Written Evidence submitted by The Agricultural Industries Confederation (AIC)(SH0023)

The Agricultural Industries Confederation (AIC) is the agri-supply industry’s leading trade association with over 230 Members in the agri-supply trade and represents over £9 billion turnover at farmgate. AIC represents several sectors within the agri-supply industry including: Animal Feed; Crop Protection and Agronomy; Fertilisers; Grain and Oilseed and Seed.

1. 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?

HOW TO MEASURE SUSTAINABLE SOIL MANAGEMENT:

Soil is a complex issue. Government acknowledgement of this and that its management needs to be ‘tailor made’ by those responsible for it considering the soil type, land use and landscape and prevailing weather patterns would be welcome. No one size fits all and it is impossible for survey data alone to present a full picture.

Some general principles and established methods for measuring/indicating the physical, chemical and biological state of soils and changes in management practice can provide useful national trends, however. The current science-based methods available and private industry/Government guidance broadly give farmers, land managers and the registered professionals advisers the tools they need.  Whilst soils are complex, it is not complicated to manage to them well over a period of time assuming soil sampling, soil management guidance and campaigns are proactively followed across the country.

It is clear that there are challenges to soil protection around the UK. This said, there are local examples in farmed landscapes and crop management situations revealing problems which can be solved. There are few who could disagree that it is imperative to remedy soils back to a healthy and resilient state as resilient environmental and economic outcomes depend on it.

It must not be forgotten in future reporting of soil management that crop yields come from good, fertile soils – a degraded soil cannot sustain yields. There is scientific evidence that arable soils naturally have a lower equilibrium level of organic matter content than grasslands. This is not necessarily to be thought of as soil damage but is a state resulting from cropping patterns.

In all soils the percentage organic matter (OM) changes towards a stable or equilibrium level. In long term Rothamsted arable experiments, the soil OM in the top 23cm is 1.7% and has not changed in the last 100 years.  In permanent grassland experiments it has been 5% for the last 300 years. The equilibrium depends on four factors i) the amount of OM added each year ii) the rate of breakdown of the added amount and background levels iii) soil texture and iv) climate. 

Factors i) and ii) depend on the rotation which can be altered to raise OM content- a goal supported by AIC.

AIC would urge Government to fund the extension of the existing Countryside Survey monitoring of soils to build on the information already collected (including adding subsets of data for carbon at 1 metre depth). This was the consensus view of wide-ranging group of bodies[i] in 2018 including AIC, the agri-supply and advisory sector, farming bodies, companies operating in the food chain and academics.  We are not aware of any developments to progress this action, following these discussions which were also attended by Defra.

Of equal importance are funds for excellence in the interpretation of the information collected alongside a review of complementary and supplementary evidence from:

Catchment Sensitive Farming Monitoring and evaluation reports, Game and Wildlife Conservation Trust’s Allerton Project, British Survey of Fertiliser Practice including manures , Defra Farm Practices Surveys, Environment Agency State of the Environment Soil report, RASE report, Shades of Green and 250,000 soil sample results from UK soil labs and data which the private sector are increasing collating, as soils become a priority in setting of food chain sustainability targets. 

CHALLENGE

Apart from the funding gap for further monitoring of soils (to date, lagging behind monitoring for water and air), our knowledge base in interpreting data to produce a balanced picture of sustainable soil management is gradually being lost and needs addressing for the longer term.  The current challenge requires pulling together a consortium of expertise from various disciplines to come together and agree an overall view for soil and management.

The 2030 target for sustainable soil management is only 5 years away, and to achieve the task of Government reporting with integrity would require early funding of activity similar in design to the public and private sector model/effort to creating the UK greenhouse gas and ammonia inventories.

BARRIERS (& OPPORTUNITIES):

Local knowledge is priceless and seldom accounted for. Case studies and anecdotal evidence from those who advise farmers and landowners over large areas of land is as valid as survey data and should be referred to in Government reports.   The positive evidence is as important to present as where soil degradation is an issue, as this drives progress by those responsible for managing and caring for our soils for future generations.  

