Written Evidence submitted by the Council for the Preservation of Rural England (CPRE)(SH0077)

Summary

1. CPRE, the countryside charity, strongly welcomes the EFRA Select Committee inquiry on Soil Health. CPRE has a long-standing interest in the protection and health of soils as a critical natural asset securing our long-term supply of food, shaping rural land use and landscape character, underpinning the health of farming at the heart of the rural economy and at the base of nature’s food webs. Our work on land use planning and land use change highlights the multiple pressures on land and soils. This is increasingly so due to climate change. CPRE advocates for a strategic and multifunctional approach to land use to maximise opportunities and minimise trade-offs when addressing these pressures. Healthy soils are pivotal to this and their protection, improvement and regeneration will be vital for ensuring the countryside is resilient and able to provide for our essential needs from food to clean water to carbon storage to our access to nature.

2. We welcome the most recent publication of Environmental Land Management (ELM) schemes and the 5-year reiteration of the 25 year Plan for the Environment (25YEP) in the new Environmental Improvement Plan (EIP). These provide important policy direction and delivery mechanisms for future management of particularly agricultural soils. ELM continues to evolve. It will have further iterations and revisions so its effectiveness in delivering changes to farm soil management is yet hard to assess. Many questions remain.  The EIP builds on commitments in the 25YEP to bring greater clarity on what soil health monitoring frameworks will be developed over the next 5 years.

3. Nevertheless, despite some progress, CPRE remains concerned that soils in general lack the coherent and comprehensive policy framework, evidence base and allocation of research funding they deserve. If the EIP represents the new England Soil Health Action Plan (ESHAP) then with the soil health section at only 2 pages long it is profoundly disappointing. It also has the dubious distinction of further weakening the government’s commitment – set out in earlier strategies in 2009, 2011 and 2018 – to sustainable manage all soils by 2030. This sits in contradiction with a restatement of the commitment to end land degradation by that date and a UK sign up to the Sustainable Development Goals.

4. We also remain concerned that soil is treated in the EIP as a natural resource to be used ‘sustainably and efficiently’ comparable to fisheries catch or harvesting timber. Fisheries and timber, if well managed, are replenishable resources within human timeframes. Soil is one of if not the critical natural asset for our survival, supporting all terrestrial ecosystems and, is in itself, a habitat and ecosystem of unfathomable biological richness and complexity. As non-replenishable within human lifespans, it deserves strong protection from loss, degradation and unsustainable use. This is particularly true when land is developed and sealed, and soil effectively ceases to function in most respects except as a building platform.

5. We welcome the EIP commitments to develop a national indicator of soil health for agriculture and consistent tools for other land uses as well as baseline mapping of soil health by 2028. Similar tools are promised for farmers and these will need to be deployed rapidly to enable farmers to assess their current practices, innovate and adapt to maintain and improve their soil health. The linkage between such metrics and the vague term ‘sustainably managed soils’ needs to be made clear. We also question why, when so much land has been degraded, we do not have a more ambitious target to regenerate soils and restore then to optimal health.

6. We welcome significant allocations of funding to particularly lowland peatland research and further exploration of the viability of paludiculture or wet farming as an innovative potentially productive way to bring intensively farmed peatlands into genuinely sustainable productive management. We hope this funding will in future be accompanied by a renewed emphasis on filling gaps in knowledge of soils. Soil research has been historically poorly funded by government compared to air and water. Major gaps in for example our understanding of erosion need to be filled if we are to monitor change nationally and scientifically.

7. CPRE GIS based research has shown that agricultural soils of the highest quality (grades 1 to 3a) are under threat from changes to developed uses, particularly housing; and significant concentrations of these soils are found in land, such as in the Fens and in Merseyside, at the highest risk of flooding. The quantity of such land could also diminish severely under climate change scenarios threatening other key food production areas with drought. Such risks amplify the need for stronger protection for such land by joining up policy across planning and wider land use via an integrated land use framework – promised by government for 2023- as well as through reform of measures within the National Planning Policy Framework.

