Written evidence by Linking Environment and Farming(LEAF)(SH0049)

This is a response to a request for evidence on how the government intends to meet its goal of having all soil “managed sustainably” by 2030, considering the following questions:

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?
2. Do current regulations ensure that all landowners/land managers maintain and/or improve soil health? If not, how should they be improved?
3. 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?
4. 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?
5. What does the UK Government need to do to tackle other stressors on soil health such as soil contamination?

We at Linking Environment And Farming (LEAF) would like to first state that we fully support any measures to manage soil sustainably as a key resource for the sustainable future of the planet. We are living in a crucial stage for sustainable farming, with farmers on the front line of climate change solutions – from reducing carbon emissions, building healthier soils, delivering clean water and air, and enhancing biodiversity.

As a leading organisation delivering sustainable food and farming, much of LEAFs work focuses on soil health management, with soil health being of the highest priority when adopting an Integrated Farm Management approach. We work to develop and promote Integrated Farm Management in three core pillars: facilitating knowledge generation and exchange, developing market opportunities through LEAF Marque, and educating and engaging the public in sustainable food and farming.

Soil health cannot be considered in isolation as the Integrated Farm Management approach illustrates. The nine sections of Integrated Farm Management incorporates the entire farm business, recognising the interrelatedness of each of the  sections and  understanding how they work together is essential for its implementation.

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?

How can the Government measure progress towards its goal of making all soils sustainably managed by 2030?

The Government will have to rely on third party data given it has no monitoring and evaluation framework for soil health including no baseline of the current health of England soils (rural and urban).

Without clarity on the definition of a healthy soil, the metrics required to inform this and the supporting data this task seems very challenging. Proxies could be used e.g. area of land in voluntary incentive schemes such as the Sustainable Farming Incentive (SFI) but this is unlikey to cover the whole country combined with whether the actions undertaken in the schemes are producing the desired impact without on the ground monitoring.

What needs to be measured needs to be agreed before working out how alongside the values of what indicates a healthy vs not healthy soil. Work has been undertaken to progress this by the Sustainable Soils Alliance and AHDB but there has been no new Government investment in soil monitoring since 2008 despite Governments vision for sustainably managed soils by 2030 embedded in the 25 Year Environment Plan. This is coroborated in the Environment Agency’s ‘ Summary of the State of the Environment: Soils’ report in January 2023 which states that ‘There are insufficient data on the health of our soils. Investment is needed in soil monitoring.’

What are the challenges in gathering data to measure soil health?

Challenges in gathering data start with the complexity of defining what is a healthy soil, what metrics are needed to inform this and the data needed for those metrics. The UK has a large number of different soil types (over 700 according to soilnet.com) which adds to the complexity; for example the optimum soil organic matter percentage for peat would be very different to a sandy soil.

The range of platforms that collect data (for example at the last count there were 65 carbon calculators in the UK) creates a challenge of who owns the data, the value of the data, duplication of data and sharing data in a market driven environment.

The resources needed to gather data, the different methods and how this is valued and therefore prioritised by those who gather it must be considered to ensure robust and accurate data is gathered.

How can these barriers be overcome?

Industry collaboration is happening but needs to be accelerated with funding for resources. Much of the work currently being undertaken is funded through donations and grants. Government have a role in supporting this financially but must not impact on the ability for reports to be independent or duplicate existing initiatives.

Agreement on what constitues a healthy soil, what are the metrics and what data is needed to inform this e.g. Soil Carbon Code needs to be developed as a framework. Given the range of existing data gathering platforms already used for example, the LEAF Sustainable Farming Review, consideration must be given on how reporting from these can be used to reduce duplication.

Ensuring the scope of the Soil Health Action Plan for England is not reduced or deprioritised when it is incorporated into the Environment Improvement Plan and ideally in light of its importance reinstate it as a stand-alone element.

Gathering data on soil comes at a resource cost in addition to inputting the data onto a platform. This has benefits for the producer but if the data is then being used to demonstrate adherence to a Government target consideration needs to be given on the monetary value of this data which is ultimately owned by the producer.

Knowledge sharing through on farm demonstration e.g. LEAF Demonstration Farms on the value to the farmer or grower of the health of their soil and how to measure is a vital part of the process.

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

Do current regulations ensure that all landowners/land managers maintain and/or improve soil health?

