Written Evidence submitted by the National Institute of Agricultural Botany (NIAB)(SH0064)

In spring 2018, individuals from across the agricultural sector met together in a series of meetings facilitated by NIAB to discuss the opportunity of developing an integrated cross-sector industry-led initiative to promote voluntary action on soil health: The UK Soil Health Initiative (UKSHi). In subsequent years, the UKSHi has co-ordinated a similar series of meetings which developed agreed message for land managers across a range of farming systems published as 6 guides in June 2021 (https://www.cfeonline.org.uk/environmental-management/uk-soil-health-initiative-guides/)  The response of NIAB below draws strongly from the agreed messages of UKSHi – where the response reflects the reflection / opinion of NIAB alone we will make that clear.

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 how can these barriers be overcome? 

• The government has existing baseline data (and some archived samples) for soil health from data collected during the statistically robust Countryside Survey Programme 1978-2007. After 2007, the programme was not centrally-funded. Since 2019 UKCEH have obtained some funding to operate a smaller rolling programme with a proportion of sites sampled each year.  A full updated sampling and analysis programme would deliver robust, up-to-date national data on soil health and more complete information on the linkage with wider environmental goals.
• To achieve useful and statistically robust national scale monitoring of land use and soil health, this survey should then be repeated at monitoring intervals of no more than 10 year intervals, as part of a regular committed environmental monitoring programme, alongside the existing schemes for monitoring air and water quality. These data would both i) provide the basis for sound policy making and ii) ensure adequate reporting on national and international commitments.
• It would be appropriate to build on the existing Countryside Survey methodology in order to provide long-term understanding of the role of soils and land management in mitigating climate change by adding some assessment of subsoil including measures of the terrestrial carbon stock to 1 metre depth at a sub-set of monitoring sites.
• It is also important to collate robust data on the soil management practices used on farm. This could be done  by adding appropriate questions on soil health improving measures to national stratified surveys e.g. Farming Practice survey in order to be able to track the rapid changes already underway in tillage practice and cropping sequence (rotation).

• Data from 250,000 soil samples submitted for routine soil analysis by farmers is already summarised annually by the Professional Agricultural Analysis Group (PAAG). These data are not a representative sample and hence do not give a robust picture of soil health at national / regional scale. 

• The industry has made a commitment to work together to develop a database with enhanced farm/field metadata so that it can be used as an anonymised farm citizen science resource to provide benchmarking for farm data collected at soil type, farm system and/or catchment level to support on-farm improvement.

• NIAB that this pre-competitive commitment by the industry will nonetheless take significant co-ordination and some additional research funding to deliver. A recent Farming Innovation Bid was unsuccessful, feedback is currently awaited, but we recognise that cross-industry working for public good delivery does not fit easily into current funding models.  If the industry were to be successful in gaining funding to deliver this resource, it is believed that as the database grows, there would be an opportunity to develop the resource alongside Defra (and especially the ASFI requirements). This would enable the collated resource to be used to support answers to policy questions by providing added granularity to the more robust Countryside Survey data.

• As an example of progress in this area, we would direct the Committee’s attention to the AHDB/BBRO Soil Health scorecard approach, which used a co-development approach led by NIAB working with industry to establish a set of measures and an interpretation framework that can be applied to mineral soils under lowland agricultural management. Last year, guidance on how the scorecard might be applied to these soils in England was published.  This follows the precedent of the RB209 nutrient management guide, also held by the AHDB[1] which established a uniform approach to nutrient management. 

• This scorecard approach includes visual assessment of topsoil and we believe that it should be extended to include an assessment of subsoil as part of wider risk assessment approaches for soil loss/runoff.  Such a tool was developed by Defra in 2022 under its Soil Structure Measuring and Monitoring scheme[2] and referred to by ministers on various occasions.[3] It would also be possible to use the co-development approach to extend the Soil Health scorecard approach to other semi-natural systems and urban soils.

• It is also possible to assess progress towards this goal, by focussing not on the soils themselves but on the impacts of non-sustainably managed soils – i.e. if nitrate or sediment (turbidity) pollution is at the desired levels in water courses then we could probably assume soil is being managed in a way that is not posing large risks to these environments. Ideally, up-stream (soil health measures) and downstream (environmental measures – water and air quality) should be assessed together potentially on a more local catchment or regional scale.

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

The principal regulations that apply to farm soils in England are the Farming Rules for Water (FRfW) (2018), created to achieve compliance with the EU Water Framework Directive and transposed into domestic Diffuse Pollution legislation in 2018.  Inn the past, GAEC rules 4, 5, 6 required farmers to achieve minimum soil cover, minimise soil erosion and maintain the level of organic matter in soil, but have been phased out since the end of cross-compliance.

Taken alone the FRfW regulations do not give a full or complete framework within which farmers might be enabled to understand how and why their actions might be deleterious for soils’ services and functions - or the threats they face.  Significant damage caused to soil (e.g. wind erosion) has little to do with water, while some damage caused by poor soil management (carbon and biodiversity loss) would not be measurable where indirect water quality metrics were used alone.

Few data seem to have been gathered about the implementation of the Farming Rules. NIAB works closely with its farmer members on technical issues, but have no role with regard to legal compliance.  Our observation is that full awareness of the requirements is patchy even amongst technically able farmers. This does not mean that they are not complying but the lack of a single clear regulatory framework that brings together land management requirements (whether for agriculture or more broadly to cover forestry, construction etc) and is focussed on measurable outcomes is a major constraint.

3. 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? 

NIAB have noted amongst its farmer members that ELMs uptake is currently balanced a bit precariously. There is the danger that if commodity prices stay high or climb then the current funding level and what the schemes are offering will be hard to compete with the increased development of systems focussed mainly on high saleable outputs. These are increasingly including private sector offers such as Biodiversity Net Gain and tree planting associated with carbon credit schemes, However with input prices and fuel prices increasing rapidly, ELMs also may fit well with a wave of farmers attempting to make their operation more efficient whether that is by using less inputs rotationally or minimising cultivations etc.  

Linked to the discussion of monitoring, we note that ELMs currently encourages farmers (through payments) to monitor soil properties such as OM and VESS.  Linking payments to measured target values is fraught with difficulty and should not be part of the direction of travel, but with a clear simple protocol (e.g. agreed GPS located points on farm that were tested regularly by the farmer) the results could be collated across the whole scheme independently with a payment for anonymised data sharing rather for the results obtained. We note that this would be logistically difficult and potentially too prescriptive, but as outlined by UKSHi a cross-industry partnership working with government would be ideally placed to deliver such an initiative.

4. What changes do we need to see in the wider food and as agriculture sector to encourage better soil management and how can the Government support this transition? 

Supply chain pressures are one of the major drivers of soil damage.  NIAB are aware that farmers knowingly damage their soils (e.g. harvesting in wet weather) because they fear breaching the delivery terms of a customer agreement.

Since food retailers and manufacturers have both a responsibility and a vested interest in the long-term sustainability of soils, better engagement and alignment of retailer expectations and requirements with the regulatory baseline (at least) or best in the development of new ways of working that reward better soil management is a clear opportunity to improve both awareness and effectiveness of the rules and drive soil health.

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

No answer.

February 2023