Introduction

CPRE, the countryside charity, strongly welcomes the EFRA Select Committee inquiry on Soil Health. Our 2018 soils report Back to the Land advocated for the pivotal role of soils in supporting natural ecosystems and multiple environmental services to be recognised and fully valued by public policy. This means recognising the fundamental importance of soils and good soil management not only as critical for securing food supply but also in supporting multifunctional land use. This includes the contribution soils can make to reducing greenhouse gas emissions, storing carbon and water and creating more resilient farming systems, as part of addressing the challenges of adapting to and mitigating climate change. CPRE identifies climate change as the single most important threat to the countryside. 

The continued need for an overarching policy framework for soils is evident. Soils underpin 95% or more of our food production and multiple critical environmental services, yet they still lack the coherent policy framework, focus and resources enjoyed by air and water quality derived from overarching regulation, originally via EU Directives. It is notable that the Environment Act 2021 has extended sections on air and water but no part, chapter or section is on soils. Accordingly, there were no legally binding targets on soils or soil health set because of the Act by end of January 2023.

Other important policy documents do consider the issue of soils.  These include the 25 Year Environment Plan, England Peat Action Plan, Agricultural Transition policy statements in particular relating to Environmental Land Management schemes and the National Planning Policy Framework. Most recently HM Government published the Environment Improvement Plan on 31st January 2023 as a scheduled 5-year refresh of the 25 Year Plan for the Environment.

1) How can the Government measure progress towards its goal of making all soils sustainably managed by 2030?

The Environmental Improvement Plan 2023 (EIP)

1. We understand that the section on soils in the Environment Improvement Plan (EIP, published in January 2022) will now supersede proposals for an England Soil Health Action Plan (ESHAP) promised by Lord Goldsmith in Parliament in September 2021. CPRE called in 2018 for the government to develop an action plan on to deliver on its 2030 target. We do not believe that the two pages allocated to improving soil health (pp180-181) and those entitled on Manage, restore, and protect our peatlands, and end the use of peat in horticulture (pp196-200) are sufficient to constitute a Soil Health Action Plan for England. It is unclear why peat soils have their own more detailed action plan but all other soils do not warrant anything similar. We urge the committee to clarify with the government whether a comprehensive ESHAP will be forthcoming.

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2. The EIP does not confirm the target and commitment to sustainably manage all England’s soils by 2030. We conclude that in fact it has abandoned that target with no explanation and replaced it by a much narrower and weaker one:

“By 2028 we will bring at least 40% of England’s agricultural soil into sustainable management through our new farming schemes, increasing this to up to 60% by 2030.”

This represents a major loss of ambition both for soils generally but also the 40-59% of soils that may not be sustainably managed by 2030, given that 41% of agricultural soils so managed could meet this 2030 target. If we are to understand ‘sustainable management’ as at the very least preventing further degradation, then the government appears to have abandoned its target to prevent further soil degradation for the majority of UK soils by 2030. This is a major failure of ambition and commitment.

3. This retraction of the existing target also amplifies the failure of the government to properly integrate the relevant 2030 Sustainable Development Goals (SDG) to which it is signed up into its departmental plans and policies. SDG 15 Life on land includes the goal to halt and reverse land degradation with a sub-target (15.3) to restore degraded land and soil by 2030, and to ‘achieve a land-degradation neutral world.’  Somewhat surprisingly, the EIP repeats that commitment (in Section 6) to “halt and reverse forest loss and land degradation globally by 2030.”[1] Yet, there is no reference in the EIP itself as to the delivery mechanisms to meet that commitment. We recommend the committee clarify with government how it can retain a commitment to this global target without policies to achieve it domestically.

4. The EIP repeats the use of the term ‘sustainable management of soils’ in the revised target. CPRE called for the meaning of ‘sustainably manage’ to be clarified in 2018 but this has yet to be defined by Government in terms that would make it possible to determine – all other things being equal – whether the goal is being achieved. We also discuss this further below.

