Written Evidence submitted by NRM, part of Cawood (SH0035)
NRM is the UK’s largest independent provider of agronomic and environmental waste analysis for land-based industries. We offer water, soil, manures, fertilisers and plant tissue analysis to farmers, growers, and agronomists for improved farm productivity, as well as land-based environmental services including composted waste, anaerobic digestate, effluents and industrial renewables. We also develop innovative high quality tailored suites of tests to meet specific needs
Please see the responses to the Soil Health consultation below.
Government and stakeholders should agree on what the term soil health means, agree on the most beneficial criteria and parameters to measure. The term soil health represents a myriad of soil functions. Improvements in some soil functions are more easily achieved in some soil types, systems and enterprises compared to others. Therefore, applying universally defined and accepted indicators, for example from the AHDB Great Soils project, would provide a baseline for monitoring the progress of sustainable soil improvement.
Also applying the new benchmarks on soil organic matter levels, to anonymised analytical data, would be a cost-effective method of assessing the progress of sustainable soil management. Working with the agricultural analytical sector presents an opportunity to review historic and future collated soil health measurement data. This approach would describe trends in soil health change, particularly if results were linked to farms participating in the new government ELMS schemes. However, a system of linking ELMS participants data to scheme obligations/outcomes would need to be developed to minimise the additional administrative responsibility and streamline the process. Working with the analytical sector, now, could give time to enable a process to be devised that enabling data reconciliation with scheme outcomes.
Government and stakeholders also need to recognise the current and future available analytical capacity. This can be a barrier in terms of making progress toward sustainable soil health. The analytical sector needs to be working in tandem with the government to ensure that soil health aspirations can be measured and sufficiently monitored to gauge the effects of management change. This cannot be achieved if the analytical sector is not prepared with the appropriate capacities and capabilities to meet the expectations of the government and/or the agricultural sector.
Regulations that deal with soil have tended to promote a tick box system that encourages the minimum to ensure compliance obligations are met. A more regulatory emphasis on soil health and management and stronger links to, for example, farming rules for water (FrFW) would underline the seriousness of managing soils more sustainably. A simple measure to strengthen FrFW could be to enforce the under-sowing of maize in situations where soils are at risk of runoff and erosion. More regulatory emphasis could be made on over-wintering stock and maximum stocking rates could be explored to reduce the negative impacts of livestock on soil structure and health. These are management choices that are only optional under stewardship engagement but could be made mandatory under regulation.
Emphasizing the benefits of mixed farming by incentivising more cover cropping, reducing bare land over winter, and the mandatory testing of not only soil but forage and grain after harvest to gauge the effectiveness of nutrient management strategies. The mandatory enforcement of some management approaches could be introduced but the practicalities cost and benefit needs to be demonstrated and should be linked to regional environmental priorities if introduced.
Enforcement of any regulations is always the Achilles heel. Confirming what is happening on the ground is the only way to ensure that any introduced soil health and management regulation has been followed. This means investment and resources for those expected to deliver the enforcement.
Currently, regulations do not include the measurements of soil health metrics, only soil nutrient analysis. The option to monitor soil health through analysis are all voluntary and/or through the proposed stewardship standards. A case could be made that includes soil health monitoring which is enforced through existing regulations. This could introduce complexity however and consideration of analytical capacity would need to be discussed with the providers of analytical services.
The new standards launched under the umbrella of ELMS do have a general ambition to restore soil health across different agricultural enterprises, but overall success relies on a critical mass engaging in all the available standards. The ambition of the soil’s standard is however underwhelming, particularly because the entry obligations are low, and transferring from an intermediate to an advanced soil standard is not an option. If the government is serious about soil health and restoring it, then more importance and encouragement of mass participation in the “more involved” but “more effective” soil options should be the objective. Getting more participants to engage in the bare minimum is unlikely to engender the long-term change needed to deliver positive soil health outcomes.
A more integrated approach between government and industry regarding the development of voluntary and obligatory standards might encourage a better adoption of the soil health narrative and uptake in soil health and management change. The food chain already requires land managers and farmers to engage in grower protocols if they are to remain as preferred suppliers [or suppliers] to retailers. Most supermarkets and retailers insist on carbon audits and part of those requirements include sustainable farming and soil management practices. These already existing supplier requirements duplicate some of the obligations included in government standards. It could be advantageous for government and industry to work closer together on “blueprint standards” that meet market requirements and promote a long-term view for the sustainable production of food and therefore management of soils. These standards would adapt as the market begins to value properly the natural assets food productivity relies upon – the government would be in the position to ensure that the market respects sustainable soil values. Agreeing with the market a clear framework and the better provision of incentives for farmers and stakeholders trying to improve soil health, would give an alternative to those pursuing carbon trading.
A soil health code [linking to the soil carbon code] would be advantageous and help the long-term progression of soil health sustainability goals and encourage the market to not just focus on the short-term market gains, such as carbon offsetting.
The polluter pays principle is one of the effective ways of tackling the other anthropogenic stressors on soil health and sustainability in the longer term. Those that contaminate land should be forced to clean up the contamination and those funds invested back into research and development to help build resilience into agricultural systems.
Climate change is a here-and-now phenomenon and agriculture needs investment into new technologies and reminders of positive traditional approaches that can and will make wholesale changes to agricultural practices. For example, some chemical substances such as urease and nitrification inhibitors to reduce ammonia volatilisation and nitrate leaching, respectively, also pose a potential challenge to soil microflora – the negative impacts yet to be quantified. Tackling one environmental issue [e.g., enrichment of sensitive habitats & water pollution] potentially has unintended consequences and could pose a threat to the soil biological populations, sustainable soil health goals are meant to enhance and protect.
This whole subject area should be reviewed and investigated, and limits considered to mitigate this potential adverse effect on soil health and biology. At regional scales, the use of ammonium nitrate and urea-based fertilisers should be restricted during very wet and/or dry and warm periods, respectively. The impact of high doses of organic inputs, such as dairy slurry in regions with high livestock numbers should also be prioritised in terms of soil health sustainability.
The current regulations which deal with soil contaminants directly and those which cover the risks of more diffuse soil contamination should be enforced by more funding and by bolstering the NGOs whose job it is to protect the environment. Soils and catchments should be regularly tested to monitor, manage, and assess the impact of these other stressors that impact on soil health.
February 2023