Written Evidence submitted by Natural England (SH0081)
Natural England is the Government’s statutory adviser on the natural environment established under the Natural Environment and Rural Communities Act 2006 (the NERC Act). Natural England’s purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations thereby contributing to sustainable development.
We are pleased to have an opportunity to submit evidence to the Committee’s important and timely inquiry.
Overview
Natural England recognises that soil health and water quality fundamentally underpin a healthy natural environment. Future ambitions for carbon, wildlife and human well-being will depend upon a transition from soil decline to soil recovery.
Natural England believes that for all soil (rural, urban and, peri-urban) to be healthy, a holistic approach that reflects the natural variability of soils across the wider landscape and all land uses is required.
While the Environmental Improvement Plan 2023 commits to improve agricultural soil health[1], Natural England strongly supports Defra’s proposal to develop a Soil Health Action Plan (SHAPE) announced by Lord Goldsmith in 2021. The action plan is necessary to address the wider challenges, and should provide for:
establishing coherent soil policy to protect soils as a finite, multifunctional resource to achieve healthy soil everywhere (see Q1 Points 5 and 6; and Q2)
setting clear minimum healthy soil standards, based on robust evidence, and regulated rather than incentivised for effective implementation (see Q2 and 3)
a Land Use Framework and planning system that recognises soil has differing capabilities and supports land use and management choices that protects soil and enhances soil health (see Q1 and 3)
skills and knowledge - a focus on soil education in schools, colleges, and universities plus knowledge exchange with land managers, planners, decision makers and the public (see Q1 and 5)
effective monitoring and evaluation of plan implementation (see Q1)
How can the Government measure progress towards its goal of making all soils sustainably managed by 2030?
The Government’s 25 Year Environment Plan (25YEP) goal to have all soils managed sustainably by 2030 is a target linked to the concept of soil health. To measure progress most effectively will require a commonly understood and agreed definition of soil health.
Natural England define soil health as the measure of how well soil delivers required functions, like food production as well as water and climate regulation. Good soil health underpins all terrestrial systems and is essential for nature recovery. There is currently no agreed Government definition of what constitutes soil health which makes a consistent approach on monitoring and managing soils extremely challenging and hampers measures to address soil health.
Soils vary in their characteristics and geographical locations meaning soils differ in their ability to deliver functions. A healthy soil will deliver its “required functions”, with low or no requirement for intervention
To measure soil health, a clear system is needed to interpret soil function measurements against expected ranges for different soil types. This will allow meaningful assessment of soil function in the context of that soil’s capability.
The Government’s Environment Improvement Plan includes a commitment to publish a Land Use Framework. A universal system which allocates appropriate land use by soil type, including urban soils is necessary to inform this proposed Land Use Framework.
An understanding of both soil and wider land capability is also fundamental to define, measure, and improve soil health as well as ensuring sustainable use and management of soils
In summary, we believe that the following measures would assist measure progress towards the 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?
Soil initiatives are increasingly prevalent[2], reflecting the increased awareness and impetus to improve and optimise soil management and soil health for environmental, economic, and societal benefits. At present no strategic forum exists to allow different organisations and soil initiatives to join-up, share information and ensure consistency. It was hoped that the Soil Health Action Plan for England (SHAPE) would fill this gap.
SHAPE was announced in September 2021, with an anticipated launch date of Spring 2022. To date, there has been no public engagement, nor launch of this plan.
Soils are formed over long periods of time, reflecting the five soil-forming factors: the prevailing climate, organisms, topography, parent material, and time. Soils are therefore highly variable, with different soil characteristics and capabilities. Consistent, collaborative measuring and monitoring are needed at a detailed enough scale to understand our soils, utilising all available soils data.
Natural England has set up a Long-Term Monitoring Network (LTMN) to record, analyse and predict environmental change in the UK. Natural England is also developing a Natural Capital and Ecosystem Assessment (NCEA) programme in partnership with the Joint Nature Conservancy Council, Environment Agency, Forestry Research, and the Marine Management Organisation (see Appendix 1). This will provide valuable new data to better understand national soil condition and report on the 25YEP indicator E7: Healthy Soil Indicators.