Current regulation is covered by GAECs 4 (Providing Minimum Soil Cover), 5 (Minimising Soil Erosion), 5 and 6 (Maintaining the level of organic matter in soil) which goes some way to ensuring maintenance but there is no incentive to improve.

Cross compliance will end after 2023 and although gov.uk states ‘that most of the standards in cross compliance will apply to your farm activities as they remain in other English laws’ the three GAECs related to soil are not encompassed in English laws at present.

Farming Rules for Water has introduced the requirement to test soils at least every five years to inform planning for manure and fertiliser application but given the purpose of the rules does not go any further in relation to other aspects of soil health.

It therefore remains unclear what regulations will be in place in the future to maintain soil health.

Current regulations do not cover the improvement of soil health.

How should they be improved?

A balance must be struck between regulation, incentive and advice as evidenced in the 2019 River Axe report. Regulation alone will not create an improvement in soil health particularly given the absence of an effective enforcement regime due to resource challenges for inspections, prosecution and effective penalties.

Those cross compliance requirements that fall outside regulation should be considered as the baseline alongside incentive and advice programmes shaped by a comprehensive plan. To consider these areas in isolation will not create the change that is required.

With the average Farm Business Tenancy of less than four years consideration of how a regulatory environment could facilitate the long-term planning and investment that is required between landlord and tenant to improve soil health would be beneficial.

3. 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 SFI soil standards have the challenge of embracing the spectrum of different levels of engagement with soil and individual sectoral challenges. At the moment the requirements coupled with the payment rates are particularly attractive to those already completing the actions and are not incentivising a change for those who are not. If an advanced standard is not being introduced consideration must be given on creating additional options to encourage continuous improvement.

ELMs is voluntary and the Government is reliant on farmers and land managers to meet its targets. The original intention was for the ambition of the lower levels of the standard to be raised over time to encourage continuous improvement. It is not clear if this is part of the future scheme design or how the future post delinking regulatory approach will dovetail with ELMs.

The payment rate calculations based on an income foregone plus costs does not have the ability to recognise and incentivise uptake on soils used for high value crops e.g. lowland peat.

It is therefore unclear if ELMs will deliver the desired outcomes and without a baseline and ongoing comprehensive monitoring programme it will be challenging to measure the impact of ELMs.

What are the threats and opportunities for soil health as ELMs are introduced?

Threats:

-          Low uptake coupled with delinking and no clarity over how GAECs will be implemented in the future.

-          Farmers and land managers delaying applying in the expectation of increased incentives.

-          Short term delivery to access funding rather than long term change.

-          Lack of clarity over agricultural budget beyond 2024 or current Parliament.

-          Earned recognition not being implemented resulting in duplication of record keeping.

-          Lack of baseline and monitoring impacting on ability to measure outcomes.

Opportunities:

-          Profile and importance of soil health is raised.

-          Instigates awareness and action on improving soil health.

-          Creates a starting point from which ambition can be raised.

-          Opportunities for blended finance

4. 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?

Recognition within the supply chain of the value of soil coupled with the investment in managing it reflected in the price paid for products. Acceleration of metrics to create a value for soil and its management to enable it’s inclusion as an asset on balance sheets.

Reducing duplication through Earned Recognition of environmental standards i.e. LEAF Marque with Government incentive schemes and inspection regimes.

Recognising the need for long term planning and investment to benefit soil health and building the support and incentives for this into tenancy agreements; particularly important for short term tenancies. A partnership approach between landlord and tenant should be created.

Sharing information in a range of different formats to recognise different learning preferences. This should include recognition of the existing on farm demonstration networks and how these can be funded for example LEAFs network of LEAF Demonstration Farms.

Recognising the importance of research and development and the role of advice in sharing that evidence to increase the awareness of where to start with soil management. Communication of evidence to the industry should have equal weight to publication in academic publications.

Encouraging collaboration across sectors and within the supply chain.

Also see ‘overcoming barriers’ in Question 1.

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

This should form part of a Soil Health Action Plan which includes the need for a baseline into soil health to provide clarity on the nature of the other stressors. This will then inform the scale of the challenge.

Research and development is required to identify methods to improve the health of contaminated soil along with appropriate incentives to implement.

Consideration of how soil health should be incorporated into other industries which impact on soil e.g. development, infrastructure projects should be included in relevant plans and legislation.

February 2023