Written Evidence submitted by the National Farmers Union (England and Wales)(SH0082)



About the NFU

The NFU represents 55,000 members across England and Wales. In addition, we have 20,000 NFU Countryside members with an interest in farming and rural life. Our purpose is to champion British agriculture and horticulture, to campaign for a stable and sustainable future for British farmers. Creating the right conditions for a thriving British farming sector includes promoting the health, safety, and wellbeing of our members.

We welcome the opportunity to provide evidence to the Committee’s inquiry on soil health. Good soil health is crucial to the future of UK sustainable food production, meeting ambitious net zero commitments, and delivering for the environment. Healthy soil delivers in reducing flood risk, supporting wildlife habitats and biodiversity, and the sequestration and storage of carbon.




Effective data usage

Monitoring and measurement are key to assessing progress towards making soils sustainably managed. The Government must work with farmers and growers to define what they mean by sustainably managed, while recognising the diversity of different soils and soil management techniques. A baseline from which to measure progress must be established, followed by suitable metrics which align with a commonly agreed definition of sustainably managed. Soil health indicators which align with these metrics would follow.


The main challenges in gathering data include the overall cost, a lack of expertise, and legislative barriers. Ownership and control of data is key to ensuring that this data protects sensitive personal and commercial information, while providing useful macro trends in soil health.


Regulatory framework

Gaps exist in current regulations that could be improved to ensure soil health. Policy must accommodate modern farming by providing incentives and guarantees for soil improvement. The Rock Review has recommended more flexibility for tenant farmers to encourage soil improvement, and the NFU supports this. There has been progress in the development of a UK Farm Soil Carbon Code (UKFSCC) to set principles and standards for a soil carbon marketplace, but this is still some way off. Regulations for voluntary carbon offset markets must be fair and accessible to farmers.


The role of ELMs

The NFU believes that the current Sustainable Farming Incentive (SFI) soil standards limit uptake due to its one-size-fits-all approach that is not viable for all soils and crop rotations. To improve soil health, the NFU suggests making ELMs flexible and accessible, offering stackable payments, including soil health management options in future productivity schemes, creating a regulatory framework for private environmental markets, providing farmers with capital support for soil management measures, and balancing soil improvement with preventative measures for pests and diseases.


Supporting farmers

The NFU is calling for investment in soil management research and innovation from both the public and private sector. Soil management practices need to be evaluated for their impact on physical, chemical, and biological soil health and that any research developed should be easily accessible to farmers. The NFU is currently supporting field-scale research and trials on new soil amendments and is working with a range of stakeholders including the four UK Agri-Tech Centres, public research organisations, and farmers to improve soil management practices. Farmers need to be encouraged to learn from each other and supported in taking risks with innovation. However, this is a challenge for smaller farmers who face more risk and capital expenditure for experimentation and adopting new systems.


Tackling soil contamination

There is a need for clear and enforceable regulations and assurance schemes to prevent contamination of soil by materials like composts, digestates, sewage sludges, and slurry. These materials must be kept free of contaminants such as glass, metal, plastics, per- and polyfluoroalkyl substances (PFAS), and other harmful substances. In particular there must be efforts to prevent such materials from entering waste streams in the first place. Regulations to reduce single-use plastics in wider society would benefit soil health and reduce contamination.




How can the Government measure progress towards its goal of making all soils sustainably managed by 2030? What are the challenges in gathering data to measure soil health and how can these barriers be overcome?



  1. Farmers have long recognised the value of their soils to their farming business. The naturally variable characteristics of soil have been one of the most significant factors in shaping local and regional land use. A combination of knowledge, research and technology is now driving increasingly sophisticated and diverse range of management strategies which are making soils more resilient, and sustainable.


1.1   With the right support and incentives, there are great opportunities to increase and enhance soil management, but only if we avoid overly prescriptive, simplistic, and restrictive approaches to doing so. Land managers generally have years or generations of accumulated knowledge about their soil. It is essential any goals to improve soil sustainability, and metrics to monitor progress, recognize that the best way to achieve them is in conjunction with profitable, and productive agriculture.


