Written Evidence submitted by The Game & Wildlife Conservation Trust (GWCT)(SH0076)

The Game & Wildlife Conservation Trust (GWCT) (www.gwct.org.uk) is a leading, independent UK wildlife conservation charity conducting scientific research into Britain’s game and wildlife to enhance the British countryside for public benefit.  We use our research to provide training and advice on how best to improve the biodiversity of the British countryside.  We employ 22 post-doctoral scientists and 50 other research staff with expertise in areas such as birds, insects, mammals, farming and farmland ecology, fish and statistics. The GWCT’s Allerton Project, our demonstration farm in Leicestershire, undertakes research into the effects of different farming methods on wildlife and the environment including soil health, and shares the results of this research through educational activities for practitioners and the public (https://www.allertontrust.org.uk ).     

Summary

Whilst we provide more detail in the answers below there are some key points we would like to emphasise:

1. The downgrading of the policy support for soils through the shelving of the Ministerial promise of an Action Plan is disappointing and ultimately short-sighted given the long-term nature of soil-based measures.  Endeavours to put soil on the face of the Environment Act were ameliorated by the promise of a Soil Health Action Plan for England (SHAPE) in 2021.  Its subsummation into the EIP23 has downgraded not only the regulatory regime but also the potential for soil health restoration through a structured action plan.  It is now reliant on a series of (currently) un-connected incentives, mostly relating to the Environmental Land Management Scheme (ELMS).  Such schemes only relate to the parcels of land entered into them.
2. The flagship claim of BREXIT is that it empowers us to draw up legislation which reflects more closely our own needs and desires. Stripping away existing EU legacy rules is all well and good, provided only if they are replaced by legislation which is better. While the EU presses ahead with its own plans to protect soils this Government is failing to heed the experts and seize another BREXIT opportunity.
3. Government needs to provide a framework that promotes long-term investment in the sustainable management of our soils (agricultural, urban, forestry, peatland etc) through easily monitored measurables supported by a ‘code of practice’.  The Soil Health Action Plan for England would have provided this by coordinating current policy initiatives and bringing together expert opinion. We would, therefore, like to have clarity from Defra on how all the initiatives related to the actions to protect and improve soil health outlined in the EIP23 fit together. 
4. A framework would also provide the confidence needed to encourage shared investment in our soils by land managers and businesses, including private finance to supplement the public money already committed through the Sustainable Farming Incentive (SFI) soil measures.
5. Further delays to introducing a metric to monitor soil health is not an option and consequently we welcome Government’s continued commitment to establish a soil health indicator in the EIP23.  Whilst the complexities mean a single metric is difficult, the measurement of soil chemical and biological properties supported by management that improves physical properties could be introduced for all soil types. The soils and the climate in England are relatively homogeneous compared with an area the size of the EU, which again presents us with a unique opportunity to design metrics which are fit for purpose.
6. Data collection alone is not sufficient to engender progress.  Best practice management advice across all land uses and soil types (i.e. not just those covered by ELMS) is needed.  This advice should relate to the multiple outcomes desired.
7. Soil health measures (both metrics and management) need to be easily adopted by land managers and be related to all soil functions and ecosystem services.

The Committee invites submissions on the following 5 questions:

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?

1.1.             When this inquiry was launched the Committee stated that it would analyse the Government’s role in preventing further soil degradation and restoration through ELMS and SHAPE.  Hence the phrasing of this question regarding sustainable soil management by 2030.  At the time of writing the EIP23 has just been released into which Government had subsumed SHAPE.  This appears a downgrade from a ministerial commitment made to establish an action plan in September 2021 during debate at report stage in the House of Lords on putting soil health on the face of the Environment Bill[1].  This was followed by a ministerial statement in October 2021 which concluded “The soil health action plan for England will provide a single, strategic approach to achieving these multiple outcomes and driving improved soil health across England, and we currently intend to consult on the framework next spring.”[2]

1.2.             The EIP23 chapter on soil health is a shadow of what we and other NGOs who are concerned about soil health had hoped that the SHAPE would be.  Not only has it downgraded targets for soil health (now “at least 40% of England’s agricultural soil [our emphasis] into sustainable management by 2028, and increase this to 60% by 2030”) but it has also removed the potential to achieve success across all soil types and functions by focussing on delivering soil health largely through ELMS. 

1.3.             We also have concerns about the ability to achieve these timescales given that the OEP felt it was “unrealistic to achieve the sustainable management of soils by 2030”[3].  This is despite a strategy in place to achieve this which was published in 2011 – “Safeguarding our Soils”.