5. The 25 Year Environment Plan limited aspirations for soils and their inclusion in a section did not mark a step change in the policy treatment of soils to bring them into line with the importance given to air and water. Instead, the plan allocated soils to a section under the goal: ‘Use resources from nature, such as timber, fish and food, more sustainably and efficiently.’ This was a significant category error. This error has been perpetuated in the EIP. While soil as any form of natural capital is an asset, it is an ecosystem stock from which we derive flows of services particularly food but also multiple other ecosystem services. It is also in its own right a habitat for myriad lifeforms. It is non –replenishable with normal human lifespans. We don’t believe it should be equated to what need to be sustainably harvested resources such as timber or fish as is done here. We believe the failure to give protecting and improving soil health parity as a major environmental goal as is done for Goal 2 clean air and Goal 3 clean plentiful water remains a major omission of policy.

6. A key example of how soil can be compromised or lost as a natural resource is when it is capped and sealed under developed uses. Even when some soil can be retained and transplanted, sealing means that it is unable to function as a habitat or support multiple essential ecosystem services. There is no significant reference in the plan to soil health linked to loss of land to development and the efficient sustainable use of land as a resource, particularly land that holds the highest quality soils, or so-called best and most versatile land under National Planning Policy Framework (the NPPF). Such land continues to be developed despite planning protections in part due to a failure to prioritise sequentially the reuse of already developed land (brownfield land). The most sustainable use of a natural resource is to harvest what is replenishable in natural annual and seasonal cycles and where it is not, to avoid its use by recycling waste resources. Policy to ensure land and the highest quality soils they harbour remain in situ to produce food and other services and are protected from removal, degradation and soil sealing is currently absent in the EIP.

7. Notwithstanding our criticisms above, some elements of the EIP are improvements to the previous plan and represent an important step forward towards assessing progress against targets on sustainable soil management. These include:

• Establishing a soil health indicator under the 25 Year Environment Plan Outcome Indicator Framework;
• Publishing a baseline map of soil health for England by 2028;
• Supporting farmers and land managers to establish their own soil health baseline, so they can best manage the health of their soil;
• Providing a methodology and tools to collect consistent information about the health of the soil under all land uses.[2]

The 25 Year Plan committed a relatively modest research sum (£200,000) for improving the knowledge base on soils and monitoring.  We welcome the commitment here to developing the national indicator of soil health – although we lack a date for this – and the publication of a soil health baseline map by 2028.

8. We also welcome the extension of the research work into a soil health methodology for all land uses. With agriculture covered, this will need to include land uses as varied as forestry, recreational uses, green infrastructure and protected habitats, transport infrastructure – such as road verges and airports and fields – as well as other developed spaces. We believe that monitoring of soil health across all land uses will be crucial to ensuring soil functionality can be optimised both for specific purposes for any given land use but also for developing a better understanding of how well soil is functioning to deliver ‘multifunctionality’ – ensuring land and soils deliver multiple ecosystem services optimally including supporting biodiversity, water recharge and infiltration, soil carbon storage, nutrient cycling amongst others. As pressure on land and soils increases, this multifunctional approach and understanding underpinned by a consistent evidence base will be ever more important. Understanding the baseline health of UK soils will be essential for enabling sound decision making under Defra’s proposed Land Use Framework and identifying ways to deliver multiple services on any given land and its soils instead of readily accepting trade -offs and loss of ecosystem services against sometimes a single land use purpose. CPRE recommends that the proposed Land Use Framework should set out policies that govern decision making on both environmental land management and in the planning system. One benefit of this is that there will be greater awareness of, respectively, what functionality can be lost through poor management, and when soils are removed from site or sealed by development.

Metrics and monitoring

9. As noted above the long-standing target to sustainably manage all soils has been weakened in the EIP. The former 25 YEP did set out a goal for developing ‘appropriate metrics and management approaches’ to support the 2030 target and committed ‘at least £200,000 to help create meaningful metrics that will allow us to assess soil improvements, and to develop cost-effective and innovative ways to monitor soil at farm and national level.’ (p43) We must assume these metrics will now be targeted primarily towards meeting the new specific target for sustainable management of agricultural soils only.

