Written Evidence submitted by ARCADIS (SH0074)

Executive Summary

Arcadis is the leading global Design & Consultancy firm for natural and built assets. Applying our deep market sector insights and collective design, consultancy, engineering, project, and management services we work in partnership with over 1,800 clients across the world to deliver exceptional and sustainable results throughout the lifecycle of their natural and built assets.

We are 27,000 people active in over 70 countries that generate €3.3 billion in revenues. In the UK we employ over 4,000 professionals across 27 offices. We support UN-Habitat with knowledge and expertise to improve the quality of life in rapidly growing cities around the world. Arcadis’ vision is to improve the quality of everyday life for all citizens.

Everyone should have a vested interest in our soils being healthy and fit for purpose.  Our food is grown in soil.  We grow fuel in our soils. Soils soak up rainfall and slow its progress to rivers, reducing the risk of flooding and filtering and purifying water. Carbon is stored in our soils, reducing the amount of carbon dioxide going into the atmosphere. Soils contain and allow to thrive an immensely diverse biodiversity. Soils support the landscapes we see, giving us aesthetic, spiritual, cultural and educational benefits.

Soil, and its health, is central and critical to key global issues which affect peoples’ livelihoods, health and welfare. Quality of life and, ultimately, the sustainability of the environment are contingent upon our soils. The reality we face is that society must learn to use and manage the world’s soil resources in a sustainable manner to secure a healthy, wealthy and sustainable future for generations to come.

We recommend that Government:

• develops and promotes a legislative framework, applicable to all settings and sectors, which gives soil the same status as air, water and biodiversity
• ensures existing relevant legislation supports the requirement for soil assessments and monitoring
• sets and implements clear targets, applicable to all sectors, for soil health monitoring and develops a long-term soil monitoring programme
• ensures government bodies have sufficient legal enforcement powers and resources in relation to soil health
• supports and funds on-going and future research in soil science and draws on existing and emerging evidence to define and update legislation and policy
• sets out an incentivisation structure based on medium to long-term outcomes which are evidenced through monitoring and which account for both the starting point and direction of travel for each measured metric
• supports and promotes enhanced public education and engagement in relation to the importance of soil to our sustainable future

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?

Our existing legislation and policies recognise the importance of air quality, water quality and biodiversity for human and planetary health.  Soil is equally important to human and planetary health, and this is well understood.  Soils support food production and biodiversity; both as a platform for above ground biodiversity and for the biodiversity within soils, much of which is still to be fully understood. Soils play a fundamental role in the quality and availability of water and in pollution control, are the foundation for construction and infrastructure and preserve the earth's history and cultural heritage. Importantly, the role soils play in climate change mitigation and adaptation is clear and as such improving soil health and managing soils sustainably is critical to our ability to achieve a sustainable future.

As such, there is a need to ensure the importance of soils is recognised and that there are appropriate and agreed measures in place to assess the current state of soil health and the direction of travel in the long-term. It is important that this framework recognises the value of soils in all settings, not just associated with agriculture and rural areas.  The soils, and the green spaces they support, in urban environments are equally important, and are critical in the reconnecting of people and communities with nature.

However, a framework to monitor soil health does not currently exist.  A first step has to be to set out a legislative and policy framework that will drive the ambition we need for achieving sustainable soil management. This must include a long-term soil monitoring programme across all sectors where soils are affected by land management and land use practices. 

Significant efforts have been made to develop suitable indicators for soil quality and soil health, and the government must draw on the evidence which exists and support new research initiatives in this area.  Soils are complex; there are more than 700 different soil types in England and Wales alone, and within this there is local variability. As such, the framework needs to set out how soil health should be measured and monitored at a range of scales, from national programmes to on-farm and site-specific assessments. This is likely to require the setting of broad principles with a requirement for projects to demonstrate through sampling and monitoring that soil health for that specific location is understood and the measures in place can support a positive change/maintenance of already healthy soils against analogous sites or historical data (such as the partial baseline provided by soil surveys carried out in the UK up to the late 1980s). Aspects of soils such as soil structure, soil organic carbon and soil biology must be central to this monitoring. In particular, soil biology, often not covered by standard monitoring on land restoration projects, must be included and draw on evolving innovation around eDNA.

