Written Evidence submitted by Cornwall Council (SH0021)


Summary and Introduction to Cornwall Council and reason for submitting evidence

Cornwall Council is the largest non-city unitary authority. The health of our environment sits at the heart of our corporate mission and resident priorities. As such, we were one of the first local authorities to develop an Environmental Growth Strategy in 2015 and one of the first rural authorities to declare a climate emergency in 2019, followed by our 2021 ecological emergency declaration. We are also the Responsible Authority for the Cornwall and Isles of Scilly (CIoS) Local Nature Recovery Strategy (LNRS).


We recognise that soil health is the cornerstone of a healthy environment. Soils are a draft Nature Recovery priority for Cornwall, based on extensive stakeholder consultation and set out in our draft LNRS following our role in the Defra Pilots. It states our ambition that soils are protected from erosion, compaction and loss by careful management and efficient use of crops and inputs – capturing and storing carbon, efficiently cleaning the air and water, and harbouring diverse fungi, bacteria and invertebrates.


In Cornwall our soil is deeply interconnected with our economic prosperity, underpinning our farming community and our iconic and beautiful landscapes. In economic terms the agri-food sector in Cornwall accounted for 16.8% of GVA, compared to the England average of 3.8%. A similar picture emerges with regard to employment. 28.8% of employees in CIoS were in the sector, above the 22.4% in Great South West (GSW) and 16.3% for England. The 2021 census recorded 32,936 people in the agri-food sector, equivalent to 12.9% of all residents in employment. The figure for GSW was 9.8% and for England 6.8%.


Over recent decades there has been a significant loss of understanding of the importance of soil health and our wide-spread dependence on soil resources for far more than provisioning services. This has led to a decline in soil health resulting from mis-guided management with a range of effects from soil misuse prevalent throughout Cornwall. For example, around 80% of our agricultural soils exhibit structural degradation1,2,; there is a legacy of contaminated land resulting from historic industry (predominantly metalliferous and china clay mining) 3; and soil erosion contributes to our ‘failing’ water bodies, which are among some of the most polluted in the country 4.


Soils in Cornwall are particularly diverse, influenced by unique and variable geology and the influence of the maritime climate. Soil type can vary significantly from the local to county-wide

scale, requiring targeted management which will only be realised if underpinned by policy

frameworks that create the need for better assessment, understanding and positive action to

prioritise soil protection and regeneration.


The marginality, and dependence of the Cornish economy on our natural environment makes us

particularly vulnerable to the impacts of climate change, which along with urban expansion

(capping) and soil degradation through poor management and land use choices, is one of the top risks to soil health. Additionally, as the land-based and landscape dependant sectors of agriculture and tourism are still predominant in the Cornish economy, we see soil health as a prerequisite for thriving, prosperous and sustainable communities.


Our geography, with sea on three sides, creates a maritime climate that delivers mild winters, higher than UK average rainfall and growing conditions that deliver almost year-round vegetative growth. This enables outdoor field-scale vegetables to be grown all year round and livestock to be grazed outdoors for longer periods. This climatic advantage necessitates policy principles that can take our extended growing season into account and also means that soil health is a significant determinant on both our economic performance and our wider environmental health.


Cornwall Council also acts as landlord to a large county farm estate of 4,370.6 hectares across 89 holdings. This means that we have a direct interest in how our soil is managed and have a duty of care to preserve it.


Cornwall Council will be involved in the implementation of any future Soil Health Plan for England through a number of mechanisms, including management of our own land, either directly or through tenants, implementation of planning policy and controls, activity as the Lead Local Flood Authority and in partnership activities with other organisations.


Cornwall has a strong recent track record in soils health promotion with relevant exemplar

initiatives including the Devon and Cornwall Soil Alliance, Natural England’s EU funded Soils for

Profit scheme and Southwest Water’s Upstream Thinking initiative all running activity here.

Nonetheless, the remaining challenges only demonstrate the need for strengthening the policy base as soon as possible.



How can the Government measure progress towards its goal of making all soils sustainably managed by 2030? What are the challenges in gathering data to measure soil health? How can these barriers be overcome?