To progress a consistent method to measure and monitor soil health, Natural England advises the following measures would be useful:
Understanding location and prevalence of different soil types is vital to improving soil health.
Currently, detailed soil mapping is only complete for about a quarter of the country.
Use of soil data is restricted by expensive licencing, leading to low awareness and underuse of existing soil data. This data should be accessible to all as a ‘national asset’.
Natural England has a database of soil sample results, from agri-environment schemes and Agricultural Land Classification (ALC) surveys (Natural England Access to Evidence - Agricultural Land Classification detailed Post 1988 ALC survey). This valuable resource could help inform and progress soil mapping to supplement existing National Soil Resources Institute (NSRI) soils data or provide the basis for future independent mapping efforts.
We would like to develop land capability mapping and soil mapping initiatives, including a revised ALC map.
Natural England advises developing the mapping of soils in a simple way, to:
This will allow better understanding of soil’s capability to provide ecosystem services, and then factor this into decision making.
Natural England plays a statutory role in protecting natural capital and deliver sustainable development in the planning process and our role in the protection of BMV agricultural land for current and future generations.
Current planning legislation gives limited protection to soils and BMV land, despite soil being a finite resource. The legislation does not factor in different soil capabilities and their role in sustainable land use. It also fails to highlight all the environmental benefits associated with healthy soil.
The 25 YEP indicates that BMV policy should be maintained and strengthened across the board. But the current policy in England lacks clarity over the weighting for BMV land.
Although Natural England have a statutory responsibility to protect BMV, and consultee role for major development, the strategic scale ALC mapping currently needs updating and a longer-term system review to accommodate climate change impacts. There is currently no system in place to monitor the extent of development and impact of land use change on soil functions or the impact of Natural England’s statutory soils advice, and there are evidence gaps for soil use and handling in construction and mineral working, soils in Green Infrastructure and in urban soils.
The Defra Construction Code of Practice for the Sustainable Use of Soils on Construction Sites is currently for guidance only. The current lack of statutory and legislative frameworks for soil management hinders good soil management practice within the planning system, including peat soils.
Early consideration of soil can inform site design and identify the best location for multifunctional open spaces. This includes Biodiversity Net Gain (The Biodiversity Metric 3.1) and Green Infrastructure (Green Infrastructure Home), and will increase successful project delivery, to ensure the sustainable management and use of soils in decision making.
Detailed information about the current consideration of soils in the planning system is presented in Appendix 2.
Natural England believes that recognition of the following considerations within the planning system would be beneficial, namely:
Planners, engineers, and the construction industry would also benefit from:
The England Peat Action Plan sets out the ambition to restore 35,000 ha of peat by 2025.
A key part of Natural England’s work to mitigate climate change is to monitor, manage, restore, and protect peat soils.
We are currently developing a new England Peat Map as part of the NCEA, based on peat depth and condition assessments, coupled with sophisticated spatial modelling techniques (see Appendix 1).
Natural England believes that the following measures would help to ensure the long-term capability of peat soils:
2. Do current regulations ensure that all landowners/land managers maintain and/or improve soil health? If not, how should they be improved?
Natural England do not think that current regulations ensure that all landowners/land managers maintain and/or improve soil health.
Regulations to protect soil health often see soils as a pollutant or waste material, rather than valued asset. Regulations for soil mainly fall into two main areas, namely:
The Farming Rules for Water aim to reduce and prevent diffuse water pollution from agricultural sources. However, their implementation does not specifically maintain or improve soil health or contribute to sustainable soil management.
Many sustainable soil management options are not in a regulatory framework but instead are paid options in the Sustainable Farming Incentive (SFI). This approach goes against the principle of minimum acceptable standards, and of having rewards available for going beyond this standard. The current SFI soil standards contain many actions that are better suited to regulatory approaches.
Short term agricultural tenancies, usually for root crops, often lead to soil degradation as there’s little incentive for the tenant to avoid damage to the long-term soil health.
There is currently no regulation that requires remedial management (resting the land, full vegetation cover) following intensive cropping.