It is considered that a range of incentives will be needed across different sectors aligned to a reporting and legislative framework.

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

There are few requirements in any sector that landowners or managers are required to adhere to in relation to soil health.

In the agricultural sector schemes such as the Environmental Land Management Schemes (ELMS) provide incentives for farmers and landowners to meet minimum standards of soil care, but uptake of the Sustainable Farming Initiative is currently low and so perhaps the incentives are not sufficient to drive larger-scale uptake. Agri-environment schemes, such as Countryside Stewardship or Catchment Sensitive Farming, require soil monitoring but entry to these schemes is voluntary.

The Defra Code of practice for the sustainable use of soils on construction sites provides guidance for how soils should be handled and re-used on construction sites.  However, it is guidance and whilst many projects follow this (for example in developing Soil Management Plans), the guidance does not set out how soil monitoring should be undertaken. Many Soil Management Plans are not implemented or monitored by properly experienced and trained individuals. The outcome from the ongoing review of this code must set out clear guidance on the requirements for implementation and monitoring and the expertise needed to undertake this work, and this needs to be supported by a framework of legislation and policy in relation to soil health.

The revised Defra Code, along with a policy framework, needs to ensure there is sufficient emphasis on soil planning (for example a requirement to define A Project Soil Strategy) and effective soil re-use which maintains the optimal suite of soil functionality for a given scenario.  This needs to support soil re-use between sites to avoid surplus topsoil ending up in large bunds or, worst-case scenario, in landfill.

Monitoring, and the competent evaluation, analysis and communication of the data, will be central in supporting land managers to adopt and implement long-term effective soil health improving practices. Incentives should also be provided for organisations to share information more widely on land management practices which have been implemented and the outcome for soil health, whether positive or negative.  This will require organisations to have access to expert and trusted advice and it is key that advisory organisations and individuals working within different sectors have recognised expertise in soil science through chartership, CPD training (such as the British Society of Soil Science Working with Soils programme) and accredited educational programmes.

Overall, legal protection for soils, which recognises a minimum level of soil health along with a requirement to improve the health of degraded soils, will be essential and will need to be combined with incentive mechanisms which are available across all sectors.  This must be paired with sufficient legal enforcement powers and resources for organisations such as Natural England and local planning authorities. It will also be critical to link this protection and incentivisation to other legislation etc. to avoid single environmental issues dominating and becoming a barrier to holistic solutions. For example, the requirement for Biodiversity Net Gain or Natural Flood Management should include a requirement for soil assessments and monitoring to ensure healthy soils are part of the outcome. 

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?

The evidence base to answer this question is currently lacking.  Adding organic matter at least once every three years, as required under the Sustainable Farming Initiative, can result in improvements in soil physical quality over time[1], but more data is required to ensure the standards do deliver short-term results which are maintained and built on in the long-term. A framework of monitoring across scales from national programmes to on-farm assessments will support this. However, these evidence gaps should not be used as a reason to stall implementation of practices which are likely to provide benefits (for both the soil and wider environmental benefits associated with healthy soils, such as flood risk reduction and biodiversity) as there is a growing body of evidence and experience that can be drawn on (for example techniques such as reduced cropping and tillage producing higher yields[2] [3]).

The ambition and flexibility under ELMs needs to be kept under constant review.  For example, guidance is provided on completing a soil management plan, but this is followed by a statement that this does not need to be followed.  Payments are in part related to the data captured; consistency in the data will be important in it’s interpretation and as such the framework for monitoring, which addresses the requirement at all scales, will be critical to ensuring the ambition is sufficient to deliver tangible outcomes, and that the interventions can be adapted as new data becomes available.