1.4.             Using ELMS as the main mechanism has short-comings – not only in its ability to restore agricultural soils (a point we expand upon in answer to Q3) but more importantly in its ability to monitor the health and restoration of all our soil types and associated land uses.  If 70% of England’s soil is agricultural that leaves a significant 30% related to other land uses.  We are therefore interested in what exactly Government means by its statement in the EIP23 that “Defra will… provide a methodology and tools to collect consistent information about the health of the soil under all land uses”[4].

1.5.             In addition, ELMS only relates to the parcels of land entered into the scheme(s) on a voluntary basis (see also 2.2 below) and we are concerned by the lack of ambition evident from the standards/scheme options presented to date

1.6.             We are also concerned that the absence of an Action Plan means that the benefits of cross-compliance, that are being lost due to the removal of direct payments, cannot be emphasised and their continued adoption encouraged.  ELMS options are voluntary.

The remaining points address the challenge of developing suitable soil health metrics so that the targets Government set can be effectively monitored.

1.7.             Soil health[5] is so fundamental to the future sustainable management of our land that we need to act now.  The key is to create an agreed set of metrics that landowners, managers and farmers can easily adopt based on agreed measurables that indicate whether progress in soil health is being achieved.

1.8.             However, soil is a living organism that is the result of various processes resulting in different soil properties (and therefore health properties) which in turn support different land uses – trees, peatlands, combinable or fruit and vegetable crops.  

1.9.             Consequently, soil health, as an overarching principle in determining the suitability of a soil for its function[6], is a combination of many factors, so choosing just a few parameters to measure is difficult, particularly as these will be different for different soil textures and climates.  Any metric will therefore be highly dependent on context[7].

1.10.         That is not to say the ambition is not welcomed; it is.  However there is a risk that the time lost from trying to achieve the ‘perfect outcome’ is arguably greater than the risk of adopting a simple metric that perhaps does not address all the factors involved in soil health.

1.11.         Soil scientists agree that a mix of physical, biological and chemical indicators are required[8].  In many cases easily adopted metrics to assess these indicators are already available.  A distinction therefore needs to be made between the detailed understanding of soil health through scientific analysis and ‘benchmark’ metrics that can give farmers and land managers site specific guidance.

1.12.         A few projects have been run recently to design these metrics including the AHDB/BBRO led Soil Biology and Soil Health project[9], which designed a soil health scorecard to allow measuring and tracking changes in soil health, with the aim of producing something that could be done simply by a farmer in a field.

1.13.         This includes organic matter content (SOM) which has many properties that make it important for soil health, including water and nutrient holding capacity (e.g. for every 1% increase in organic matter, the soil can hold over 200,000 more litres of water per hectare), improving infiltration, reducing bulk density and it is also the part of the soil that provides food and habitat to the living fraction of the soil. Consequently, SOM is often regarded as a proxy indicator; however it is important that it is recognised that SOM levels vary between soil types and so SOM must be used in context.

1.14.         SOM represents a huge pool of stored carbon which can be augmented or depleted depending on climate and management. Increased water storage is valuable for reducing runoff, soil erosion and flooding as well as improving agricultural resilience to drought and helping to secure our food supply in the face of climate change.

1.15.         Consequently, measures to promote SOM increases (or slow declines) are important as much of the SOM content is quick to degrade and slow to rebuild. 

1.16.         However, due to the slow change of this in response to land management changes it can be difficult to use this to track improvements in soil health over a short time frame.  This problem is also compounded due to the multiple methods of measuring soil organic matter, including loss on ignition and dumas, which both give slightly different results.   For tracking changes in this metric over time the samples need to be taken in the same location at a similar time of year, and then to be comparable to previous measurements they need to be sent to the same laboratory for the same type of analysis.  To make this process easier a standard method could be implemented for use in laboratories, reducing error due to protocol changes. This is the sort of issue which a Government-led SHAPE should be addressing, rather than missing the opportunity.

1.17.         SOM measures will not always yield financial returns to farmers in the short term and so for shorter term ambitions such as food security it is appropriate for Government to encourage and finance such practices through the SFI.

1.18.         However, evidence is still lacking on some land uses/managements and so GWCT would like to see a national soil monitoring programme linked with more in-depth studies at some benchmark sites. This system is being introduced in Australia and could provide the UK with a framework.   Australia has a national soil strategy (introduced in May 2021) and is supporting this with a broader package of support including stewardship and monitoring[10].

1.19.         In addition in relation to GHG emissions, consideration also needs to be given to the other gases such as nitrous oxide (N2O) which is emitted from poorly managed (compacted) soils and which is 300x more warming than CO2. Whilst measuring N2O is a highly specialised and expensive task, greater knowledge of the condition of soils in England would enable some estimates to be made through modelling.