Farmers may need consents before undertaking activities which impact soil, like turf stripping, and where a project increases the agricultural productivity of uncultivated and semi-natural land. The Agricultural Land (Removal of Surface Soil) Act 1953 makes it an offence to remove surface soil from agricultural land for sale or use in development.
Soils outside of large-scale ownership and agricultural use have very limited protection or means of implementing sustainable management. Such soils support golf courses, sports fields, private gardens and estates, public parks, and the green estate of government bodies. These soils are considerable in extent and current regulations do not offer mechanisms to maintain or improve their soil health. There is limited understanding of the scale of functions provided by these soils, with very little data available.
Natural England believes that the following measures would help to maintain or improve soil health:
developing a coherent soil policy for all aspects of soil management and soil use
regulating soil use within development
clearly defining minimum regulatory standards for soil
discouraging damaging land management practices
regulating soil health in-situ to help prevent damage or pollution caused by soil degradation
consider regulating to apply remedial management following intensive root cropping
clarifying and updating legislation for turf stripping on peat soils
commissioning soil health research in agricultural and non-agricultural soils
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?
In 2022, three SFI standards were published including two for soil - Improved Grassland and Arable & Horticultural. These standards provide payments to land managers based on actions aimed to benefit soil health.
Natural England welcomed the approach taken to the soil standards introduced as part of the initial SFI offer in 2022 in the way they bundled together a range of actions into a coherent ‘standard’, with the multiple ambition levels providing an upward trajectory to nudge applicants to do more to secure higher incentives. This approach demonstrated learnings from previous experience with Entry Level Stewardship, where the lack of more directed choice resulted in low value-for-money through unacceptably high policy ‘deadweight’[4]. In general terms, the differentiation of the ‘Introductory’ ambition level also provided a useful guide to the sorts of activities that could be dropped from financial incentivisation at the next iteration of the scheme and transformed instead either into unpaid scheme conditions or incorporated into the regulatory baseline.
Natural England believe that sustainable soil management should be a pre-requisite for entry into SFI and would prefer that soil management which simply prevents degradation is not a paid option under SFI.
There needs to be a timebound exit strategy from the current extent of the use of incentives as part of the move towards the principle of minimum acceptable standards and a more effective application of the ‘polluter pays’ principle. We are mindful that the question also only targets a subset of soils within England and believe that a comprehensive system is required to provide decision support to land managers to enable them to deliver appropriate environmental outcomes in the right place to thereby improve soil health. Such a system is currently being scoped as a Natural England project (see Appendix 3).
The ambitions for soils in ELMS should include:
clear and robust regulation as a pre-requisite for entry into SFI
detailed, but easy to interpret, mapping of soils and land capability
a management tool so farmers can identify risks and opportunities for different soil types
a soil management plan and nutrient management plan as part of the application process
a timebound exit strategy from the use of incentives to deliver widespread soil health
Natural England has recently commissioned research projects to deliver evidence and develop advice, tools, and guidance to inform the SFI Soil standards (see Appendix 3).
Natural England advises the following actions:
Threats for soil health as ELMS are introduced
The lack of a no/low input grassland standard until SFI 23 becomes available, perpetuates the risk that land managers may plough up and “improve” old grassland to receive payments. This would negatively impact on biodiversity and soil health.
The effectiveness of these standards in delivering soil health may be limited by the support available to land managers to help them optimise soil management (See Appendix 3).
The voluntary nature of the scheme may limit uptake of the standards when they are available.
When cross compliance is removed, in January 2024 at the point of delinking, we lose provisions to reduce windblown soil erosion, as well as not cultivating 2 metres from watercourses, neither of which are currently included in the regulatory baseline.
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 question targets only a subset of soils. There are large areas of land and soil not in the agricultural or horticultural sectors which also need to be well managed, including urban soils.
The success of agriculture depends upon healthy soils. Any changes in the food and agriculture sector need to look at all the ecosystem services provided by soils. Policy and legislation should be sense checked against these.