Management of soil is a complex subject, influenced by a number of cultural, economic and policy drivers as well as environmental context. The Government’s goal of progressing towards increased sustainable management of soils, recognises that poor soil management is widespread across the UK. The problem isnt just related to agriculture, and indeed the issue of soil health is less well understood in other impactful sectors:

  • Arable soils across England have lost around half of their soil organic carbon (SOC) content.
  • An estimated 80% of agricultural soils in Cornwall have damaged structures, predominantly caused by compaction.
  • The construction sector destroys soil and throws it into landfill at a rate of nearly 30 million tonnes each year.
  • Rates of soil sealing through urbanisation continue to rise at an unsustainable rate despite more environmentally friendly design solutions being available.
  • The proportion of urban front gardens in England that are paved over jumped from 28% in 2001 to 48% in 2011.
  • 6% of the land that Cornwall Council own and manage is deemed to be contaminated, overwhelmingly resulting from the areas industrial legacy predating the Authority and current generations.
  • Cornwall Councill process over 1000 planning applications annually where contaminated land is an issue.


Locally relevant information, policies and incentive flexibility

Because soil is so diverse, aligning soil health to general management proxies is challenging and benchmarks and targets for assessment of soil sustainability should differ accordingly between locations and situations. The measurements that show a soil in Lincolnshire is managed sustainably, for instance, will differ from those in Cornwall, so any framework or policy should reflect this spatial flexibility to support the targeting of actions at a local level.


Soil sustainability manifestos must be created at relevant geographical scales. These should be implemented and monitored through a range of existing and new policies and schemes, including planning policy, nature recovery strategies and the new environmental land management schemes. A Soils Health Action Plan for England, under the Environment Act 2021 could be a mechanism for creating soil sustainability action plans, which could be delivered in partnerships between national Defra bodies and local authorities, or, if suitably funded, through delegated powers to local authorities. Soil management should also integrate into all three levels of the ELMs in a way that measures, enhances, restores and protects soils at each level. The measures in place must ensure that the actions from soil management plans are undertaken and must take local conditions and a changing future climate into account.


A key challenge is incentivising uptake of soil monitoring and improvement schemes. Where the need for data gathering is reliant on the farmer it must consider the practical implications of facilitating this in terms of both capacity and funding. Failure to do so could risk uptake of relevant schemes. The Soils for Profit project, delivered by Natural England with RDPE funding under the SWARM initiative between 2008 and 2013, provides a useful model of how soil health monitoring can be integrated with wider incentives. Here, a farm visit and report on soil, manure and nutrients  was needed to access capital grants to implement the recommendations. This encouraged uptake, whilst also facilitating implementation of progressive practice.


Other key challenges that cannot be ignored include:

  • The impacts of climate change will be felt most on our already degraded soils and will make soil management practices less effective in restoring soil health – research and innovation must continue alongside implementation of new soil health strategies
  • Economic drivers will continue to influence land management decisions, and policy drivers cannot respond quickly enough to economic volatility – education and cultural change approaches will be more effective and sustained over the long-term


Ambitious Definitions and Relevant Indicators

We need an ambitious definition of soil health, that acknowledges that our soils are in desperate need of recovery and celebrates their potential.


Soil health should be assessed at the ‘unit’ scale (relevantly divided within individual farms, building sites, urban areas, woodlands etc.), and the indicators used to assess progress selected on the best-fit basis. The assessment must be holistic so that the overall health and protection of a soil is secured. Questions that relate to holistic management include:

  • Is there a soil risk assessment and plan/map?

-          Soil type

-          % soil cover (space and time)

-          Gradient

-          Pathways and receptors

  • Is a soil sustainability action plan in place and being implemented?
  • Is the use of soil inorganic inputs reducing?
  • Are soils stable, or vulnerable to erosion?
  • Are soil organic matter levels increasing or good?


Gathering this data should be done in collaboration with land managers, and the data gathering process can be harnessed to improve knowledge, information and signpost to sources of support for improving management practices. This requires resources with relevant specialists and could benefit from partnerships between delivery bodies and research organisations.


Remote technologies are useful in quantifying change, however dont have the same potential to effect change as on-the-ground advisers and collaborations.



Do current regulations ensure that all landowners/land managers maintain and/or improve soil health? If not, how should they be improved?


Current regulations dont ensure that all landowners and managers maintain and improve soil health. This is evidenced by the fact that a lot of money is made through practices that deplete soils. In Cornwall, the relatively recent rise of agri-business, compared to an agricultural sector made up of small farm units, has multiplied the influence of profit compared to the influence of individual, farmer/farm manger decisions. The design of regulations to improve soil health needs to clearly identify at which level interventions will be most impactful.