1.20.         Therefore, as suggested above, not only do we need metrics we also need to set a pathway towards good soil management which is flexible enough to respond to real-life situations – for example incentivising a move to direct drilling may help retain soil carbon, but this may also lead to more widespread compaction in the short term, thereby increasing N2O emissions and leading to a significant net increase in climate impact from soil in the short term.  In such situations it maybe that ploughing is needed on a rotational basis. 

1.21.         Consequently it could be that for agricultural soils there is a need to not only demonstrate an improvement in soil structure – through for example earthworm counts and soil organic matter (SOM) content - but also demonstrate a change in cultivation processes.

1.22.         A SHAPE should have included within in it a programme of demonstration events and knowledge exchange meetings. This approach was pioneered in the early 2000’s by the UK Soil Management Initiative (UKSMI). UKSMI organised events which helped farmers transition away from intensive tillage practices into lighter minimal or direct seeding tillage. So successful was SMI in assisting with this switch that in the space of 6 years 40% less land was being ploughed and the area of land subjected to non-plough tillage exceeded that the ploughed area for the first time. 

1.23.         So far, our response has focussed on all agricultural soils but peatland soils are also the specific subject of environmental improvement targets due to their importance in GHG emissions.  In upland peatlands their health and condition is currently measured with reference to the Common Standards Monitoring (CSM) of protected sites but we question whether this is fit for purpose as the CSM was not designed for the broader ‘natural capital’ applications it is currently being used for[11]. 

1.24.         The degradation of upland peat soils has resulted from historic land uses and industrial pollution and so reversing these impacts has been the main objective in restoring deep peat, mainly through rewetting and Sphagnum planting.  On-going monitoring will determine the success of such an approach.  The indicators used relate to carbon flows, species and habitat recovery and hydrology. Given that soil is a living organism involving processes rather than defined inputs and outputs, it is important that this monitoring leads to management approaches evolving in response to the evidence, particularly as water tables in peat are likely to be impacted by future climate change.  The 10-year results from a 20-year study led by York University suggest that unmanaged sites can result in a lowering of the water table due to increased evapotranspiration[12].

1.25.         We are also concerned that there have been no dedicated measures to address the protection and restoration of lowland peat, given that it is central to much of our intensive, high-value food production.   The Lowland Peat Taskforce was set up in 2020 given that “.. Centuries of draining these areas to support intensive agriculture have led to degraded peat soils, which emit more than 9 million tonnes of greenhouse gas emissions each year”[13].  Does the reduced target for soils in the EIP23 reflect a downgrading of ambitions to restore lowland peatland soils?  Whilst we do not advocate widespread adoption of paludiculture, given the importance of these soils for our domestic food security, we do feel that more emphasis needs to be placed on their management to protect the remaining carbon and other nutrients that make this soil so valuable to food production.  In addition, as we highlight in 2.8 their protection is not just about agronomy and cultivation techniques, it requires a consideration of how tenancy terms can impact on their management.

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

2.1.        Current regulations are based on individual outcomes such as reduced losses into water courses through the Farming Rules for Water or carbon sequestration rather than an holistic view of soil structure, suitability and condition.  As a result, it appears to us that a number of important threats to soil health including compaction, wind erosion, contamination/pollution and loss of soil biodiversity are not covered by the current regulatory framework.

2.2.        The GAEC rules (as part of cross compliance) that required farmers to protect soils from erosion and maintain organic matter will no longer be applied once the basic payment scheme has finished.  Whilst the SFI arable and horticulture soils standard incorporates green cover and organic matter, the benefits of this will only be limited to the parcels of land within the standard. 

2.3.        We regarded the framework for oversight as a key component of the promised SHAPE.  The current policy approach risks weakening the underpinning regulation given the multi-functionality of soils and the range of ecosystem services provided.  SHAPE would also have provided the much-needed connection with other frameworks/plan/strategies that underpin Government targets such as net zero, biodiversity, air quality and water.

2.4.        More money needs to be spent on monitoring soil health.  In 2020 the Sustainable Soils Alliance calculated that just 0.41% of the environmental monitoring budget was spent on soil health.   This is after the inclusion of soil health in the 25-year Environment Plan.

2.5.        The lack of national data on the state of our soils means that there is no baseline[14] although in the EIP23 Government has committed to publish a soil health map for England by 2028.  As identified by the OEP there is a continuing lack of suitable data to assess the soil health indicator within the 25YEP goal of Using Resources from Nature More Sustainably and Efficiently and there is a lack of definition of what sustainable management means[15].  Is ‘sustainable management’ in this context aimed at purely the environmental aspect or is it aimed at combining this with the business of food production?  The first suggests policy would seek the maximisation of environmental outputs; the second would require the optimisation of both environmental and economic outputs.  This makes any judgement on policy success difficult; neither does it encourage innovative funding approaches such as environmental credits. 