In addition to food production soil also provides wider ecosystem services to society, through carbon sequestration (see ‘Carbon Storage and Sequestration by Habitat 2021 - NERR094 (naturalengland.org.uk)), water quality regulation, and flood regulation. It’s imperative that these wider societal benefits are clearly communicated, protected, and enhanced.
People need reassurance, at an individual level and across the food production sector, that the food they eat meets the environmental standards that they expect. There is no current system to recognise the various shades of regenerative agriculture in food production, and the practices used often fall in between conventional and organic (certified) agriculture.
Natural England believes that the following measures would be helpful
5. What does UK Government need to do to tackle other stressors on soil health such as soil contamination?
A code of practice already exists for sewage sludge applications to agricultural land to prevent potentially toxic elements (PTE) accumulating in soil. Agricultural slurries and manures are not tested or regulated in the same way, but their repeated application can elevate contaminant levels and damage soil function. Sewage sludge can also contain chemicals not covered by the current code, meaning their impact on soil health is not known.
Government could consider:
Soil contamination from past industrial use requires remediation to improve human and environmental health. But sometimes contaminated land supports rare species which need protection from remediation.
Capping or a “dig and dump” approach to contaminated soils can concentrate pollutants and lose soil resource. Alternative biological and chemical remediation techniques are available but are often considered expensive and impracticable Natural England believes that the following measures would be helpful:
The ability to deliver soil health is compromised by:
Natural England believes that it would be useful to promote:
soil science education in schools, colleges, and universities
soils representation through national and regional designations
Many soil organisms are disturbed by land use change. The impact from these changes is relatively well known for above ground biodiversity, but less so for soil fauna with soil organisms largely absent from the priority lists of species.
To understand present soil biodiversity and likely past losses we believe that the following measures would help:
characterising soil biodiversity nationally
funding a strategy to monitor soil biodiversity across different habitats to prioritise their protection and conservation
monitoring habitats currently lacking protection for soil biodiversity
Natural England’s Long Term Monitoring Network (LTMN) includes the physical, chemical, and biological characteristics of soils in a range of habitats in National Nature Reserves (NNR) to detect how climate change and pollutant deposition impacts biodiversity and ecosystem function[5].
Natural England works alongside the Joint Nature Conservancy Council, Environment Agency, Forestry Research, and the Marine Management Organisation to deliver the NCEA. NCEA is a comprehensive programme to understand the extent, condition and change over time of biodiversity, ecosystems, and natural capital assets in terrestrial, freshwater and marine environments, supporting the government’s ambition to improve the environment within a generation (Natural Capital and Ecosystem Assessment Programme - GOV.UK (www.gov.uk)). An element of the NCEA programme is the England Ecosystem Survey (EES) which will include soil monitoring. It will comprise the measurement of the physical, chemical, and biological properties of the soil across all non-woodland, terrestrial habitats. Analysis will provide data on physicochemical characteristics of the topsoil and subsoil, an evaluation of soil structure, and biological information on flora (micro) and invertebrate fauna (micro, meso and macro).
To improve our understanding of peatlands, Natural England is currently developing a new England Peat Map, based on a campaign of peat depth and condition assessments, coupled with sophisticated spatial modelling techniques (Working towards a Peat Data Standard - Natural England (blog.gov.uk)). While this project aims to provide an improved understanding of our peat soils, ongoing national monitoring will be required to understand the impacts of our efforts to restore peatlands and prioritise future activity. The England Peat Map also represents a new, publicly available soil map, albeit for a sub-set of the country’s soils. Integration of this mapping with future efforts to produce and make available detailed soil maps for the rest of the country will enable coherent management and planning relating to land spanning both peaty and mineral soil types.
Peat soils are an important carbon store (C) but are susceptible to degradation through drainage, cultivation, forestry plantation, poor burning management, wildfires or through peat extraction. This can result in erosion and decomposition, leading to a loss of their stored carbon. Management and restoration of degraded peat soils is a high priority as it not only delivers protection for stored soil C but also helps to restore valued habitats such as blanket bog, raised bog and fens.
In addition, evidence is required about the impact of chemicals, fertilisers, microplastics and pesticides in soils, and their impact on soil health.
