Written Evidence submitted by Compassion in World Farming (SH0061)

  1. Compassion in World Farming (Compassion) welcome this inquiry into soil health. We have a long-standing interest in this issue, and the role that livestock production can play in both enhancing and undermining soil health. We wish to make the following key points, which are expanded on in our detailed submission (from paragraph 7).


  1. The Environment Land Management (ELM) schemes Sustainable Farming Incentive (SFI) standards mark a good starting point yet they are not ambitious enough either in scope or accountability to adequately protect or improve soil health. The government needs to take a whole farm approach to integrate agroecological principles into UK farming and agricultural policy. This would support the transition away from intensive agriculture and factory farming, with animals raised as part of mixed systems and integrated with crop rotations. Doing so would build natural soil fertility and plant health through nitrogen fixing crops and legumes and animal manure alongside a vast reduction in agrochemical fertilisers and pesticides. A further benefit of this would be the building of natural animal immunity through higher welfare agroecological systems whilst reducing the routine use of antibiotics in intensively farmed systems which contaminate and damage soil biodiversity.


  1. In the UK, intensive agricultural practices erode soil health, reducing soil fertility thus damaging wider crop health and long term food growing ability, whilst increasing the risk of further soil erosion and flooding. Intensive farming serves to contaminate the soil through agrochemicals which negatively alter soil biochemistry and to compact the soil, reducing aeration and ability to store water whilst.


  1. In order to ensure progress is made and UK soils are protected and restored, a standardised methodology for measuring and monitoring soil health is needed and the data gap which currently exists must be filled.


  1. Compassion urges the development and implementation of government agricultural, environmental and land use policies which are: more ambitious than current proposals and targets; more coherent across land use sectors and policy departments; and more joined up within ELMS.


  1. In response to the inquiry, we would like to make the following detailed submission:


Question 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?


  1. A key means of measuring the progress of how sustainably soils are managed is through the uptake of government schemes designed to improve soil health, such as the Sustainable Finance Incentive (SFI) and the Soil Structure Measuring and Monitoring (SSMM) Scheme.


  1. Monitoring uptake of soil payments within the SFI should be relatively straightforward, as Defra are focusing on monitoring outputs (i.e. % of land coverage) rather than outcomes (the environmental benefits derived from outputs) and recognising that payments for soils alone are low.


  1. We encourage the Committee to urge Defra to produce regular reports on how many farmers are in this scheme and how much land is covered by standards to increase soil health. Over time, these figures should show an upward trend, in both cases, from the baseline (which should be recorded from the scheme’s start date). But simply measuring uptake is insufficient – the Government must also monitor that the SFI is indeed improving soil health, and make necessary changes to further improve it, if the scheme in its current design is not delivering.


  1. Under the SFI soils standards, farmers will be required to do basic sampling, and the 5-hectare limit will be carried forward from the BPS scheme. Compassion urge removal of this rule to allow smaller farms to apply (this would benefit small scale livestock farmers and more of the horticultural sector).


  1. However, we are concerned that output-focused monitoring will underrepresent the co-benefits for the environment of any practices. This in turn would undermine the total recognised environmental benefits as well as the benefits to farmers of improvements to their soils e.g. ultimately reducing costs in fertiliser use.


  1. Longer-term monitoring of those benefits to the agronomy and the environment would allow for a more holistic analysis, which would demonstrate the value of a shift to more sustainable practices to both producers and wider society.


  1. Challenges surrounding the monitoring of the application of organic matter remain, as this will require testing of soil organic matter (SOM), whereby farmers will be asked to submit records of their application of inorganic and organic fertiliser on a proportional basis. The development of a standardised soil structure methodology as part of Defra’s SSMM scheme, under which farmers will be paid to assess their soil structure according to standardised metrics and methodologies (for SOM, earthworms and visual assessment) is therefore welcome as supplementary to the requirements of the SFI.  Specifically, a standardised methodology must include guidance on how to assess subsoil. Concerning the measuring and monitoring of soil health, both soils standards require farmers to undertake a soil health assessment and create a soil management plan. Compassion welcome this.