2.6.        However, the GWCT also knows from experience of farmland birds and other species that, while essential, monitoring alone is not enough. Without positive measures there is a danger we will simply preside over a measured decline in soil quality, recording it but not fixing it.  We support the suggestion therefore that any metric should be supported further by a Code of Practice that advocates and incentivises good practice[16].

2.7.             In addition, it is important that Government (and stakeholders) recognise that a metric for soil health is a long-term commitment (for the various reasons highlighted in Q1 above) and so farmers and other land users need the confidence that any change in Government will not alter this investment.

2.8.             Current agricultural tenancy legislation does not support improved soil management practices.  We have highlighted in other inquiries the damage that short-term (usually a single cropping season) Farm Business Tenancies can do.  Whilst they have achieved what they were designed to do and freed up the fluidity of land in the rented sector it was not foreseen that they would have disastrous consequences for soils, particularly Grade 1 soils on which the fresh produce sector relies so heavily. Fields are re-let on an annual basis to the highest bidder with the tenant only interested in a short-term return. This means that the crop rotation is heavily exploitative resulting in perpetual soil degradation. Many of these soils are drained peatlands which are simultaneously suffering from shrinkage and loss through oxidation and wind-blow. Tenant farmers who rent fields on a 5 -10-year cycle, dictated by the need to prevent pest build up, report soil depth to be depleted each time they return to the field. Some soils will have a finite life and be un-farmable in time. This is precisely the sort of issue the Government should be addressing through the Action Plan.

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?

3.1.        We can only comment on the SFI standards currently available – those for arable and horticulture and improved grassland soils..  The actions outlined (increasing soil cover, increasing SOM additions etc) are positive steps toward increasing SOM, and creating a measured baseline is vital.

3.2.        But it has to be appreciated that even with the regular use of successful and high biomass cover crops, the implications for SOM are very slow and long-term, with the main benefits being in the reduction of soil loss from wind and rain and the retention of soil nutrients away from water courses.

3.3.        Reduced tillage must be a key element of a soil health plan, BUT it must also be appreciated that tillage (e.g. ploughing) can play a vital role within a rotation for economic and agronomic reasons, and must remain as a tool in the toolbox – albeit with incentives and encouragement to use sparingly.

3.4.        More diverse leys are to be encouraged from a resilience viewpoint, but it must also be acknowledged that soil under permanent pasture is likely already to be of high quality and high SOM/SOC.

3.5.        We have concerns that the Grassland soil standards will not radically alter the current situation on-farm.

3.6.        The major threat to soil health under ELMS perhaps comes from insufficient payment rates to encourage farmers to adopt SFI standards, and would in fact likely lead to an intensification of farming practice as farmers attempt to ‘farm their way out’ of a financial hole.

3.7.        Dropping farm margins may also retard uptake of more modern equipment and techniques.

3.8.        The opportunities, if an appropriate budget is available, are relatively unlimited in terms of what can be achieved through appropriate incentivisation and education. 

3.9.        If ELMS is to be the main route to achieving soil health then we are also concerned about the lack of connectivity with the main routes to the oversight of good practice such as the Farming Rules for Water.  Compliance with these is not a pre-requisite of achieving the standard and this suggests to us a lack of an holistic approach to soil management and oversight.

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?

4.1.        Managing soils as part of our natural capital is a vital input and mechanism for reducing risk across a range of sectors and the need to manage this resource sustainably is increasingly recognised by business. This is an area where we expected the promised SHAPE would be influential by coordinating policy and actions.

4.2.        Obviously, soil is fundamental to the sustainability of our food and beverage sector.  Consequently, there has to be more profitability returned to the farm gate. Not only does Government need to better support farmers to achieve a range of environmental outcomes (and produce food) but the supply chain has to allow more of the profit to get to farm level to allow for reinvestment in more sustainable farming methods, which can often 1) have large up-front costs 2) reduce yield, if only in the shorter term and 3) remove land from production.

4.3.        Partial grant funding etc is acceptable so far as it goes (e.g the Farm Technology Investment Scheme etc) but is not accessible to all farmers and doesn’t address the underlying chronic lack of profit in most parts of the farming sector.

4.4.        In addition, we would argue that the focus on encouraging the sustainable management of soil should extend beyond the food and agriculture sector as it also helps reduce the risk of floods and droughts which is critical for businesses such as utilities, insurance and any business in downstream towns and cities[17].

4.5.        The wide impact of soil management and the risks posed by continuing soil degradation emphasise the need for long term planning and interventions at scale.  This also provides clear drivers for businesses and land managers as well as Government to work together on a shared approach and shared funding.

5. What does UK Government need to do to tackle other stressors on soil health such as soil contamination?   [not answered]

February 2023