WHAT TO MEASURE

There are four basic means of measuring/indicating whether soils are being managed sustainably in farming. These are accepted by the agricultural sector:

i)                    Visual assessment of the physical integrity of the soil structure and condition

ii)                  Level of microbial activity, and the organic matter content (which is calculated from the total carbon content multiplied by 1.72) - relative to optimal/equilibrium level for soil type & land use.

iii)                 Soil pH and balance of fertility for the habitat or cropping system

iv)                 Crop, forage and grass yields

As mentioned above, measurement is only part of the story to derive meaning from data collected from the Countryside Survey, it is necessary to relate the information gathered from a soil sample to land use management, and to make an assessment of whether the status of soil is capable of sustaining a management practice or purpose. Creating a land capability scoring index with the soil sample would provide useful intelligence on the resilience of a soil.

In addition, the propensity for soil damage from extreme weather events or activity would be useful to record along with the soil sample and land management assessment. Evidence already gathered from the Catchment Sensitive Farming catchment advice and monitoring programme may give insight.

It is worth noting that not all soil movement is preventable and that some of the most fertile alluvial plains for agriculture are the result of natural processes. The key thing to understand is what we can do to support our soils to be more resilient to damage and to be able to repair in the event of it (considering recent and future patterns rainfall events and temperatures forecast by the Meteorological Office)

We can support soil resilience by investing in the soil’s living organisms. Soil rich in organic matter has the ability to repair and this is something that can be enhanced by feeding the soil’s biomass in tandem with the crops we grow. 

It is worth noting that certain soil types such as light, sandy soils may still be capable of sustaining increasingly high yields at relatively low levels of organic matter, therefore it can be questioned whether this is necessarily unsustainable practice in terms of its purpose.  However, constant good soil management is required by way of cultivation practice and run-off mitigation to maintain the resilience of these lighter soils and the cropping systems they sustain.

Perspective is important to Government reporting of the status of sustainable soil management and therefore should include information and data on soils not at risk as well as those that are. 

The ideal soil condition and management will depend on soil type and character of the subsoil; making comparisons between soil types in Government reporting would not be helpful. The important point being that it is managed according to its character, resilience and fragility.

CHALLENGE:

While there are user friendly farm tools, capable of measuring soil microbial activity, there are no agreed analysis methods for measuring categories of life e.g. those that breakdown residues, bacteria which associate with plant roots or mycorrizae fungi. Research into producing new laboratory methods and standards is required to add to our understanding of biomass populations and then to eventually build this into the Countryside Survey monitoring.

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

Overall, the AIC would agree that regulations do ensure this. The current regulatory frameworks for protecting water from excess nitrogen and phosphorus losses from soils, Farming Rules for Water and those in development for improving air quality include requirements for proactive soil management. These aim to protect physical and chemical quality, and indirectly soil biology benefits from the improved soil condition in which the biomass population can grow and thrive.  Future regulatory reviews would enable any specific amendments or additions to be made for soils, if found to be necessary.

There has been lengthy debate, over many years, as to whether specific regulations for soil are necessary or indeed possible to formulate and enforce. While the drive to build soil biomass is beneficial (and will improve soil resilience) enforcement, site specific relevance and measurement would be impractical.

If malpractice is an issue, the Environment Agency has sufficient powers already to protect soils, though enforcement notices to prevent, change, or rectify soils which are vulnerable.

The requirement for further regulations also needs to be considered in the context of other positive drivers for soil:

1. The current political, social media message and trend to place soil and resource conservation higher up the priority ladder.  A stepped change to invest in the soil has been prompted by volatility in the market affecting fertilisers and the situation in Ukraine
2. Widespread awareness across the agricultural sector of more frequent, less predictable and intense variations in the weather and the need for soils to be more resilient to their effects
3. The imperative to feed crops sustainably and affordably (farms need to be in profit to invest in soil)
4. Sector wide call to action for improving soil nutrient balance accounting for optimal pH and all crop nutrients (Nitrogen (N) supply, Phosphorus, Potassium reserves and Calcium, Magnesium balance, S availability and the ratio to N supply, etc.) given that the overall balance of nutrient availability is essential to improving the efficiency of crop uptake, and also to feed the diverse biological life of the soil;
5. The widespread press and farmer to farmer conversations of beneficial effects of building organic matter and nutrient status with cover crops, green manuring and composting

The package of activities which already exist (including a complementary mix of Catchment Sensitive Farming (CSF), industry-led nutrient management and soil advice and adoption of incentives for more effective use of organic materials and a clear transition plan) should bring the outcomes for soil quality without the need for additional regulatory drivers, which would arguably be of little overall benefit or impact. 