Key areas which require further work, include:
New techniques are developed to interpret soil biological communities as indicators of non-persistent chemical pollutants.
Better understanding of the impacts of chemicals, their degradation products, and interactions with other chemicals, on soil functions and soil biological communities
A clear and well-maintained system is needed to prioritise those chemicals most likely to be having a high and/or widespread impact, for monitoring
A clear policy mechanism is required to enable government to respond effectively to environmentally damaging exposure of soils to chemical pollution.
Our soils are a finite resource, and their differing capabilities can be lost completely through inappropriate development, or damaged or wasted through poor handling or misuse.
Built development is detrimental to soil health and function as it’s mostly permanent and irreversible. The finite extent and importance of soil, particularly within land use planning work, where development or other land use change may permanently impact on the soil resource needs to be reflected in the sustainable reuse of soils, in which soils should not be seen as a waste. Benefits of this are reduced landfill burden and reduced soil import.
Following the Defra Construction Code of Practice for the Sustainable Use of Soils on Construction Sites does not eliminate these adverse consequences and can only aim to minimise them.
For spatial planning, changes in land use are monitored by the Department for Levelling Up, Housing and Communities (DLUHC)[6]. Whilst not designed to monitor soil health they provide an insight into the likely magnitude of development impacts on soil, most notably physical loss, or sealing.
Concerns arising from the planning work include that development can have the most damaging and long-term impacts on soil health and function as it is largely irreversible where soils are completely removed and/or surfaces sealing by tarmac and concrete, or contaminated by rubble, PTEs etc.
The implementation of the mitigation hierarchy should be considered within planning: Avoid, mitigate and if all else fails there should be some form of compensatory mechanism developed for virtually complete loss of soil function (e.g., a levy to fund improvement of soil health elsewhere or improving soil education).
Concerns extend also to temporary developments. A recent increase in the scale (time and size) of solar developments loses agricultural land from (intensive) production for 40-60 years. This may impact food security by effective sterilisation of the soil resource. There’s also a risk that the land may not revert to agricultural use when the project ends. Limited data is currently available about how solar panels impact soils, meaning alternatives have yet to be explored. Technology has moved forward more quickly than planning policy and a greater flexibility is required in the planning framework to take account of this and other rapidly developing areas.
To ensure high standards of restoration, soil management needs embedding in planning policy (as per mineral developments).
Soil Management Plans are normal practice for minerals development (Minerals - GOV.UK (www.gov.uk)), to establish the soils baseline, inform site restoration criteria and appropriate soil management.
Soil resource survey could identify low nutrient or peat soils suitable for habitat creation or highlight the suitability of soils for specific on-site uses such as amenity or recreational areas, gardens etc.
Careful soil handling and management in accordance with the Defra Code will help retain as much natural soil functioning as possible, to maximise water infiltration, carbon storage, successful re-vegetation for landscaping and greenspaces and other environmental mitigations or improvements.
Natural England have recently commissioned research projects to deliver evidence and develop advice, tools, and guidance to inform the SFI Soil standards. This R&D work will improve the capacity of advisers to give good quality advice and to inform decision making, taking account of the multiple benefits of well managed soils and links between soils and habitats.
A comprehensive system is currently being scoped as part of a Natural England project, to provide decision support to farmers, land managers, and advisors, that will enable their management to deliver appropriate environmental outcomes, and thereby improve soil health, in the right places. Such a tool to optimise land use and management would also be of value for land use planning, and could help to deliver landscape scale improvements, by encouraging similar, appropriate land use and management across soil types spanning several land parcels, including agricultural and non-agricultural land.
If a single, comprehensive system of this nature can be developed, it also has potential to be used for interpretation of soil health based on measurements, integration with other farm planning (e.g., nutrient management planning, organic matter input planning, and farm management software), and to supply data for national monitoring. It could be linked to soil mapping: farmers or advisors might carry out local characterisations of their soil to identify their functional type, and this could be used to update the freely available detailed soil mapping mentioned earlier. Likewise, if use of the system is supported by payments with public money, the data could be used to identify potential areas of poor soil health, inappropriate management, or likely breaches of regulation, enabling better prioritisation, and targeting of inspections. However, it could also provide a basis whereby management or land uses most appropriate to the soil type could be rewarded with better rates of scheme payment than those which don’t reflect the land’s natural capability.
