Written Evidence submitted by The Wildlife Trusts (SH0063)


An introduction to The Wildlife Trusts

1. The Wildlife Trusts are a federation of 46 independent wildlife conservation charities covering the whole of the UK, Alderney and Isle of Man. Together, The Wildlife Trusts have more than 870,000 members, 38,000 volunteers and 3,000 staff. Wildlife Trusts steward some of the most special and complex areas for wildlife in the UK, Alderney and Isle of Man. Collectively we manage over 2,300 nature reserves, operate 123 visitor and education centres and own 29 working farms.

2. Our vision is of a thriving natural world, with our wildlife and natural habitats playing a valued role in addressing the climate and ecological emergencies and driving global change, with people inspired and empowered to take action for nature. We work on land and at sea, from rural communities to coastal towns and busy cities. We work in partnership to achieve a greater impact, for example through advising farmers and landowners on how to help nature on their land. We undertake research, we stand up for wildlife and wild places under threat, and we empower people to take action for nature and the climate in their lives - and to join us in calling for effective policies and legislation to help our natural world recover.

3. The Wildlife Trusts have decades of experience working with decision-makers, including the UK governments, and a wealth of expertise, experience and passion within our staff. We welcome this inquiry and are pleased to contribute written evidence. We have provided our answers to the questions below.


Q1. 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. In order to measure progress towards the goal of making all soils sustainably managed by 2030, the Government needs to clearly set out its definition of sustainable management, and outline what factors it will use to assess soil health. The lack of a clearly defined concept of what makes up soil health will hamper both the ability to ultimately meet the goal and the capability to monitor progress towards it, so this needs to be addressed. There are many physical, chemical, and biological attributes that contribute to soil health, so an integrated approach that takes a range of indicators into account is needed to get an accurate picture.
  2. The Government should prioritise the development of a standardised soil health metric that can be rolled out nationwide, taking into account multiple biological, chemical, and physical indicators. Physical and chemical factors such as bulk density, water infiltration rate and soil organic matter levels are important measures to include, but care must also be taken to include biological indicators as well. Soil biodiversity plays a key role in promoting and maintaining soil health, but biological indicators have often been overlooked in previous soil health assessment schemes[1]. Without including biological indicators (ideally at multiple scales, such as earthworm abundance/diversity and microbial activity) the metric will be missing key indicators that are central to determining soil health[2].
  3. The soil health metric should also be able to account for the soil type, location and land use specific factors that apply to any given soil, as soil health will vary depending on these factors. For example, a healthy deciduous woodland soil may look different from a ‘healthy’ arable soil directly adjacent to it, and ‘healthy’ arable soils growing the same crops may show markedly different features depending on the underlying soil type. To account for this, accurate baseline sampling will be needed across a range of soil types and land use factors. The UKCEH Soil Health Webtool SOil FunDamentals’ (SOD)[3] provides a good example of how a soil health monitoring tool can consider these factors whilst maintaining a user-friendly interface. The Government could use tools like this one as a valuable starting point, improving on it by collecting more data, adding in additional indicators, and standardising data collection processes.
  4. The lack of any national soil health framework has hampered efforts to collect data and understand the state of UK soils to date, so prioritising the development of such a framework is necessary to achieve the goal of sustainably managed soils. An essential part of this should be the delivery of a coordinated soil health monitoring scheme using a standardised metric as discussed above. Investment into the rollout of this scheme will be needed, but Government funding for soil monitoring has so far been severely lacking. This has been highlighted by the Sustainable Soils Alliance, who calculated that of the money spent on monitoring the three principle environmental indicators (air, soil, and water), soils receive a mere 0.4%[4].



Q2. Do current regulations ensure that all landowners/land managers maintain and/or improve soil health? If not, how should they be improved?