Industry campaigns, roadmaps and sustainability targets set by the food chain, should prove effective considering the financial consequences and reputation damage of not supporting sustainable soil management and improving Farm Nutrient Balance

Will the standards in Environmental Land Management schemes have sufficient ambition and flexibility to restore soils across different agricultural land. What the threats and opportunities for soil health as ELMS is introduced.

Rewarding farmers for action taken after a Soil Protection Review, alongside making proactive changes on the back of a Nutrient Management Plan would eventually be more productive than a claim for an administrative act. We know this is difficult to enforce but spot checking of farm records would be all that it is required.

In future standards, there is scope for incentivising liming of fields with the aim of maintaining land at the optimum pH for the rotation. pH is key to the physical, chemical and biological balance of the soil (this would provide a win- win for nitrogen efficiency, nutrient uptake generally, net zero goals and air quality).  Rewarding farmers for avoiding tramline shift and their compaction affects, and for using the equipment which helps e.g. (controlled traffic farming, floatation tires, precision technology etc.) could be pursued as a policy aim or outcome.

THREATS:

UK soil laboratories (through the Professional Agricultural Analysis Group (PAAG) have expressed their concerns over access to laboratory supplies (as a result of EU Exit and global availability of goods) and capacity in light of increasing demand on soil laboratories, for soil analysis and incentives for carbon measurements.

AIC would urge Government to have a good understanding of the practical constraints on soil labs to be able to deliver the volume of work that is potentially expected of them.

In ELM, timeframes are tight to demonstrate the results of positive action. Government will need to show trends in uptake and practice through ELMS and be aware that actual change in soil quality/condition will take time to be revealed as soil changes relatively slowly.  There is a concern that maintenance of good soil management soil health will be considered as ‘no progress’; often this will be progress in so far as not allowing the soil to degrade. It is important to not allow short term results to influence necessary long term investments to soil.

Similarly, the intensity of weather events can undo progress made on individual farms. Improved Catchment Management Planning (for all land use and management) will therefore be required to mitigate the likelihood of flooding and soil movement on UK farms.

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 tipping point for change has already come (see above list under Q2 of ‘positive drivers’ in play) after many years of research and collaboration by interested parties. Knowledge and the prioritisation of future soil health and resilience is increasingly becoming embedded in the agricultural and food sector through investment in auditing, tools and services which support better soil management.

Government acknowledgement of the private sector commitments to soil through accreditation of farm advice, assurance and certification involved would be welcome. This would provide a more balanced picture of the totality of effort and investment in place to manage soil and animal nutrition and soils more sustainably.  The value of farm advice, when integrated with soil management (BASIS, FACTS) has been recognized by the recent announcement of significant allocation of ELM funding for agronomists and crop nutrition advisers (£989 and £589 annual payment, respectively under ELMS).  Feed Advisers (see FAR Register) are also taking on their role in soils advice for animal forage production.  The development of the new BASIS Environment Register is also worthy of mention as it recognises competency in soils.

The whole food chain from raw material supply, to farm to fork, is under pressure to demonstrate its sustainability credentials and to set targets accordingly. Major retailers, as well as large and small food chain companies are working with the agri-supply sector (such as AIC), and in many cases providing farmers and landowners with the professional advice to further the cause for soils.

While the unique selling point details for supply chains are in commercial hands, all acknowledge the need to compete on a common and level playing field.

To support the transition to greater levels of organic material to build soil microbial biomass and improve soil resilience, and with the range of mineral fertilisers required, farming industry representatives have committed to working with Government on developing a transition plan. Proposals were made in 2022, with Defra’s Water Quality team during conversations regarding more sustainable use of organic manures as part of transitional aspects of compliance with the Farming Rules for Water. 

We also expect to learn more about the direction of travel and how policy can support it when the Defra established Nutrient Management Expert Group issues its report and recommendations this year.  This Group also addresses soils specifically and in the context of nutrient management, water and air as their relationship is so integrated.

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

Phasing out of plastics films for soil warming and microplastics in products applied to land are not currently covered by regulations, and may need to be considered alongside existing waste to land regulations and licensing/permitting of field treatments/applications. AIC looks forward to being involved in future discussions on this.

February 2023