The renewed Sustainable Farming Incentive puts soil health at its centre, and in doing so demonstrates that soil positive practices should be at the core of all agricultural management. The Government has targets towards increased uptake of the scheme, but farmers have been tentative in the transition from BPS and a lack of clarity in early renditions has delayed progress. Farm businesses need stable policy and subsidy frameworks, around which they can manage the range of other variable factors impacting their businesses and decisions. Securing the subsidy framework and demonstrating stability should be a priority for leaders.


Currently, cross compliance and stewardship are seen as key regulatory areas for soil health, however, these are optional. The term ‘Soil Protection’ has fallen out of Cross Compliance since the removal of the need for land managers claiming Basic Payments to complete an annual Soil Protection Review. Since leaving the EU and developing a domestic agricultural policy, the new SFI includes strengthened positive actions for soil-health at all levels. However, there is less focus on identification of risk and because the payments are for generic actions, this has weakened the place-specific element. This should be improved by inclusion of the need to create in-field scale soil risk assessments.


In addition to regulation, it is vital that the necessary support, training and advice is available to farmers and land managers. The farmed landscape accounts for 75% of Cornwall’s terrestrial make up and yet coverage of farm advice is significantly under-resourced and is often disjointed with different advice providers, grant schemes and policy initiatives all operating in the same space. A whole farm business approach would in our view (all advice, payments and grants wrapped up in a single agreement) deliver better outcomes at a lower cost to the farmer and a lower cost to the public purse through lower administrative costs. Our Local Nature Partnership and Local Enterprise Partnership have developed a joint proposal for what this whole farm approach could look like which we have shared with DEFRA previously and would be keen to discuss further if it is of interest.


We have tried to address this need in Cornwall through a platform named ‘Daras, but need additional support and resources to make this way of operating standard procedure. Daras is a one-stop-shop platform for farmers and landowners, created in partnership with the CIoS LNP. The platform brings together funding opportunities, landowners and farm advisors in one space. These types of local mechanisms support collaboration and partnership across the agri-food sector to ensure joined up thinking to restore soil health at a landscape scale.




Will the standards under Environmental Land Management schemes have sufficient ambition and flexibility to restore soils across different types of agricultural land? What are the threats and opportunities for soil health as ELMs are introduced?


The ELMs scheme has the potential to be a powerful and vital mechanism through which to reward farmers and land managers for actions which deliver for food, the economy, for nature and the wider public good.


A key threat weve identified is that the ELMs schemes emphasise a blanket response with standardised interventions across England which dont take into account localised variabilities – for example standardised herbal ley mixes which arent necessarily optimised for all soil types or climatic conditions. Another example would be upland policy in England under the CAP regime. The policy was designed on the assumption that vegetative growth occurs on uplands for around 180 days a year. This worked well for the upland areas in the North of England.  However, on Bodmin Moor our climate allows vegetative growth to take place for almost 250 days a year which meant that the closed periods when stock had to be taken off the moor were too long and therefore when the stock were re-introduced, they were unable to control the vegetative growth.


In response to this threat, we would like to highlight the brilliant results that Cornwall has seen from the AONB FiPL process as a model for integrating local knowledge within agri-funding solutions. The emphasis on farmer-led interventions which have been conceived within an agreed standardised framework, supported with officer capacity, has resulted in better-than-expected outcomes for Cornwall. A similar approach for 2nd tier of ELMs would benefit the rest of the Duchy as rapid and comprehensive take up of the ELMs offer is key to delivering large scale improvements in soil health. If we only get 50% of our land in ELMs agreements, it will be impossible to deliver our overarching objectives for soil health.


Six new standards have been added to SFI, which broaden its appeal to farmers, and this shift was needed, but the detail is yet to be seen as to whether this will result in payments for action or payments for positive change. For instance, will being paid to record a hedgerow condition now actually mean that it is still there in 10 years’ time?


Options included in SFI are directing farmers towards management practices that reduce damage to soils and minimise the risks associated with chemical and organic inputs (pesticides/fertilisers and manures). Together, these should have a positive impact on soils, but monitoring is required to confirm the efficacy. Monitoring and reflective practice should be written into SFI Soil Management Plans. Towards the 2030 soils target, a medium term (i.e. 25/26) expert-led review of stratified-random sample of SFI Soil Management Plans should be carried out, with recommendations drawn up for how these can be improved in future. However, economically there are on farm consequences resulting from this that are exacerbated against a backdrop of increasing pressure from the market at a wider level. Thereby, alienating the farming community from the SFI as payments may not cover the shortfall.



