the size and some elements of disease and pest resistance.  Moreover, it ensures that your crop tree will come true.  If you plant an apple pip, you’ll never really know what tree will result – it’s likely to be a hybrid (due to pollination) and is also, quite probably, going to produce inferior fruit.  Finally, grafting speeds up the propagation process.  In a couple of minutes you’ll have a small tree.  If you planted a pip, you’d wait two or three years to get a sapling of the same size.

Why not just root cuttings?  Well, you can do this.  However, by doing so, you won’t be gaining the benefits that a specially bred rootstock could bring (control of vigour, disease resistance, etc.).  What’s more, many of the tastiest apples either do not have a very good natural root system themselves, or they have such a prolific root system that within a few years your tree will have grown so vigorously you won’t be able to reach the fruit anyway!

Although February and March are the main times for grafting with scions, you also get a second chance for propagation during the summer when “budding” or bud grafting can be used.  For this, rather than using a stem from the parent tree, only a bud is needed.  This method is particularly popular with commercial propagators because they can bulk up their material very rapidly; just think how many buds are on one branch.  It’s also a useful way to save the genetics of old trees that may have become too gnarled and unproductive to take a viable scion from.

There is a wealth of information on all types of grafting on the internet.  Here in Wales, Paul Davis of Dolau Hirion Nurseries is one of the leading experts on all things apple and has some great information on his website.  If you don’t feel confident to graft your own trees, Paul offers a grafting service.

Food safety – quality assurance for growers

Hypothetically speaking, if someone fell ill as a result of a food-borne pathogen (perhaps e-coli or clostridium) after eating your produce and the finger of blame was pointed at you, how confident would you be that you were in the clear? And how easily could you convince the authorities of this?

Nobody likes unnecessary paperwork and bureaucracy, but in a situation where your production processes are being called into question, having a robust set of procedures in place with appropriate records and documentation will be your first and strongest line of defence.

In the UK, if your produce is going to one of the major retailers, they will insist on you having appropriate production, harvesting and storage protocols in place before they will buy from you.  This may seem like an unnecessary burden and cost, but it protects you as well as the retailer and ultimately the consumer.

Those who sell via other routes (e.g. to wholesale, direct to the consumer or via independent retailers) will seldom be asked to produce evidence that “due diligence” has been used at all stages of producing their crops.  While this is a “nice” and “friendly” approach that often relies on trust, it will be of no use at all if something goes wrong.

Putting food safety quality control processes into place doesn’t need to be overly complex, nor does it have to be costly.  There is no particular reason why you should use a paid for accreditation system if you don’t need or want to.  The advantage of using one of the recognised accredited systems is that they are “fit for purpose”.  That provides an enhanced level of confidence to both you and your buyers.  But if you want to set up your own system there is nothing to stop you, and any kind of system is better than none.

Even with the best systems in place, things sometimes go wrong.  Having a food safety quality control system in operation is not a cast-iron guarantee for your produce.  What it does do is demonstrate that you have considered the risks and put into place measures to address them. Doing that is a legal requirement as a primary producer: but without documentation how can you ever demonstrate that you were acting with due diligence?

Don’t take risks with your business or your customers’ health: put a food safety quality control plan into place and into practice now!

For further information visit:

Selling culinary herbs – things you need to know first

Herbs are one of the most pleasurable crops to grow.  They’re also great for selling, but, there are some tricky legislative considerations you ought to bear in mind if you are selling herbs.  The legislation may be infuriating, but it’s also bizarrely interesting.  For example do you know which herbs are “allowed” to be sold by the bunch, rather than by weight?  Read on to find out…

Primary product or food
Since 2006, the EU Food Hygiene Regulations have applied to primary producers (i.e. growers and farmers) as well as food producers and processors.  Culinary herbs fall under these regulations.  In their raw, unprocessed state, culinary herbs are primary products (not food).

The regulations mean that as a primary producer you have a duty of care to ensure your produce is fit for purpose.  Particularly you must avoid it being contaminated by things like soil, chemicals, non-potable water, etc.  You must keep records that demonstrate how you have ensured the produce is as safe as possible.  This will include detailed records of any plant protection products used, when they were applied, why, at what rate, etc. – this type of record should always be kept anyway if you are using sprays and chemicals. 

If your holding doesn’t already have a Customer Reference Number (CRN) or County Parish Holding Number (also known as a CPH number, or Holding Number) you will have to register with your Local Authority as a Primary Producer.

When is a herb a food?
Primary products become food once they have been processed.  In general, fresh herbs sold with little or no processing will remain as primary products.  However, dried herbs are considered to have been processed and are therefore classed as food.  Food products have far more onerous regulatory requirements than horticultural primary products.  Washing (with potable water) and trimming will not usually be considered to turn a primary product into food, but do check with your Local Authority to find out how they interpret the Regulations

By the bunch?
Most foods must be sold by weight, but chives, mint, watercress and parsley can be sold by the bunch, without a weight.  For other herbs, if sold in weights of more than 5g (about 1/6th of an ounce – almost nothing), you get into the realms of selling by weight.  For this, you need to make sure that you have suitable scales with calibration records to prove their accuracy.

