Written Evidence submitted by Sustain Alliance (SH0029)


Sustain is the alliance for better food and farming. The alliance is made up of over 110 member organisations who share our vision for a sustainable, resilient, healthy, fair, and accessible UK food and farming system.

Summary: The UK Government’s plan to improve soil health, laid out in the recently published Environmental Improvement Plan (EIP), is seriously lacking in ambition and strategic thinking on soil in England. Furthermore, the Government needs to set out a clear plan for increasing the ambition of Environmental Land Management (ELM) to deliver soil health outcomes. At present, the Sustainable Farming Incentive (SFI) and the Countryside Stewardship (CS) schemes are not ambitious enough, or joined up enough, to substantially deliver soil health benefits. However, the Government needs to look beyond the farmgate, and to the problem of market failures in the food system that unfairly suppresses farm incomes and disempower farmers to reinvest income in actions like improving soil health and resilience. There is also a clear need for Government to lay out and communicate a clear plan to increase the regulatory baseline over time to bring up all farms, but this cannot be undermined by the current approach the UK has to trade policy.

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?

  1. The Government must standardise the way in which soil health is measured. There is currently a risk that too many approaches to testing soil will lead to contradictory and misleading results for metrics. To measure progress, standardisation is important.


  1. Further to this, farmers and land managers need to have access to affordable and good-quality advice for collecting soil health data and being given the tools/knowledge for improving soil health. This advice provision could include a programme to upskill farmers and farm workers over time on how to accurately collect data and use it to improve their farming system.


  1. The Sustain Alliance also supports the Sustainable Soils Alliance (a Sustain member) recommendations for improving soil health:
    1. Embed good-quality, independent, flexible, and easy-to-use soil health advice into all future agri-environment schemes.
    2. Develop a farming and environment advice sector that is fully independent from the agricultural industry (i.e. agrochemicals, fertiliser manufacturers etc.).
    3. Review the CPD service and ensure that all farm advisers are fully trained and qualified (i.e. BASIS certification) on sustainable soil management.
    4. Review soil health in higher and further education, and ensure it reflects that most recent scientific, research, and policy thinking and methods.

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

  1. The UK Government has removed the ‘greening’ requirements of the Basic Payment Scheme (BPS) in 2021 which had some low baseline regulations on soils. At present, we understand that cross compliance (the monitoring and enforcement mechanism for agricultural regulations) will go in 2024. This could leave a gap in regulations and enforcement that is yet to be replaced.


  1. The Farming Rules for Water (Reduction and Prevention of Agricultural Diffuse Pollution (England) Regulations 2018) was brought in to create a new regulatory baseline for good farming practice. It includes three rules (numbers 1, 6, and 7) for soil protection on arable and livestock farms. However, it has yet to be seen if these regulations have been effective at reducing and preventing soil erosion and other harms to soil health.


  1. There are 2 key issues with current regulations: 1) There are not enough resources given to the Environment Agency to monitor and enforce regulations and penalties, which is clear in the numbers243 breaches, but 0 penalties given; 2) There has been very little communication from the Government to the farming sector on the Farming Rules for Water, leading to low awareness of them.


  1. Improving soil health regulations:
    1. Soil regulations should focus on protecting as much of the carbon that is already stored in them. This could include stronger rules around tillage (esp. on sloping land and land vulnerable to erosion), green cover (esp. in autumn and winter months), and livestock poaching (esp. on land near watercourses or vulnerable to erosion). Additional areas would include regulating pollution from all sources and protecting the soil biodiversity.
    2. As the agricultural transition period progresses, the UK Government could look to put the low ambition level SFI actions on soil into regulation in order to bring up the regulatory baseline.
    3. Stronger regulation across the food supply chain to ensure that the food industry is doing its part to protect and enhance soil health. Our own research shows that farmers have the biggest financial burden (and squeeze) in the farm to folk chain.
    4. Alongside soil-related regulations that stretch across the supply chain, it is crucial that supply chain fairness regulations are working to ensure farmers get a fair price for their produce, and therefore, have the income to invest in the sustainability of their soils (and wider farming system).

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?

  1. It is important that Environmental Land Management (ELM) especially the Sustainable Farming Incentive (SFI) and Countryside Stewardship Plus (CSP) schemes takes a whole farm approach and supports a transition to agroecological farming in England by 2030.