What changes do we need to see in the wider food and agriculture sector to encourage better soil management and how can the Government support this transition?


The majority of our most economically marginal land is so because it has vulnerable soils that become degraded quickly through inappropriate agricultural management techniques and other inappropriate types of land use. Nonetheless, agricultural use of these places can be more supportive of soil health than many other potential uses if the correct land management techniques and operations are deployed. At the same time, focusing agricultural activity on the more productive soil types can mask soil deterioration because yields remain economic even when soil health has declined, at least in the short term. The majority of farmers recognise the need to change the way they manage their land, and whilst there is still room for significant improvement soil sustainability is increasingly being prioritised within our agriculture and food sector and it is important that the market recognises this change and rewards good performance with higher prices in order to potentially offset higher costs and/or lower yields. Unless the UK wants to offshore its food production (and the resulting carbon impacts) we need a productive and profitable agricultural and food sector, but this will not be possible if the degradation of soil continues unchecked.


A key change that is needed is that food production systems will be selected to match the soil, rather than managing the soil to match the food system that is economically in demand. Evidence is now clear that non-conventional food production systems can be productive whilst reducing the risk of soil degradation. Widening the diversity of soil-friendly food production systems contributing to the UK food sector, as well as eliminating soil-negative systems will increase our food, economic and climate security. Soil positive food systems are all designed in a location specific way so that diversity is represented at an appropriate spatial scale. These may include:

  • Permaculture
  • Agroforestry
  • Silvoculture
  • Silvopasture
  • Soil restorative pasture
  • Rotational agriculture
  • Mixed farming
  • Allotments and gardens


The governments can help to support this by providing strategic oversight and mapping of UK soils, including soil type, health (including degradation level and type), pressures etc. and making recommendations based on scientific evidence of farming practices which are best suited to the soil conditions. This can include practices which support the regeneration and restoration of degraded soils. This exercise must be linked to the UKs current food supply requirements, in order to ensure that if implemented we would still be producing the food needed to support a healthy and nutritious diet that is affordable for all. This exercise would also need to take into consideration future climatic conditions, as well as be locally relevant to ensure that any suggestions also match up with the skills in those areas.


When skills gaps are identified, then adequate funding and training will be needed to upskill farmers. Cornwall Council in partnership with the University of Exeter have created Future Farming maps for Cornwall. Learnings from this are that farm advisors are crucial for successful implementation of these tools and in considering the local context however there is a lack of holistic and consistent farm advice and people qualified to deliver it. Likewise, seeing the benefits of practices outlined in SFI in the context of a whole farm system has been difficult for farmers, and there is no nationally respected body to advise on how SFI can be beneficial at the wider scale. Therefore, flexibility must be built-in to provide a suite of options for landowners rather than rigid recommendations which are less likely to gain uptake. 





  • An agri-food sector that celebrates local and seasonal

Cornwall Council is involved with a local growing schemes working group that is working to understand barriers to access and availability of local and seasonal produce and navigate solutions to these.



  • More people involved in food production and food systems at a local scale


Tamar Grow Local is one of many nature-friendly community food producers in Cornwall. It is a not-for-profit cooperative working to revitalise the local food economy and address barriers for small-scale farmers. It provides support and education on growing food in allotments and community orchards and works with business to increase the availability of local produce. Funding streams which support initiatives like these, which are sustainable and encourage long-term success would enable more small-scale community initiatives such as these.


  • Everyone having access to a sufficient, nutritious and sustainable diet


Our Cornwall Plan states that “in 2050, no child depends on food banks for good nutrition, and sustainably produced Cornish food and drink is highly sought after”. However, in 2018/19 16,752 3-day food parcels were given out by the Trussell Trust in Cornwall. Healthy soils are key to growing food which is nutritious. The government must ensure that high quality and nutritious food is the standard for all people. This means that low-cost food shouldnt be to the detriment of the environment, particularly soil quality.


  • More people, particularly children, aware of the links between food-health-environment


Centralised support of events such as Cornwall’s annual Farm & Country event, held at the Royal Cornwall showground. It gives 1500 Cornish primary schoolchildren the chance to experience all the sights and sounds of farming and local food production teaching them about the cycle of food production from soil health all the way to their plate.