  1. A further challenge regarding the monitoring of soil health and management is the soil health data gap. This must be addressed through investment and farmer-to-farmer learning. A Key Finding of the 2019 Environment Agency The State of the Environment: Soil Report[i] was the ‘insufficient data on the health of our soils’ and need for investment in soil monitoring. This report cites the widely accepted need for more data on soil health as essential for developing effective policies and programmes to protect soil health. Compassion second the call in this report for government-supported use of ‘technology such as drones, satellite imagery and DNA sequencing alongside traditional field-based monitoring’ to ensure soil health data is collected, stored and analysed efficiently and regularly without incurring excessive cost. Data must also be reported and easily accessible by all institutions and businesses who wish to view it.


  1. Compassion also notes the need for investment and support to ensure collaboration with, and between, farmers to ensure peer-group learning about best practice and to fill the data gap through knowledge sharing.

February 2023

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


  1. The government’s policy drivers which aim to improve soil health include the Environment Land Management schemes. Specifically, under the SFI: the soil standards; Arable and Horticultural soils and; improved Grassland soils. The objective of the SFI is to deliver the ambitions outlined by Defra in their 25 Year Environment Plan (25YEP). This includes the aim of sustainably managed soils by 2030, by ‘addressing factors in soil degradation such as erosion, compaction and the decline in organic matter’[ii]


  1. However, there are several concerns, and areas for improvement:

a)      The outputs-based approached taken by DEFRA to monitoring progress might mean the co-benefits for the environment of any practices will not necessarily be captured. This would lead to an under-estimation of the environmental benefits, as well as the benefits to farmers of improving their soil. SFI must be flexible rather than punitive when circumstances (e.g., weather) would be unfavourable for the implementation of certain practices.

b)      The Sustainable Soils Alliance note the clear role for independent advice in supporting uptake of the SFI scheme[iii] and Defra should support peer-to-peer learning for farming and advisors and avoid relying on the commercial advisory industry to help deliver SFI ambitions (as commercial interests may conflict with environmental priorities).

c)       Regarding soil assessments, the SFI does not currently prescribe a standardised methodology for assessing soil, and the Government must ensure the development of the SSMM scheme overcomes this.

d)      SFI would benefit from further clarity, including definitions for eligibility, the viability of the scheme for small farms, future flexibility of the scheme design, government commitment to continued payments and how the three ELM schemes will work together.

e)      As it stands, there is some ‘overlap’ between the SFI soil standards and regulations, raising the concerns that farmers will be paid for activities that are otherwise required by law. Although soil-relevant regulations will be brought together in a clearer way under the Soil Health Action Plan for England (SHAPE), the Government should ensure that payments aren’t being provided for merely complying with existing laws and regulations.


  1. The Environment Act 2021 promises legally binding targets for soils once baseline data is established. The government’s Environment Improvement Plan, the first revision of the 25YEP, brings together targets to improve wildlife habitats, air and water quality, and species protection to halt the decline of nature by 2030 (and then reverse it)[iv]. This includes interim targets and funding for supporting wildlife and habitats, specifically thousands of hectares of new wildlife habitats, improving the state of sites of special scientific interest, a multimillion pound species survival fund (yet to be launched), and reliance that ELM scheme uptake will be 60-80% for nature friendly farming on 10-15% of farmer land by 2030.


  1. The Environment Plan commits to a reduction in nitrogen, phosphorous and sediment pollution from agriculture of 10% in 5 years. The aim is for this to be achieved through large scale landscape recovery projects to restore water quality and through the 3000 hectares of new woodlands to be established along rivers. Compassion supports these aims.


  1. There is a wider issue, around the incoherence of agricultural policy. Agricultural policy since World War Two has resulted in ever increasing intensification of farmland and a corresponding degradation of soil.


