Written Evidence submitted by the National Trust (SH0028)



With our staff, members, volunteers and supporters, the National Trust is the biggest conservation charity in Europe. We protect and care for places so people and nature can thrive. Many millions share the belief that nature, beauty and history are for everyone. So we look after the nation’s coastline, historic sites, countryside and green spaces, ensuring everyone benefits. For everyone, for ever.





The National Trust was formed to preserve places of historic interest and natural beauty for the benefit of the nation. Our land is at the heart of what makes the Trust special, and we proudly care for more than 250,000 hectares of land. More than 80% is managed for farming in some way, either by us, farm tenants or commons rights holders.

Climate change and the loss of habitat and species represent the biggest risks to the future of the places in our care. We believe that restoring nature must be at the core of our nation’s efforts to tackle climate change. 


The State of the Environment Report highlighted that the UK’s natural resources, including its soil, are in poor condition. Sustainable land management requires healthy soils, clean water, and thriving nature. The intensification of agriculture over the past 50 years has had the biggest, overwhelmingly negative impact on soil and ecosystems in the UK. Degraded soil was calculated to cost £1.2 billion a year in 2010, and degraded soil is more vulnerable to the impacts of climate change. 


Sustainably managed, resilient soils are key to our response to the climate and biodiversity crises in the UK and critical in delivering the National Trust’s ambitions for people and nature. In contrast to air and water quality, soils are less protected by legislation. The Welsh Government is developing a soil policy statement, to underpin the sustainable management of soils in Wales and we would like to see a corresponding national policy covering England, Wales and Northern Ireland. Such a national Soil Policy Statement would need to address and support the delivery of the overarching Agriculture Act (2020) and the Environment Act (2021).  Likewise, we wish to see a join up between a policy statement and the 25 Year Environment Plan, the Sustainable Farming Incentive and reformed planning policy infrastructure that will be delivered by the Levelling Up and Regeneration Bill.





  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 and how can these barriers be overcome? 


The UK Centre for Ecology and Hydrology (UKCEH) Countryside Survey was the only national monitoring scheme that included soil. However, the scale at which this data was collected meant that it could only answer broad, national questions and not regional or land use specific questions, limiting its use to land managers trying to measure improvements in soil health. The last complete Countryside Survey was in 2007, and a partial update due in 2022 has yet to released. So, our current understanding of soil condition in the UK is limited and out of date[1].  


There have been industry led projects, like the ‘GREATSOILS’ project which has collected data to create a ‘Soil Health Scorecard’ to aid the interpretation of soil data in relation to the management of agricultural land. But this data is largely focused on lowland, productive agricultural land and doesn’t help with the management of uplands, non-agricultural habitats, or provide a comprehensive picture of national soil health.

With the Grassland and Arable Soil standards in the Sustainable Farming Incentive (SFI) requiring the collection of soil data, there is an opportunity to collect national data at a higher resolution than the Countryside Survey.  The data collected as part of SFI could be used to inform the national picture and provide insight into regional variation and/or different land uses. This data, suitably anonymised, could be used to improve and refine a tool, like the Soil Health Scorecard, and expand it to cover a wider range of land uses.
As well as informing ELMS the data could be used to measure progress against the 25 Year Environment Plan objectives.

Challenge – Data privacy. Farmers may be reluctant to engage in the ELMS soil standards if it is not clear how their data will be used, with concerns that it will be used against them in the future as highlighted in a recent article in Farmer’s Weekly:
Farmer asks 'am I wrong?' to be suspicious of data sharing - Farmers Weekly (fwi.co.uk)

How the data will and will not be used needs to be made clear, with protections to prevent the data being exploited. Farm data has an economic value, particularly to consultants and large companies trying to develop management tools and apps that they wish to sell to farmers. There is a tricky balance between the data being a public good (since its collection is paid for by public money), the farmers rights to their own data (and its value), and the interests of the private sector that need to be explored and understood. Various aspects of it have been discussed previously but the conversations have not been pulled together into a comprehensive framework of how data ownership and access should be managed across competing interests.


Challenge – data access. There are existing soil datasets that currently sit behind paywalls (e.g. detailed layers in SoilScapes) that should be made free to access to allow researchers and industry consultants to use the data to improve land use models and the advice given to land managers.


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


There are no current regulations that directly cover soil health. Instead, soil management is referenced in the delivery of another objective e.g. the Farming Rules for Water which cover soil management for the delivery of water quality but do not directly address soil health nor will they lead to significant national improvement in soil health.

In an agricultural setting, where farmers are claiming BPS, soils are protected by cross-compliance standards (GAEC 4: Providing minimum soil cover; GAEC 5: Minimising soil erosion; GAEC 6: Maintaining the level of organic matter in soil) but these are set to end in 2024 and there is not yet a clear replacement.