  • Food producers being celebrated for social and environmental outcomes


Events such as the Cornwall Sustainability Awards celebrate farmers who are prioritising nature recovery as part of land management through working to increase biodiversity and wildlife habitat to strengthen Cornwall’s nature network. Entrants for the sustainable farming category are judged partially on their successful protection of natural resources including soil health. These awards are a first step towards recognition, but more tangible accreditation on products for successful applicants and winners would strengthen motives to work towards higher environmental standards.


  • Increased collaboration and partnership



  • Peer to peer learning between landowners enabling progressive approaches to farming


Forest for Cornwall will fully fund 10 Agroforestry exemplar sites representing a range of farming practices integrated with trees. These will act as demonstration sites to empower other farmers to undertake similar schemes. At this stage there is an oversubscription of interest compared to funding. Inclusion of trees in the farmed landscape improves soil structure, drawdown of organic matter and reduces soil erosion. Continued support of projects through funds like that of the woodland creation partnership fund give rise to adoption of soil positive food systems.


Further funding schemes which support the creation of peer-to-peer learning, for example facilitation funds for the creation of farm clusters, empowers farmers to work together to make changes which can have benefits at the landscape scale. Funding the extension of projects such as Farm Net Zero (FNZ). The FNZ project team have sampled over 200 fields of FNZ farmers and completed more than 50 carbon footprints. This assist in understanding the impact of the community network on soil health, soil carbon and reducing greenhouse gas emissions on farm. Further to this FNZ assist farmers to deliver events, workshops, training and trials to their peers focused on specific areas highlighted by the community which will increase business resilience through enhanced sustainability.






What does the UK Government need to do to tackle other stressors on soil health such as soil contamination?


Identify and map vulnerable, at risk and high value soils and create protected status for these soils, which would operate in a similar way to protected species. Policy interventions could then be designed to encourage the necessary changes to land management and farming practices.


In 2013, soil carbon losses due to development were estimated at 6.1 million tonnes of CO2. All development over a certain threshold should be required to undertake a soil health risk assessment and adopt a management plan based on the five principles of the Environment Act 2021. Cornwall Council has been involved in the Soil in Construction Task Force, which is taking steps to better inform the industry about soil and develop recommendations (https://www.soilstaskforce.com/_files/ugd/583ec4_160d0162e9ca45dca726ddbd5989d547.pdf).

We have also been pioneers in having our developments accredited by industry schemes for sustainability and biodiversity gain, such as Building with nature, which requires holistic environmental principles and baseline data to underpin design so that impacts can be reduced and positives for both people and environment delivered.


The Defra – Construction Code of Practice for the Sustainable Use of Soils on Construction Sites

(2009), must be updated in light of the Government’s soil sustainability targets – Other Planning Authorities should be encouraged to develop their own targets as well.


Waste classification needs to be amended so that soils can be reused more easily. In 2018, 29.5 million tonnes of soil from construction sites were disposed of in landfill in the UK. Only 0.6 % of this was hazardous, meaning a huge amount is being lost during construction because it legally must be treated as waste. This is 10x greater than the 2.9 million tonnes lost due to soil erosion each year in England and Wales.


Historic soil contamination sites should be considered. For example, soil in Cornwall which has been degraded through heavy metals from mining activity. 6% of Cornwall Council owned land is deemed to be contaminated, overwhelmingly resulting from the areas industrial legacy. Cornwall Councill is currently processing over 1000 planning applications annually where contaminated land is an issue.


The government should provide guidance on how the five principles of the Environment Act 2021

relate to protection and enhancement of soil sustainability, as well as outline clearly how the law

will be pursued to enforce these principles.


The government should also better resource the Environment Agency to support awareness

raising of the five principles and enforcement of rectification at source and polluter pays in

relation to soil sustainability.


At a local government scale, we are researching the effectiveness of the local environmental compliance regime within Cornwall & the Isles of Scilly. The research will pertain to environmental compliance on issues having a direct or indirect impact on the natural environment terrestrial, freshwater, soils and marine to 12 nautical miles.






  1. Soils for Profit Project Report (2013), Natural England
  2. Palmer and Smith (2013) Soil structural degradation in SW England and its impact on surface-water runoff generation Soil Use and Management, 29, 567–575
  3. Cornwall Contaminated Land Inspection Strategy 2020 – 2025 (2020), Cornwall Council
  4. Water for Life and Livelihoods Part 1: South West river basin district River basin management plan


January 2023