  1. In 2010, a report to Defra found that soil degradation in England and Wales was calculated to cost £1.2 billion a year and a primary cause of that degradation is intensive agriculture[v]. Compassion call for a systems-based/wide approach, prioritising environmental benefits, specifically soil health, when creating and assessing wider policy, as required by the Environment Act.

Question 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? 


  1. Under the ELM schemes farmers and land managers will be paid to deliver public goods which both directly and indirectly contribute to improved soil quality. Compassion supports this approach and move away from BPS according to farm size, however does not agree that the £22 a hectare available for assessing soils or adding organic matter to soil is enough to ensure the scale of uptake so urgently needed.


  1. It is positive that, in January 2023, Defra announced further standards covering hedgerows, nutrient management, integrated pest management, low input grassland, improved grassland, and arable and horticultural land (on top of those already established, pertaining to arable and horticultural soil, improved grassland soil, and moorland and rough grazing)[vi]. These, and other standards, are connected to soil health and have wider benefits for soil quality. For example, farmers will also be able to access funding to work with an independent BASIS and FACTS qualified adviser to produce an integrated pest management plan (£989 per year). This support reduces the need to use agrichemicals and pesticides, the application of which harms soil biodiversity, whilst also allowing for knowledge development and the raising of professional standards across land management and food production.


  1. The benefits to soils seen through the SFI must also be protected when wider policy is being created, so as to avoid incoherence. As such, in wider areas of land use and waste management, soil health must be recognised as a key factor in need of protection.


  1. This should link to a whole farm approach, which will relate to farm systems. Defra should therefore introduce more whole-farm type standards to SFI in 2024/25, including the organic and agroecological farming and agroforestry standards which work to naturally restore soil health. Until these schemes embed whole farm approaches into its design, it is crucial that farmers are incentivised and encouraged to stack environmental actions.


  1. Compassion supports these latest additions but highlights that the schemes do not go far enough and are unlikely to deliver fundamental and significant changes needed within British to rescue the UK’s natural environment.


  1. In order to do so, farming systems that are no longer based on cruel intensive methods, such as the use of crates and cages, must be prioritised within a wider government-supported shift to agroecological farming. We therefore urge the Government to ensure that the expansion of grants is used for genuinely improving animal welfare and supporting farmers in this transition.


  1. In recognising the array of policy levers and mechanisms, a joined up approach is needed to ensure that farmers and land managers can easily apply and receive payment.


  1. The ELM schemes currently lack the ambition to restore soils across different types of agricultural land, despite the positive standards already set.  For example, the three levels of ambition within each SFI standard have been dropped in favour of a blanket approach to stand alone actions, so there is currently no clear ‘ladder’ of ambition being offered.


  1. Moreover, there is no clear plan to integrate and move towards a more ambitious scheme over the rest of the agricultural transition period. The approach to SFI is fairly atomised and lacks the support for farmers to transition to whole farm agroecological approaches that are urgently needed to protect and improve soil health.


  1. We urge the establishment of a plan for how the ambition of actions within standards with be ratcheted up. For example, adding more specific targets around diverse cover cropping and minimum tillage into the arable and horticultural land standard, or rotational/mob grazing into the low input grassland standard. Nor has there been any clear commitment to shift lower ambition standards out of the scheme and into the regulatory baseline, overtime, as they become the new norm. The evolution of the SFI scheme, and its standards, towards continual improvement, needs a strategy.


  1. Through this expanded SFI offer and in combination with Countryside Stewardship Plus (CSP), a total of 280 voluntary environmental actions are available for farmers to choose to take. On this point, although Defra announced a new SFI management payment (to recognise the cost of entering the scheme, set at £20 per hectare for the first 50 hectares), Compassion call for greater incentives and accountability for farmers as uptake is currently very low and the costs of implementing many actions is seen to outweigh the benefits for many farmers.


  1. The Government should also give consideration for different land types. The SFI will begin with a soil focus, which is pivotal to encourage sustainable agricultural practices (as soils are a key national asset. The roll-out will have two soils standards: arable and horticultural soils, and improved grassland soils, both with introductory and intermediate levels.