  1. Current regulations are not only insufficient for improving soil health, but they have also been unable to prevent the decline of soil health across the UK. In 2009, Defra acknowledged in the ‘Safeguarding our Soils’ document that our soils have been degrading for many decades, due to intensive agricultural production and industrial pollution[5]. In this document, Defra described three main threats to soil health - soil erosion, organic matter decline and compaction. In 2015, one study estimated that declining soil health was costing around £1.2 billion per year in England and Wales alone[6]. More recently, additional research has provided further evidence of continued soil health declines, including a recent report indicating that earthworm populations have declined by a third in the last 25 years[7].
  2. Despite these concerning declines in soil health, there have been very few new policies to reverse these trends or encourage action. The development of new policies and targets on soil health has been hampered by the absence of nationwide soil monitoring and a lack of baseline data, which in turn has been blamed on a lack of funding and prioritisation of soils at the policy level[8]. Some progress has been made as a result of the 25 Year Plan for the Environment, the Scottish Soil Framework and the Well-being of Future Generations Act, which for the first time have laid out goals for improving soil health across the UK. However, alone these targets do not commit to any new policies or investment and will be insufficient to reduce the declines in soil health we are observing.
  3. Despite the recent development of soil-based targets, regulations governing soil health are very limited and split across a number of directives and policy mechanisms. A few regulations applicable to soil health can be found scattered across the Farming rules for water (2018), the Water Framework Directive and the Environmental Impact Assessment Agriculture regulations. Cross Compliance is one of the main mechanisms that sets out rules for landowners and managers to maintain soil health, specifically rules ‘GAEC 4’, ‘GAEC 5’ and ‘GAEC6’. However, in the past Cross Compliance has been criticised for being difficult to assess, lacking in accountability and limited in scope with regards to the range of measures needed to restore soil health[9]. The Government have also stated that Cross Compliance will come to an end in 2024, and it is currently unclear what, if anything, will replace it. Without a replacement, there is a risk that we will therefore lose the only regulatory baseline currently in effect for soils.
  4. When it comes to declining soil health there is no time to lose, so the Government must urgently set out new regulations and strengthen the regulatory baseline to reverse soil health declines. To start, a new regulatory baseline should be introduced that, as a minimum, incorporates the protections for soil that will be lost when Cross Compliance ends in 2024. This should then be built on with additional regulations designed to protect soil structure, increase soil carbon levels, and increase soil biodiversity. Requirements for comprehensive soil monitoring should also feature in new soil regulations, to combat the lack of historical monitoring that has hampered action to promote soil health thus far. Alongside outlining a regulatory baseline and introducing new soil regulations, proper enforcement of the regulations is needed. There is currently a very low bar when it comes to requirements for soil health actions, but even this low bar is often ignored. To prevent this happening with newly introduced regulations, adequate enforcement activity is needed when breaches do occur.
  5. Alongside regulations, a clear roadmap of how the Government aims to meet the target of having soils managed sustainably by 2030 is needed. It was hoped that the Soil Health Action Plan for England may go some way towards providing this, but this has now been incorporated into the recently published Environmental Improvement Plan (EIP). Unfortunately, the EIP has significantly watered down the target to make sure all soils are sustainably managed by 2030, and has not outlined any new regulations, additional funding, or a clear plan to seriously address soil health declines. Whilst the pledges to establish a soil health indicator and a baseline soil health map for England are welcome, the lack of detail on how to meet the target and lowering of ambition is very disappointing and suggests soil health is slipping down the list of priorities once more. Rather than scaling back its targets and releasing vague promises, it is vital that the Government increases ambition and sets out a comprehensive, adequately funded plan to improve soil health.