There are many sad stories of producers printing off sheets of labels only to be told they were non-compliant and therefore unusable.  Labelling regulations are complex.  Essential information for pre-packed herbs is: the name of the herb (plus any additives if appropriate); the business name and address; and the net weight of the product.  For packs of up to 50g the writing must be at least 2mm in height.

Do the regulations always apply (is there wriggle room)?
Direct supply by the producer to the final consumer or to local retailers may fall outside the scope of the Regulations.  However it’s always better safe than sorry, so you should use best practice and comply as far as you possibly can anyway.  Ignorance is no defence in the eyes of the law.

Because the regulations are so complex, you should seek more advice from your local Trading Standards Office (about weights & measures, packaging, etc) and Environmental Health Office (for food hygiene information).  They are almost always helpful and friendly.  They would rather work with you and avoid problems arising than have to take enforcement action.
This information is provided as general guidance only and is no way comprehensive or a replacement for professional advice.

Gross margin information – a help or a hindrance?

Some people swear by gross margin information, others think it is misleading and pretty much irrelevant.  But, if you’re starting out in horticulture, or considering diversifying into a crop you’re not familiar with, gross margin information is probably going to be a key starting point for you.

But it should be just that: a starting point.  It is important not to read too much into the gross margin information.  And it is vitally and hugely important that you don’t underestimate the costs that are not included when working out a gross margin.  A common failing in business plans of new enterprises is underestimating overhead or non-divisible costs. Those are the costs that are not taken into account when calculating the gross margin.

Gross margin calculations consider the variable costs associated with producing a specific crop.  So, they will take into account operations specific to the crop, for example, cultivating, drilling, weed control and harvest.  They will not take into account contributions to costs like rent or mortgage payments, interest payments on any loans, running the office, paying your accountant, depreciation, insurances, etc.

It is easy to get taken in by a headline gross margin figure, but don’t do it!  Think harder and deeper.  Gross margin is not profit.

Another thing to bear in mind is that gross margins are generally quoted as a per annum figure – e.g. gross margin per hectare per year.  Not all crops occupy the land for the same length of time.  So, it is also important to take time into the equation.

A perennial crop like rhubarb or globe artichokes is going to be occupying your land all year round.

By contrast many summer salad crops will go from seed to yield in only six weeks.  With these crops, you’ll be able to have multiple harvests (either by using cut-and-come-again varieties or by resowing).  And with careful planning you’ll be able to follow them with a crop for late-winter or spring harvesting.  The gross margins of all these crops are then additive for that plot of land.

And finally, remember to consider where the gross margins you’re looking at have come from.  In general, the most widely published information comes from quite large scale, fully commercial operations in the main production areas of a country.  If you’re thinking of growing a small area of a crop with minimal machinery, data derived from hundreds of hectares of mechanised production are just not going to be of relevance to you.  Sometimes, you’re just going to have to sit down and work things out yourself!

Overcoming the labour shortage in horticulture

Research in Wales has repeatedly found that a lack of available labour is an impediment to horticultural business growth.  Informal discussions with potential employees (students, un- and under-employed) indicate that two factors have a strong impact on this:

Firstly, potential employees are unaware of opportunities with local growers.  Advertising in the press is not cost-effective for short-term posts.  Advertising positions with the Job Centre seems ineffective and often results in candidates who are uninterested in work applying for posts to meet the Job Centre’s requirements rather than because they have any interest in the position.

This problem of promotion is one which could be overcome relatively simply. 

The second factor adversely affecting recruitment in the horticultural sector is the perception of poor terms and working conditions.  It is undeniably true that some horticultural work is physically demanding, has to be done in horrible weather conditions and is mundane and repetitive.  But one of horticulture’s strongest points is the huge diversity of jobs that are available in it.  Growers need to raise awareness of this diversity.  And even for the most back-breaking, finger-freezing work, there is a willing pool of would-be employees, if they only new about the opportunities.

A more intractable problem is that of pay.  Margins are tight for many growers, so they feel they cannot afford to pay better wages.  But a better pay offer, coupled with the right terms and conditions, is an investment that will yield returns.  There will be less staff turnover (churn) –which is costly in terms of training, recruitment and morale; and there should be improved productivity.  Taking both of these into consideration, investing in improvements to employee terms and conditions may well be one of the best options for a grower.

Wage data are notoriously difficult to analyse.  However, Defra’s data for Agriculture and Horticulture Wages suggest that, when inflation is taken into account, wages for full-time female employees in 2009 were nearly 6% lower than they were five years earlier.  The figure was similar for full-time male employees, but they did earn more than 10% per hour more than their female colleagues. 

Rather than joining the race to the bottom, growers would be well advised to strive to be the best employer they can.  People need nurturing as much as plants.  People management is one of the trickiest parts of business, but getting to grips with it is one of the primary keys to success.