  1. The roll-out will also have a moorland standard (introductory level only) and a soils standard for unimproved grassland will come later in the roll-out.


  1. However, the 2023 ELM announcement will provide little reassurance to smaller farm businesses that Defra is seriously looking at how to make the schemes workable for them. Particularly as the 5ha barrier remains, preventing smaller farm businesses from participating and improving soil health. 

Question 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? 

  1. Intensive farming of crops and animals can result in soil degradation and loss of soil fertility, limiting the soil’s ability to perform functions and ecosystem services such as carbon sequestration, flood prevention and long-term food production.


  1. Researchers warn that intensive farming has depleted soil nutrient levels and entrenched processes of erosion and desertification to such an extent that global food security is at risk[vii], with soils only able to provide 60 further harvests[viii]. Land use and farming must therefore shift from intensive methods and towards nature-friendly farming in order to rebuild the soil’s carbon stores, boost soil biodiversity and fertility, and ensure long term soil health and management.


  1. Intensive animal agriculture (factory farming) and crop production for animal feed are severely damaging to soil health. These systems depend on vast monocultures requiring routine fertiliser and pesticide use, reducing levels of soil organic matter and biodiversity, soil fertility and the ability to sequester carbon.


  1. Large monocultures of cereal for animal feed also reduce the soils’ ability to aerate and hold water, as a result of compaction by heavy machinery. When soils become compacted, they are more likely to become waterlogged, leading to run-off and flooding and further soil erosion. This increases nutrient losses to watercourses, causing pollution and reducing nutrient levels in soil. This has the further effect of doubling the amount of nitrogen fertiliser needed to maintain yields.


  1. The process of ‘landspreading’, which is common in intensive farming, further damages soil health, contaminates crops and livestock and affects the aquatic environment. Though the long-term consequences of soil contamination, for example through microplastics and the spreading of slurry, are less researched, shifting to regenerative food and farming would prevent the immediate harm done to soils through the spreading of contaminated waste within intensive systems.


  1. The quantity of crops needed as animal feed must be reduced and arable land farmed less intensively through regenerative and agroecological methods. This would enable the quality of agricultural soils to be restored through the use of rotations, legumes, fallow periods, green manure and animal manure in crop-animal integration, as opposed to intensively produced monocultures.


  1. Crop-animal integration is a fundamental part of regenerative and agroecological practices, and must be central to UK farming systems. Animals intensively farmed in monocultures have reduced natural immunity and the system is therefore dependent on routine antibiotic use, contributing to the wider public health issue of antibiotic resistance. As well as obvious animal welfare concerns here, this problem also affects soil health and waterways, with a recent report finding antibiotics present in ecosystems adjacent to intensive farms.


  1. According to World Animal Protection and the Alliance to Save our Antibiotics, manure sludge contaminated with superbugs can enter soil and alter the balance of bacteria[ix]. Once in the soil, superbugs can persist there even if there is no further contamination with antibiotics.


  1. Compassion supports the conclusion that the government must implement routine testing of soils and waterways on or adjacent to intensive farmsto determine and document the extent of soil contamination and poor soil health as a result of run-off.


  1. More broadly, the government should support the implementation of higher-welfare mixed animal husbandry practices to enable the phasing out of antibiotic use in farms as part of wider agroecological farming practices, which will contribute to healthier soils.


  1. A report by the European Commission’s Sustainable Finance Platform emphasises the link between the number and management of integrated livestock-crop systems (where the number of animals does not exceed the capacity to use their manure) and soil health measurements[x]. This is one way for assessing whether livestock operations make a substantial contribution to biodiversity and ecosystems, the sustainable use and protection of water, and pollution prevention and control. This will help show the value of on-farm feed production and on-farm nutrient cycling and fixation (through animals and nutrient-fixing crops and legumes in rotations). Compassion welcome this approach to this issue and emphasises its significance for both soil and wider food system benefits.