The link between sustainable soil management techniques (such as those which limit soil disturbance) and carbon storage[4] needs to be highlighted more widely.  Whilst some caution is needed with this at the moment as benefits may only be realised in the medium to long-term, more research is needed and additional soil carbon sequestered can easily be reversed as above this should not be used to limit the implementation of such techniques which are widely recognised as very likely to have a range of positive environmental benefits.

It will be important to assess the level of uptake and how the incentives work to engage with all land managers. In particular, there is a risk of benefiting those who are starting from a point of poor soil health and low soil carbon, penalising those who have traditionally undertaken land management to ensure soil health is improved and carbon sequestered and maintained.  As such, incentives must be based on medium to long-term outcomes which are evidenced through monitoring and which account for both the starting point and direction of travel for each measured metric.

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?

This is an exceptionally difficult question given conflicting demands of food security, decarbonisation of agriculture, reforestation, and improved biodiversity/soil health. However, there is a clear need to elevate soils to the same level as air, water and biodiversity, set the metrics by which soil health can be measured and ensure that the whole supply chain, from farmer to supermarket chain and consumer, understand and promote the importance of soils.

There will need to be trade-offs. For example, monitoring may require additional investment which may result in a price increase for the final product.  But this will need to be measured against the wider environmental benefits realised which in themselves should result in reduced costs elsewhere (for example better soil management leading to reduced flood risk and reduced sediment build up in drainage channels and networks). Changes to policy, legislation, funding and planning must seek to enable the delivery of holistic solutions which maximise the potential benefits at any given location and for any given circumstance, minimise trade-offs and ensure effective communication of the rationale, based on the benefits which will be realised, to the local communities.

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

Measures introduced to provide a legislative and policy framework, and associated monitoring and reporting, for soil health must take a holistic approach and as such should encompass issues such as soil contamination. Much contamination is historical and often the contaminated soil is simply disposed of in landfill.  Support should be provided in terms of waste regulations (and their review to ensure they are fit for purpose and support a truly circular economy) and in terms of funding for innovative remediation techniques which can enable greater material re-use. Incentives should be provided to ensure the planning of remediation projects takes into account a proposed end use and which ensures the remediated soil materials can support the maximum potential environmental benefits at that location, for example through tree planting, habitat creation, flood risk reduction etc.

More emphasis should be placed on the use of Tier 3 land contamination risk assessment, as detailed in the land contamination risk management guidance (LCRM), rather than relying on generic assessments to inform the extent of remediation required (and hence risking larger quantities of soil going to landfill). This will require support for more education of regulators to increase their understanding and hence willingness to drive this with contractors, developers and consultants; this would reduce the potential for simple approaches to be taken and reduce the volume going to landfill.

A system thinking approach will need to be promoted – ensuring that solutions are developed which maximise the potential benefits at any given location and for any given circumstance, minimise trade-offs and ensure effective communication of the rationale, based on the benefits which will be realised, to the local communities. Incentives should require the delivery of holistic solutions which reduce the pressures soils face from the whole range of stressors, from contamination, improper disposal, erosion, microplastics, soil organic matter loss, structural degradation and soil sealing. For example, incentives could be provided for housing schemes which maximise the extent of green spaces, use innovative approaches to Masterplanning to drive this and which deliver (through setting soil a soil strategy) quality green space which delivers as wide a range of ecosystem services as possible for that given location.

Overall, legal protection for soils, which recognises a minimum level of soil health for the full range of land use scenarios, along with a requirement to improve the health of degraded soils, will be essential and will need to be combined with incentive mechanisms which are available across all sectors.  As noted in responses to previous questions this must be paired with sufficient legal enforcement powers and resources for organisations such as Natural England, the Environment Agency and local planning authorities. But it will also be important for the legal and policy framework to be reviewed and updated regularly.  New techniques will be developed as the evidence evolves, alongside a growing understanding of emerging contaminants. Those involved in soil health will need to remain agile, and the framework within which they operate will need to be able to respond to changes.

February 2023