10. While there is no specific sum allocated to the future soil health baseline and indicator in the EIP, the ambition of these suggests that much more resource will be given over to soils in the future. We are also encouraged by the sums allocated in the EIP to lowland peat research (a £6.6 million) and development programme and £5.6 million to ‘continue to deliver the £5.6 million Paludiculture Exploration Fund. ‘[3] Nevertheless, as set out above, there remains a substantial deficit of research to fill and we recommend that government continues to strive harder to fill it.

11. The EIP has advanced this agenda by committing to produce both a national indicator and supporting farmers to assess their own baseline. We support the development of both an objective national indicator and tools to support farmers to manage their own soils – and in both cases establishing a baseline is important. CPRE recommends that clear signposts to the national indicator must be made in local on-farm assessment tools to enable farmers to assess their own practices, innovation and improvements in their soils. This will enable both farmers and the general public to understand whether soils are being sustainably managed. Since this goal is about management, it must be defined by a set of practices that work to at the least prevent degradation – the ‘nutrient depletion, declines in levels of humus, and erosion and compaction of soils’ set out in the 25 YEP (p43) as well as maintaining soil biological activity. How these are to be identified, assessed over time and codified into a framework for sustainable soil management and how this both marries with the baselines and indicators to be developed has yet to be described. 

12. The resources allocated by Defra in the 25 YEP to developing soil metrics and monitoring did not reflect its importance as a key element of nature, natural capital and underpinning of agricultural production. There is a historic deficit in funding allocated to research on soils versus other elements in the wider environment. Analysis by the Sustainable Soils Alliance based on Freedom of Information data for government spend on air, water and soils monitoring in 2017/2018 showed that just 0.4% was allocated to soils.[4] It will be important to address this deficit. Our own simple search of Defra Science and research projects listed on gov.uk (Science Search (defra.gov.uk) illustrate this long-standing disparity: there are hundreds of projects listed under air and water quality (159 and 419 respectively), also monitoring and pollution. There are only 15 projects listed on soil quality and soil health and none on soil pollution or soil contamination.

13. Defra’s own research project SP1303 indicates that there remain major research gaps in relation to soils and with respect to erosion.[5] We know that climate change is driving more extreme weather events which are directly affecting farm yields and productivity as well as placing soils at risk. In the context of a less stable climate it becomes all the more urgent to engage science in understanding better the extent of risks this presents to soils, to monitor change effectively and present the evidence to drive policy to prevent and mitigate such risks.

14. In terms of erosion, the report of Defra’s project SP1303[6] identified gaps in knowledge and opportunities for further research by looking at known drivers of erosion where necessary research is lacking to provide effective monitoring of change. This work covers a range of agricultural activities and erosion risks including:

• Upland soils erosion - significant degradation of upland soils by erosion with ‘significant degradation of the UK‘s most significant terrestrial carbon store’ and a ‘significant risk of negative impacts of climate change and land use change on upland erosion’; ‘In this context there is a clear need for systematic monitoring of the erosion status of upland soils. (p5) Data available allows the characterisation of typical upland erosion but is too piecemeal to ‘provide a robust basis for ongoing monitoring of change’. Upland soils could be measured systematically to provide important information on broad erosion trends using remote sensing technologies with repeat survey LiDAR measurements. These could provide measurements of volumetric change to establish erosion rates but must be done over long enough periods (c 10 years) at the current resolutions available.

• Outdoor pigs – according to the report, ‘No papers or reports could be found which have tried to evaluate the erosion rates from outdoor pigs’.