Q3. 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. The ELMs standards announced so far in the Sustainable Farming Incentive (SFI) lack the ambition needed to restore soils across agricultural land. The current soils standards only pay for basic soil health actions that many farmers already carry out, and prior to the January 2023 changes, surveys indicated that the payment rates were insufficient to attract farmers into the scheme[10]. This, combined with low regulatory baselines and the current lack of a mechanism to ratchet up ambition in the standards over time, will mean soil health declines are not sufficiently addressed.
  2. To improve the ambition of the SFI, new actions should be introduced to the soils standards that offer payments for a wider range of soil health actions, including supporting switches to reduced tillage regimes, the introduction of leys or fertility-building crops, and actions designed to reduce compaction. Despite compaction being identified by Defra as one of the three main threats to soil health, there are currently no actions aimed at addressing this issue. As well as a wider range of actions, an advanced level should also be added to the soils standards, and payment rates improved so that the SFI becomes more attractive and beneficial to farmers.
  3. Alongside improvements to the SFI Soils Standards, the scheme must ensure that further actions which contribute to soil health are rolled out as a matter of urgency and designed in a way that allows integration with the soil standards. These include actions to reduce pesticide use and promote the adoption of IPM techniques, as pesticides have been shown to reduce soil biodiversity and have negative effects for overall soil health[11]. Alongside ambitious IPM actions, payments for farmers to create space for nature and improve on-farm biodiversity should also be introduced, as this has also been linked to improved soil health outcomes[12]. The SFI could be further strengthened by the inclusion of an action to measure soil biodiversity, so that the importance of this key pillar of soil health is recognised and properly monitored.
  4. To ensure the SFI standards reach the level of ambition needed to achieve the Governments soil target, it will be necessary to increase their ambition over time. While it is understandable that the early offer for the SFI presents a low barrier-to-entry for farmers, if the scheme is to generate the scale of action needed there needs to be a ratcheting up of ambition overtime, so that farmers continue to take new steps to improve the health of their soils. Defra have acknowledged the need to do this[13], but more details of how ambition will be ratcheted up has yet to be provided.
  5. Finally, it is important to stress that soil health should not just be seen through the lens of the SFI and productive agricultural land. It should also be an important consideration in both the Countryside Stewardship Plus and Landscape Recovery schemes, as soil is far more than just a substrate in which plants grow. It is a complex, diverse, living ecosystem, that provides many ecosystem services above and beyond food production[14]. It is therefore deserving of protection and should be a key consideration in all the ELMs schemes.


Q4. 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. Firstly, a focus on providing better soil health training and education at all levels of the education system is needed. This includes in schools, colleges, and university courses, as well as specialised agricultural institutions and farm advice courses. Soil health has long been neglected in education[15], leading to a shortage in knowledge and information sources that would help to bring about change. Tackling this lack of soils content will allow farmers and other land managers to improve their own knowledge of soil health, whilst also accessing quality advice from trusted advisors.
  2. Alongside soil health education, we also need to see wider shifts away from intensive livestock farming systems with high stocking densities, because of the poaching, compaction, and nutrient overloading issues that are associated with them[16] . If managed appropriately, moving away from specialised intensive livestock systems towards more extensive and mixed farming systems could bring soil health benefits to degraded arable land, and free up land that is currently used to grow animal feed. Growing cereal crops to feed animals currently takes up 40% of all the UK’s available cropland and is itself also associated with soil degradation[17]. As well as improving soil health, a shift to lower stocking densities could bring other environmental and climate benefits, whilst also boosting farm profitability by reducing the amount of money spent on inputs to support high livestock numbers[18]. The government can support a shift to lower livestock densities through additional options in ELMs, and by offering incentives and training for farmers to reduce their inputs and improve soil health outcomes.
  3. Linked to the above, the wider food and farming sector need to shift away from a heavy dependence on agrochemicals and veterinary medicines, and instead embrace more agroecological and regenerative farming approaches. The use of large amounts of artificial fertilisers, pesticides and antibiotics disrupts the soil ecosystem, leading to a range of negative outcomes that lower soil health[19]. This often leads to a vicious cycle, where declining soil health means that farmers are forced to use ever increasing amounts of pesticides and fertilisers just to maintain their yields[20]. More support for farmers who want to break this cycle and shift to more agroecological farming practises that do not lock in a dependence on artificial inputs is therefore needed, including through increased training, promotion of peer-peer learning opportunities and financial support.