Agricultural management of soils affects many aspects of soil health and subsequent environmental health. There is a current paradigm shift towards regenerative agriculture systems that integrate sustainable food production with soil health (see Appendix 4). However, it is still unknown how best to restore degraded soils or understand the agronomic and environmental impacts of many existing soil and agrochemical management practices and there is no system to help farmers to target their land management to the most appropriate land. This will lead to misapplied management that will not only fail to improve soil health, but may exacerbate problems such as flooding, biodiversity loss, or climate change.
Within land management, strategies and systems can be applied that enable natural processes to carry out functions that we might otherwise attempt to deliver using physical or chemical interventions. This type of land management is represented by the broad concept of regenerative agriculture
The principles of regenerative agriculture revolve around growing food while replicating, as closely as possible, the natural processes under which soil has operated since it first appeared on the planet 400 million years ago. These processes include the ongoing input to the soil of organic materials, derived ultimately from plants, the provision of a stable chemical environment, lack of disturbance, and the reliance on soil organisms to provide the soil conditions (moisture, nutrients, structure, pest control) that enable crop plants to thrive. The development of regenerative agricultural techniques has been a combination of discovering past ways of farming that were replaced by quick technological (chemical or machinery) solutions during the last 100 years, or through the application of new technologies and understanding of how the soil system works, for example, using herbicides to enable no-till agriculture, or through a better understanding of mycorrhizal fungi.
Regenerative agricultural techniques in the UK have benefited from research carried out in other countries but have received little direct support in the UK. As a result, many of the techniques applied by UK farmers have been developed by the farmers, themselves and their value for food production based on individual’s experiences, as communicated through networks. While this is a valuable source of ideas and case studies, it cannot establish the scientific basis for regenerative agriculture. As such, a clear funding stream is needed, in collaboration with the agricultural levy boards and industry bodies, to maintain and support innovation in regenerative agriculture and to test and validate techniques in a wide range of soils and farm situations. These will include new methods of integrated non-crop organic matter into rotations, new methods of reducing reliance on herbicides to enable reduced tillage, new approaches to managing soils to promote communities that naturally control pests and diseases, and methods of managing soil organisms to improve nutrient supply, water use efficiency, soil structure and wider ecosystem services.
February 2023
[1] Through our new farming schemes, bring at least 40% of England’s agricultural soil into sustainable management by 2028, and increase this to 60% by 2030.
[2] e.g. SocEnv Soils and Stones Report Published | Society for the Environment; Sustainable management of surplus soils and aggregates (ciria.org); Soils in Planning and Construction Task Force | Sustainable Soils (lancaster.ac.uk); New Community of Practice for construction soil management (ciria.org); Our Work | Projects | Sustainable Soils Alliance
[3] a commitment made in the recently published Environmental Improvement Plan; Environmental Improvement Plan (publishing.service.gov.uk)
[4] for example: ADAS and FERA (2013), Evaluating the impacts of limiting free choice in management option selection by Entry Level Stewardship (ELS) applicants (NECR117), Research report for Natural England, part of the “Making Environmental Stewardship More Effective” (MESME) project, http://publications.naturalengland.org.uk/publication/5185845
Natural England’s evidence to the EFRA Committee inquiry into the ‘Environmental Land Management and the agricultural transition’, March 2021, paras 6.6–6.9, https://committees.parliament.uk/writtenevidence/22010/pdf/
RSPB’s evidence to the EFRA Committee inquiry into the ‘Environmental Land Management and the agricultural transition’, March 2021, para 44, https://committees.parliament.uk/writtenevidence/21834/pdf/
[5] Long-term Monitoring Network (LTMN) - Soil Chemistry and Biology Baseline - data.gov.uk; Long Term Monitoring Network: monitoring soils 2011 to 2016 - EIN024 (naturalengland.org.uk)