• Wind erosion - no systematic monitoring of wind erosion in the UK and ‘relatively few papers quantifying local scale rates of wind erosion in the UK’ even though this is ‘well known on light and organic soils during dry conditions’ and in East Anglia described as Fen Blow. (p8)

• Grassland erosion - ' very little understanding of the rates of erosion and yields of sediments’ in temperate grasslands despite their potential to erode especially when over grazed by livestock matter’; soil health is assumed to be good in these areas but ‘this may not actually be the case (Brazier et al., 2007)’; also ‘there is very little scientific data to link the degradation of vegetation and soil health to the degradation of surface waters in a systematic manner.’ The researchers conclude that large coverage of grasslands in England and Wales, ‘vast soil resources’ devoted to grassland farming requires ‘clear understanding of erosion rates and extent’

• Tillage erosion – ‘There has been no systematic monitoring of rates of tillage erosion in the UK or elsewhere.; a tillage map of England and Wales exists but is based on a small number of sites ( 34) with only one in the UK; they sum up ‘ in the light of the magnitude of tillage erosion rates and their effect on soil properties within arable fields, there is a clear need to broaden the UK database for tillage erosion.; this in turn would enable best practice to be identified to reduce rates of tillage erosion. (p15) 

2) What are the challenges in gathering data to measure soil health and how can these barriers be overcome?

15. Monitoring of soil health is important at both the national level and at field scale. The approaches need to be different but we believe can be complementary. At national scale government needs to commission national monitoring which is reliable, rigorous and objectively conducted by scientists to assess change at repeated intervals over decades. Some of this work has been done by the National Soil Inventory which took 6,500 representative samples across the country in the 1980s and repeated these to a smaller extent in the 1990s (600 samples). This work has not been repeated recently we assume for lack of funding. We lack consistent monitoring nationally. This weakens the evidence we have of the state of health of soils, of the impact of policy making and of progress against government targets – bearing in mind the long-standing target noted above. It therefore hampers sound policy making.[7] While the EIP has now committed to producing a new baseline map for soil health by 2028m the relationship of this to the National Soil Inventory and longitudinal data should be explicit so we can track change over decades. 

16. At the field scale farmers and other land managers need to regularly assess their soils to understand how well they are functioning for their agronomy, whether on key measures they are degrading or improving and how well any interventions are working and which should be continued or not.[8] This understanding needs to be at farm and filed scale or below. It is also key to enabling farmers to innovate and test the benefits of innovation in crop rotations, crop management, tillage, use of amendments and added nutrients and the role of livestock and livestock management in building and regenerating soils to fertility and health.  Given that soils can vary not only from field to field but within field then regular and frequent soil sampling for sending off site for laboratory testing can be prohibitively expensive to carry out. This represents a significant cost barrier to soil health assessment. Low-cost approaches are needed to include simple assessment techniques that farmers and land managers can use and track their soils to develop their understanding of their soils over time as well as the impacts of their management.[9] Ultimately these assessments will need to factor in physical/structural, chemical and biological properties of the soil.

17. Practical tools have already been developed to enable on farm monitoring and trialled by such as by AHDB and BBRO in their soil health scorecard.[10] The AHDB toolkit included Visual Evaluation of Soil Structure (VESS) which they describe thus: “VESS is a straightforward and quick way to test soil structure in three simple steps – soil removal, soil assessment and soil scoring. The soil quality score produced can help highlight where soil structure needs to be improved.” Vidacycle have developed Soilmentor, an app-based tool for use in field to run a series of soil tests which can be GPS tracked to sample site; data is then uploaded to a laptop/desktop to record results over time to track change. Tests are wide-ranging and include VESS, earthworm counts, infiltration test, topsoil count, dung beetle count, sward density, penetrometer etc.

18. The EIP has committed to ‘Support farmers and land managers to establish their own soil health baseline, so they can best manage the health of their soil.’ Detail is lacking in how this will be done. As more and more farmers engage with the new ELM schemes and are given incentives to manage their soils, then supporting the deployment of tried and tested tools would seem to make sense. Defra could run its own assessment of different practical on-farm tools and decide which to support. Funding could be made available for farmers to download or adopt such tool either directly through some modification to ELM Sustainable farm Incentive standards on soils or via a dedicated link to grant schemes such as the Farm Equipment Technology Fund (FETF). While this fund currently supports grants to purchase expensive new direct drills, as we understand it, does not support purchase of simple soil assessment tools.