Q5. What does the UK Government need to do to tackle other stressors on soil health such as soil contamination?

  1. Alongside the recommendations included above, taking action to reverse the wider decline of nature will be crucial to tackling other stressors on soil health. This is because nature and soils are intricately linked, with more than 25% of the world’s biodiversity found in soils[21]. Without nature, our soil systems would quickly collapse. It is therefore vital that the Government boosts progress towards meeting the Environment Act nature targets and provides more funding to tackle nature’s decline. The Government should also scrap the Retained EU Law Bill, as this currently threatens hundreds of pieces of active environmental legislation that were designed to protect nature[22].
  2. The nature crisis is also inextricably linked to the climate crisis, and taking bold and decisive action to address the climate emergency will also help to promote soil health. There is more carbon in the soil than there is in all the aboveground living organisms and atmosphere combined[23]. Protecting and increasing the carbon stored in soils is vital if we are to achieve the Government’s Net Zero target. Unfortunately, because of intensive agriculture, the UK has already observed soil carbon levels declining in recent decades[24], which is concurrent with the decline in soil health. Reversing this trend will help to tackle climate change and promote soil health, so the Government must look at linking action on soil health with measures to reach Net Zero.



February 2023

[1] https://www.nature.com/articles/s43017-020-0080-8

[2] https://www.pnas.org/doi/pdf/10.1073/pnas.1320054111

[3] https://connect-apps.ceh.ac.uk/soilhealth/

[4] https://www.sustainablesoils.org/?view=article&id=706:ellen-fay-ssa-wcss-legacy-article


[6] https://www.sciencedirect.com/science/article/pii/S0921800915003171#bb0095

[7] https://www.theguardian.com/environment/2022/dec/19/earthworms-may-have-declined-by-a-third-in-uk-study-reveals

[8] https://sustainablesoils.org/about-soils/uk-soil-policies

[9] https://publications.parliament.uk/pa/cm201617/cmselect/cmenvaud/180/18007.htm

[10] https://www.cla.org.uk/news/preparing-for-agricultural-change/

[11] https://www.sciencedirect.com/science/article/pii/S0960982219310231

[12] For example see https://ami-journals.onlinelibrary.wiley.com/doi/abs/10.1111/j.1462-2920.2005.00888.x and https://www.sciencedirect.com/science/article/pii/S0167880901002468

[13] https://www.gov.uk/government/publications/environmental-land-management-update-how-government-will-pay-for-land-based-environment-and-climate-goods-and-services/environmental-land-management-elm-update-how-government-will-pay-for-land-based-environment-and-climate-goods-and-services

[14] https://www.sciencedirect.com/science/article/pii/S2468584417300326

[15] https://www.sciencedirect.com/science/article/pii/S0016706122003603

[16] https://acsess.onlinelibrary.wiley.com/doi/full/10.2134/jeq2017.08.0313 and https://www.fao.org/fileadmin/templates/lead/pdf/nutrient_balance_europe.pdf

[17] https://www.wwf.org.uk/sites/default/files/2022-06/future_of_feed_full_report.pdf

[18] https://www.wildlifetrusts.org/sites/default/files/2019-11/Hill%20farm%20profitability%20report%20-%20FINAL%20agreed%2015%20Nov%2019.pdf

[19] https://www.sciencedirect.com/science/article/pii/S0006320722000283#bb0470


[21] https://www.fao.org/global-soil-partnership/resources/highlights/detail/en/c/1309274/#:%7E:text=Soils%20are%20a%20reservoir%20of%20biodiversity.&text=In%20fact%2C%20soils%20are%20home,in%20return%2C%20nurture%20the%20soil.

[22] https://www.wildlifetrusts.org/news/four-nations-nature-charities-denounce-government-bill

[23] https://www.nature.com/scitable/knowledge/library/soil-carbon-storage-84223790/