Written Evidence submitted by The Energy Institute (SH0070)

The health of soil in the UK – soils ability to function as a vital living ecosystem that sustains plants, animals, and humans – faces challenges from contamination, nutrient loss, erosion and compaction. The impact of this is likely to be significant through accelerating climate change, increasing the chance of flooding, reducing the productivity of farms and losing an important ecosystem for bacteria, fungi and invertebrates. The inquiry will look at why soil health continues to be a problem and consider how the UK Government can accelerate soil restoration in England.

The Committee invites submissions on the following:

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 how can these barriers be overcome?

A1. Although several definitions are in circulation, and this call for evidence references “soils ability to function as a vital living ecosystem that sustains plants, animals, and humans” – there is no definition we are aware of that UK Government have adopted for ‘Soil Health’. In support of the EU Soil Health Framework, the European Environment Agency 18 Jan 23023 EEA – Indicators and thresholds for soil health assessments – it is acknowledged that the “concept of soil health is defined in a variety of ways in the literature”. 

In order to [make all soils sustainably managed by 2030] - A common, agreed definition of ‘Soil Health’ is needed before metrics can established against which to measure the goal of making all soils sustainably managed by 2030.

In terms of [challenges in gathering data], like many parts of the UK Land Management process – soil health data should consider the ‘end use’ of soils. Soil in the UK is present in a range of rural and urban settings, and provides a range of functions – from agriculture to infrastructure. The collection / measurement of soil health of soil used for example, in crop growth, woodland or under a building/factory providing different functions, will need to be captured and compared differently.


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

A2. Members of the Energy Institute represent users that principally have a range of industrial uses of soil – that is to say soil is used in multiple scenarios – from a wind turbine within an agricultural scenario, to an oil refinery within an industrial complex.

When considering [regulations to ensure that all landowners/land managers maintain and/or improve soil health] - In general, though experience varies:

-          Where soil health is managed early in the facility life it is though the planning process - where (if applied) specific requirements are made on environmental protection (e.g. soil).

-          Through facility operation, principally permitting requirements are used to control soil health (e.g. the Baseline Survey as part the Integrated Pollution Prevention and Control (the IPPC Directive). The focus, broadly, is in preventing further degradation of soils, and in mitigating the impact of any pollution to soils – rather than improving soil health.

If there is a move to [consider improvement of regulations and improve soil health] – then understanding the ‘end use’ of the soil and its’ functions should be embedded in regulation. This would be consistent with a proportional, risk based implementation of regulation and would acknowledge the benefits that anthropogenic use of land, and the soil below it, has bought to society.

Of course, although regulation should be best aligned for the needs of the United Kingdom, a close alignment with the developments of Soil Heath in the European Union would likely mean easier interaction and dialogue on the complex topic of soil with our European colleagues.


Q3. 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?

A3. It is understood that the schemes to reward environmental land management all focus on Agricultural use of land under the headings of the Sustainable Farming Incentive, Local Nature Recovery, and Landscape Recovery.

In the UK Government Farming statistics report (June 2021) it is reported that the total utilised agricultural area in England is just over 8.8 million hectares (of a total 13.3 million hectares as reported by the ONS). Energy Institute members therefore recognise that Environmental Land Management schemes must focus on agricultural land use. We would welcome the opportunity to comment on [threats and opportunities for soil health under ELMs] if those are devised for industrial land.


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?

A4.  Although individual members might have views, as an organisation, the Energy Institute will not comment on the appropriateness of regulation in other sectors.


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

[to tackle other stressors on soil health such as soil contamination] Energy Institute members would request the UK Government implement new Soil Health regulations in a way that complement the current land contamination risk management framework and the land use planning framework.

Regulation should allow for appropriate identification, management, remediation, and disposition / beneficial reuse of Contaminated Land, in a well-regulated framework that encourages voluntary action. A reasonable framework would incorporate:


Soil management on brownfield sites should be founded on risk-based management principles. It should require development of a conceptual site model (e.g., ISO 21365:2019), supported by a relevant soil survey, that identifies source-pathway-receptor linkages and incorporates sustainability assessment (e.g. ISO 18504:2017, Sustainable Remediation). This permits remedy selection and implementation for soil contamination, but also seeks to enhance soil quality to support future use, including biodiversity net gain. This will encourage re-use of contaminated land for future beneficial uses and does not place new barriers to the successful regeneration of sites. Excavated soil should be managed as a resource on sites, not as a waste, unless it is discarded off site.



Land management on brownfield sites requires remediation actions proportional to the risk(s) to human health / environment, and does not require remediation where there is no unacceptable risk. Treatment of high risk, recalcitrant chemicals may require high energy, destructive technologies to reduce loading to acceptable levels – and this may transform soils and affect soil quality/health. Treatment technologies should be subject to assessments to determine the greatest net environmental benefit, which should include potential enhancement of residual soil to enhance all soil functions.



February 2023