3) 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?

19. Defra published its ‘environment and climate ambitions for the 3 new, complementary environmental land management schemes’ in January 2022 in an ELM outcomes policy paper.[11] The stated ambition for soils was: “We’re aiming to bring up to 60% of England’s agricultural soil under sustainable management through our schemes by 2030.” This goal has been recast in a weaker form in the 2023 Environmental Improvement Plan (EIP), as: “By 2028 we will bring at least 40% of England’s agricultural soil into sustainable management through our new farming schemes, increasing this to up to 60% by 2030.”[12]

20. The new target compares poorly with the now jettisoned target for sustainable management of all soils – including but not limited to all agricultural soils – by 2030. So, even in its own stated terms. ELM lacks the ambition to ‘sustainably manage’ all farmed soils by 2030 but also, as discussed above, we do not have a clear description of what sustainably manage might mean. If it means maintain the status quo so no further degradation then it again fails as a target to set ambition high enough to restore soils. Also, if we define sustainable management as a set of practices which as a minimum prevent further degradation, then the target leaves for the remainder of the decade at least 40 and up to 59% of soils at risk of further degradation.  We can compare this residual area with total areas identified as at risk by researchers at Cranfield University and question whether measures via ELM and the target will indeed address areas at risk of compaction and/or erosion (both below that 40% threshold):

-          ‘An estimated 3.9 million hectares of agricultural land are at risk of compaction in England and Wales’

-          ‘About 17% of arable soils in England and Wales show signs of erosion, although 40% are thought to be at risk.’ [13]

In our view, therefore, the Government’s target lacks the ambition required. If the target itself is lacking it is also hard to see how ELM will be designed and financed to meet targets with greater ambition.

20. There are also significant challenges to the implementation of ELM itself and a continuing uncertainty about various elements of ELM as it continues to evolve. These complexities are likely to hamper its ability to rapidly drive sustainable soil management, more so if they hamper rapid uptake of the schemes and expansion of their ambition in terms of challenge of options selected, farmers engaged and hectares of farmland under options.

21. ELM is in development and full roll out of the range of schemes is not expected until late 2024/2025. This means the measures now available are interim and can be expected to evolve; following a recent review by Defra begun in September 2022 the mid-level Local Nature Recovery scheme was replaced by an evolution of the current successful Countryside Stewardship (CS) scheme, labelled CS Plus, This already confusing policy framework is now complicated further as the new Sustainable Farming Incentive (SFI) and CS were not designed to work together so more work will need to be done to harmonise different options within them so they can work together and avoid double payment or conflicting actions

22. ELM Outcomes include engaging ‘at least 70% of farmers, covering at least 70% of farmland, to take up [SFI] agreements’; by this token SFI can be expected to be the main mechanism for achieving targets for the sustainable management of soils. The earliest SFI standards open for take up were soils standards for improved grassland and arable and horticultural soils. These do prescribe a set of actions for farmers who join the standard to take. In the SFI arable and horticultural soils standard for example these actions are:

•                   completing a soil assessment and producing a soil management plan
•                   testing soil organic matter
•                   adding organic matter
•                   having green cover on at least 70% of the land in the standard over winter (with the 70% including 20% multi-species cover crops at the intermediate level).

While these measures may well work to reduce soil erosion, help reduce leaching of key nutrients, restore organic matter and support soil biology over winter via living roots, the bundle of actions specified are, though in themselves welcome, limited as a package. Crop diversity is not required in green cover at the introductory level but nor is a broader rotation required at all.  Reduced tillage options are not available or encouraged here and, while organic matter can be added, the role of livestock isn’t considered. Other options that would work well here such as using legumes or buffer strips and hedgerows to protect soils aren’t signalled. In future we expect scheme design to become more flexible so that actions under current standards may not be required together but bundles may be offered and incentivised. While this will indeed increase flexibility there is a danger, without adequate signposting, guidance and advice, that this could hinder farmers and land managers selecting the range of relevant options that would improve soil management. This may increase initial take up of the schemes but may also lower ambition or enable some farmers to select for the best rewarded or easiest options but not those most complementary and synergistic.