We need a balance of regulation and incentives to ensure that necessary work on soils is undertaken; that best practice is encouraged everywhere, and that farmers are supported to transition to new farming practices. Good soil health, however, will deliver increased productivity for farmers and the ELMS system should not pay farmers to make good businesses decisions over the long-term nor pay for minimum basic requirements in the short term.


  1.   Will the standards under Environmental Land Management schemes (ELMs) 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 current ELMS soil standards do not have any clear over-arching objectives or outcomes, showing how they link into the other ELMs standards and what the overall SFI programme is trying to deliver.


The lack of clarity on what ELMs is trying to deliver, how the data will be used and where the industry is expected to be in 10/20 years’ time, mean that the current Grassland and Arable Soil standards risk becoming a tick box exercise as there is no clear motivation to farmers as to why they are doing it other than to get the payment. Clear long-term objectives would help farmers plan the delivery of these standards across their farms in a way that best suits their business to deliver the objectives whilst moving the farming sector to a new level of sustainability where some of what they are getting paid for in the short-term become standard good/best practice in the long-term.

Challenge - Clear guidance: to facilitate delivery of the standards across all farm types.  Templates for nutrient management plans that are simple for farmers to complete when they have not had to do these before would be really helpful. The current examples are for highly complex arable set-ups, not a simple straw/muck based upland system. If they are too tricky to complete from the outset, it may put people off joining, particularly if they need to pay someone to help them do it when the payments are low, or they do not yet have clarity about why they need to do it or how it will help their business.


  1.   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? 


Farmers have managed most of the soil in England for generations and have a good understanding of the properties of their local soils. But for many, their understanding of management and what makes a ‘good’ soil has been shaped by college courses and industry events over the last 30 years that focused on optimising fertiliser use, not protecting and enhancing soil health and function. There is industry recognition that there are not many consultants or advisors who have the skills to consider soil physical and biological health as well as its fertility, and how that can fit holistically within the wider farm business. Until the Duchy College launched its 2-year soils course this year, there was no higher education course focusing on soils. Most universities offering agricultural or land management degrees generally only offer 1 or 2 soil modules.

Many farmers, particularly those who consider themselves ‘low input’ do not understand the value in looking at soils, for their business or for wider public benefit, as they do not need to calculate fertiliser rates or do not recognise a problem in the first place. This is reflected in comments from one of our tenants about soil monitoring and the SFI Grassland Soil Standard:
“…I’m not sure where soil management sits in the ‘give time over to thinking about it’ category. As a low input, low output system, we don’t use fertiliser and only limited spays (weed wipes) and soil isn’t up there in my agenda. Even with SFI entry, I know testing needs doing and I will probably need to lime, but beyond that, I doubt it will get more attention. I do have some significant areas where cattle grazing in the Higher Tier have caused erosion, but there are no mechanisms to fund me to address this.”


However, it is these farmers on often marginal land where improvements in soil health could deliver the largest benefits to the farm business and simultaneously deliver public goods like flood prevention and carbon sequestration.


There needs to be a general education or knowledge exchange programme on the value of soil, and how good soil management can provide economic benefits to the farm business as well providing vital public goods. Such a programme would enhance the exchange of knowledge between farmers, decision-makers and scientists to provide the best possible information for optimal solutions and opportunities for sustainable management of agricultural soils. This could be complemented by support for the development of soil training through universities and CPD courses that take a holistic view of soil health and its role on-farm and in the wider landscape.


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

Plastic pollution

Micro and Nano plastic particles present a significant risk to soil health, with an estimated 110,000 tonnes of plastic debris introduced into agricultural fields in Europe each year[2].
There are multiple environmental sources from anthropogenic activity, but the main agriculture specific sources that need addressing include: degrading silage wrap, greenhouse film, agricultural mulch film, weed matting, and polymer coatings on seeds and slow release fertilisers.

There needs to be better guidance aimed at reducing the use of agricultural plastics and regulation on their use and disposal to limit environmental contamination. There are existing recycling schemes but uptake is low due to a lack of awareness, cost and practicality.


Construction industry


The management of soil on building sites needs better soil management guidelines and regulation (or existing regulations need enforcing). There has been industry led work to develop guidance to improve management, but this needs government support and a higher regulatory baseline.


Urban soils


Soils in urban and peri-urban areas are often highly compacted and many are also contaminated with plastic and industry waste. While urban areas only occupy around 6% of the UK, in cities and large urban areas, parks and other green spaces are the only available, unsealed soils that can deliver ecosystem services such as flood mitigation, air purification and carbon sequestration.  Working with councils and other partners to improve the health of urban soils could deliver significant local benefits.


February 2023















[1] Soils | Countryside Survey (a partial update was due in 2022 but is not yet available, and the next full update not till 2025).

[2] Nanoplastic–plant interaction and implications for soil health (wiley.com)