  1. Implementing farm systems which meet key standards, including the primary use of organic manure and biological Nitrogen fix, with minimum use of chemical fertilisers and a maximum farm-gate N balance (which includes the Nitrogen of brought-in feed), soil health and quality can be naturally restored.


  1. The ELM schemes must go further as part of a wider reform of UK farming in which crops are produced in non-intensive, nature-friendly ways with minimal use of chemicals. Soil fertility should be encouraged more naturally, for example, by using composts, cover crops and manure from animals raised on the farm, rather than chemical fertilisers. These changes to production practices must sit within wider government-supported changes, and part of that should include encouraging a move towards ‘less and better’ meat and dairy consumption.


  1. By consuming less intensively farmed meat and dairy, and prioritising organic, regenerative, or agroecologically produced foods, dietary patterns will lead to reduced demand for intensive animal feed and factory farmed animals, supporting the transitions outlined above as essential for soil health and fertility.


  1. Intensively growing monocultures of cereals for feeding livestock, is a wholly inefficient system for proving food and nutrition security and is incompatible with environmental sustainability goals. Doing so wastes food and resources which could be utilised for human consumption. Analysis of the UK Government’s ‘Agriculture in the UK 2021 statistics[xi] (Table 1) shows that, between 2019 and 2021, an average of almost 49% of the wheat, oats and barley produced in the UK were used as feed for livestock (the figures are 41%, 55% and 54%, respectively).[xii] Aside from being terribly resource inefficient, it puts serious pressure on the UK’s soils that could, as highlighted above, be better managed through less intensive, pasture-based farming systems.








Table 1. Source: Defra 2022














Produced, thousand tonnes

Animal feed, thousand tonnes


Produced, thousand tonnes

Animal feed, thousand tonnes


Produced, thousand tonnes

Animal feed, thousand tonnes















































For further information, please email: policy@ciwf.org 

February 2023

[i] Environment Agency (2019). The state of the environment: soil. The state of the environment soil (publishing.service.gov.uk)

[ii] House of Commons (2018). A Green Future: Our 25 Year Plan to Improve the Environment. 25-year-environment-plan.pdf (publishing.service.gov.uk)

[iii] Sustainable Soils Alliance (2022). Soils in the Sustainable Farming Incentive (SFI) Delivering results for farming and the environment?. Soils_in_the_SFI_Workshop_Report_-_April_22-2.pdf (sustainablesoils.org)

[iv] House of Commons (2023). Environmental Improvement Plan 2023.Environmental Improvement Plan (publishing.service.gov.uk)

[v] Defra (2011). The total costs of soils degradation in England and Wales. Research project SP1606 by Cranfield University. (Science Search (defra.gov.uk)

[vi] Defra (2023). Environmental land management schemes: details of actions and payments. Future Farming Blog.  Environmental land management schemes: details of actions and payments - Future Farming (blog.gov.uk)

[vii] UN, Soil erosion must be stopped ‘to save our future’. Soil erosion must be stopped ‘to save our future’, says UN agriculture agency | UN News

[viii] Philip Lymbery (2022). Sixty Harvests Left… Or a Future-Proof Planet and Food system?. Philip Lymbery | Sixty Harvests Left

[ix] Alliance to Save our Antibiotics, World Animal Protection and the Bureau of Investigative Journalism (2022). Swimming in superbugs: MRSA and E coli found in British rivers. https://www.saveourantibiotics.org/media/2051/superbugs-in-the-environment-v3.pdf

[x] Sustainable Finance Platform (2022), Platform on Sustainable Finance: Technical Working Group. PLATFORM ON SUSTAINABLE FINANCE: TECHNICAL WORKING GROUP (europa.eu)

[xi] Defra (2022). National Statistics Chapter 7: Crops. https://www.gov.uk/government/statistics/agriculture-in-the-united-kingdom-2021/chapter-7-crops

[xii] Calculations based on tables 7.2a and 7.2c (Wheat), 7.3a and 7.3c (barley), and 7.4a and 7.4c (oats).