23. Defra will need to set out how different options work together and identify through some form of bundling or packaging which options work together both harmoniously but also synergistically to optimise the benefits for the environment and food production. Currently, despite multiple calls from various organisations including for the development of a whole farm standard to support systemic – agroecological and regenerative approaches to land management- such a standard has yet to be developed to offer a coherent complete package of options.[14]  Development of an organic standard has been flagged in various policy statements and we urge Defra to introduce this as a model for the development of more integrated packages of options that can be applied by farmers systemically.

24. As far as we are aware what constitutes ‘sustainably management’ of soils has not been formally defined by Defra within ELM – or indeed elsewhere in policy. Actions set out within the current ELM offer are described as ‘support(ing) the sustainable management of soils’. There is a risk that the stated target may be met by using the number of farmers applying soil management options on their land as a percentage of a total targeted area. This would be inadequate. While the ELM options are in themselves positive, it is not clear what constitutes sustainable management as an end goal or the point at which soils will stop degrading. This raises the question of how will Defra develop and set out a package of actions to be deployed across different soil types that would constitute sustainable management as an outcome, not least so their target can be demonstrated to have been met. This further opens up the question of the adequacy of the goal of ‘sustainable management’ – is this goal for soils sufficient or should Defra not be aiming higher, as the Committee’s question implies, to restore soils that have been degraded for decades rather than manage soils to maintain them in their current (degraded) state.

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

No comment

5) 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?

No comment

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

25. Recent research by CPRE set out in our report Building on our Food Security identifies key risks from both climate change and loss to build development, to our stock of high-quality productive farmland and the high-quality soils they harbour. Under the Agricultural Land Classification system such land is classified as grades 1 to 3a land; within National Planning Policy this is referred to as best and most versatile land (or BMV land). The research shows that:

-          59.8% of all England’s Grade 1 land defined as excellent quality is at the highest risk of flooding (zone 3) representing an estimated 212,319 ha of all England’s land at that grade;[15][16]

-          a similarly high percentage, 48% of England’s agricultural land in grades 1 and 2 is at the highest risk zone 3 of flooding (using Environment Agency criteria)

-          significant areas of the highest quality farmland (grades 1 to 3a) continues to be lost to planned development; data since 2010 shows 14,000 hectares of such land has been allocated to developed uses;

-          a worrying increase in such BMV land planned for development in 2022 with a 100-fold increase on the number of hectares allocated. (CPRE, Building on our food security, p5).

26. In addition to CPRE research, further threats have been identified in research commissioned by Defra. This highlights that such soils many of which are concentrated in the east of England may be subject to increased droughtiness due to the increasing effects of climate change. Under a medium emissions scenario the research reports that the quantity of land categorised as the highest grades 1 to 3a could fall from 38.1% of agricultural land on a 1961 to 1990 baseline to 11.4% by 2050 and under a high emissions scenario BMV land could reduce to 9.2% of agricultural land.

27. Although such projections remain highly uncertain, the UK relies on its best quality land for both high levels of productivity and for production of crops where we are deficient in domestic production including salads and winter harvested vegetables for which the highest grade land is very well suited.

28. While the recently published EIP has little to say in this issue under protection of soil health, planning policy does appear to broadly protect such land. Yet, the risks to the overall stock of such land from development, flood potential and drought explored above argue for stronger protection for the highest grades. As mentioned above, CPRE believes that a land use framework will better integrate decision-making in planning, farming and wider land management, and strengthen the value attached to such land for particularly food production. Greater protection should also be achieved via changes to national planning policy including by introducing:

-          a brownfield first policy nationally

-          a strong presumption against developing such land, with greater weight the higher the classification

-          improvements to site surveying for ALC classification

-          implementation of monitoring of further losses of BMV land by local authorities and

-          government commissioning a review of the underpinning Agricultural Land Classification evidence base notably in the context of a changing climactic conditions.[17]

February 2023