  1. The current soil-related actions in the SFI might improve soil health to a degree on land which is starting from a low baseline. However, the SFI lacks ambition and does not have a strategy to increase its impact on improving soil health in the coming years. Defra has given assurances that ambition will be ratcheted over time, but there is no clear and concrete plan to do so yet.


  1. The 6 new SFI standards might deliver some co-benefits for soil health, but similarly to paragraph 9, they are currently set at a low level of ambition (see detail). It would take high uptake at both the national level and on farms that are at a lower soil health baseline. Most of these actions do not address the root cause of poor soil health, but instead, could help reduce soil run-off. The actions which might deliver co-benefits depending on uptake at the national and farm levels are:
    1. Nutrient management actions such as ‘Establish and maintain a legume fallow (arable land) and ‘Establish and maintain legumes (improved grassland).
    2. Integrated pest management actions such as Establish flower-rich margins, blocks or in-field strips’ and ‘No use of insecticide.
    3. Low input grassland actions to ‘Maintain grassland with very low inputs.
    4. Arable and horticultural land action to Establish and maintain a 4m to 12m buffer strip on arable and horticultural land.
    5. Improved grassland action to Establish and maintain a 4m to 12m buffer on improved grassland.


  1. To make a real difference to improving soil health at the national and farm levels, Defra must introduce more ambitions SFI standards and actions. For example, introducing organic farming, agroforestry, and pasture-based livestock standards would present more significant opportunities for improving soil health. However, it is just as important to take an approach to the scheme that is based on the whole farm.


  1. The other key issues that need to be addressed, include the lack of a clear and cohesive plan to ratchet up the ambition of the SFI and CSP schemes. Without it, there is a concern that good progress will not be made on soil health and its related goals linked to Net Zero, nature targets, and food security. Farmers also need better access to affordable or free advice, training, and demonstration sites so that they can build and apply knowledge on achieving better soil health.

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?

  1. The UK Government needs to introduce new supply chain codes of practice that were promised in the Agriculture Act (2020). These are crucial to tackle problems of unfairness and poor trading practices by large food businesses, that are leaving farmers with low income. That means farmers are unable to invest in the sustainability and resilience of their soils.


  1. On top of this, the Government must retain the Groceries Code Adjudicator (GCA) and not amalgamate it into the Common Markets Authority. The GCA has had some success in reducing the unfair and poor practices that supermarkets use, but problems persist that lead to low incomes for farmers. As we have highlighted, those low incomes stifle the ability of farmers to invest in soil health and other environmental outcomes.


  1. Furthermore, the UK Government should also look to catalyse investment and growth in better and more diverse routes to market for farmers. This could be done by directing some of the Levelling Up money into local food infrastructure, networks, and skills. This could solve some of the market failures and help farmers receive a fairer price and a more stable income to reinvest back into the sustainability and resilience of their business (including soil health.)


  1. The Government needs to find ways to stop the loss of diverse, small and medium sized farm businesses. Evidence shows that smaller and more diverse farms deliver greater environmental benefits alongside healthy food production. Alongside tackling market failures, the ELM schemes need to be workable for farms of all types and sizes.


  1. Trade policy must align with maintaining high environmental standards while also not undermining UK SME farm businesses.

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

  1. The UK needs a national soil health action plan that covers contamination from industrial activities, as well as pollution from agriculture and other land use activities. There could be plenty of opportunities for cities and towns to use urban and peri-urban green space to produce food close to market, but contaminated soil can be a limitation, especially in previously or currently industrial places.


  1. A programme to clean up contaminated soil, working with local communities to provide funding and advice for local projects, could help to clean up spaces that can then be used for community benefit like producing healthy food and improving access to nature.


  1. The original ambition in the 25 Year Environment Plan (25YEP) was for all soil in England to be sustainably managed by 2030. The Environmental Improvement Plan (EIP) which updates the 25YEP, published in January 2023, reduces this ambition to only 60% of agricultural soil (not all soil) to be sustainably managed by 2030. Agricultural soil amounts to 69% of England’s land mass, meaning a substantial amount of soil does not fit into Government’s plans including commercial forestry, industrial sites, contaminated sites, nature (e.g. woodland, wetland, peatland) sites, and 40% of agricultural land. This is very clearly a drop in ambition.


February 2023