1.2   Monitoring and measuring soil health is key to sustainable soil management. Many farmers and growers already routinely test and assess soil fertility using professional soil testing services and use the data to maintain or improve crop and livestock productivity, as well as environmental benefits.


1.2.1         Regional and local variation must be accounted for in any metrics used to measure sustainability. Variation may extend down to the field scale, and the results of many of these must be considered in relative terms when used to assess trends in pH, structure, organic matter, and mineral content.



1.2.2         It is essential to know what we are aiming for when discussing the goal of making all soils “sustainably managed” by 2030. The NFU would welcome the opportunity to work with Government to define 'sustainably managed' soils and establish a baseline to from which to build from. Any baseline must take account of the considerable work farmers already do to improve soil health, and of the local conditions. A crude baseline, or one which starts at an arbitrary point would be counterproductive, as would one which did not support the wide range of ongoing projects and collaborations to improve soil health with catchment areas, water companies, and business.



1.2.3         Government should also work with farmers and researchers to reach a consensus on metrics to be measured that will meet the goal of sustainably managed soils and develop a suite of ways for farmers to assess progress in improving soil health. A central part of this should be focussed on how farmers plan to manage their soils sustainably and farm productively, and such planning will need to be flexible to accommodate the variability of managing soils, and any metrics adjusted as science, data gathering, and circumstances change.


1.2.4         Metrics must also account for what is frequently a non-linear relationship between management techniques and measured results. Variables like weather conditions, cropping, point in the rotation, time of testing, and soil type can mean actions which drive a measurable improvement in soil health one year, do not the next, or vice-versa. This can be compounded by variability or inconsistency in soil sampling. Improving soil health is a fundamentally long-term process, and progress may be difficult to measure in the early stages. Crucially, trends over time are much more important that short-term absolute measures.


1.3   In order to successfully measure progress, we suggest that the Government work with industry to identify key indicators that align with the agreed upon metrics and definition of sustainably managed soils. Such indicators could be chemical, physical, and biological and include levels of organic matter/carbon, nutrient balance, pH level, earthworm count, soil structure and biodiversity.


1.3.1         Interactions with water are also important, so drainage, water retention and compaction are also potential indicators of healthy soils. Great progress has been made with the AHDB’s Soil Health Scorecard and this project could be suitable for outlining these key indicators. It is imperative to take a collaborative approach to forming definitions for these indicators, to ensure they are realistic, flexible and capture the complexity of managing soils.


1.3.2         To utilise such indicators, the NFU supports the gathering, storage, and use of data to evaluate whether commonly agreed upon soil health metrics are being met. Measurement and monitoring are key to understanding whether progress is being made. Where metrics are not being met, the Government should work with industry to identify why, with reflection on the suitability of the metrics.


1.4   Reliable and accessible measurement, reporting and verification (MRV) methods are needed to benchmark the current situation against future progress, and enable farmers to make informed management decisions. Currently, the cost of MRV can be prohibitive, and there are concerns that a free market approach to soil testing could mean prices could rise in line with any Government soil support.

1.5   It is essential that there are robust data security and data governance mechanisms to ensure soil data is used only with the consent of those who supply it. Any large-scale data should be aggregated and anonymised to protect farmers and growers. Linking this data with previously gathered data from the Countryside Survey (launched in 1978) could provide some consistency and valuable information on long term trends and change.


1.6   There is significant potential to aggregate farm level data to gain valuable insights into the macro trends in soil health. Such aggregated data has the potential to inform future scheme design with improved reward mechanisms for environmental delivery, develop better targeted advice, inform research and development initiatives, and drive evidence-based best practice on farm.


1.6.1         The potential of using aggregated data will only be realised if farmers are provided with appropriate ownership and control over what data is shared and how their data is utilised. This includes providing appropriate protections for the use of data, restricting its use to anonymised macro level analysis and protecting sensitive personal and commercial information.

1.6.2         If sufficient confidence is achieved that appropriate safeguards on data sharing and use are in place, a farmer-led approach to data collection and sharing could yield significant benefits in developing the management capabilities and understanding of farmers, Government, and supporting industries.


1.7   A free nationwide comprehensive soil-testing programme, similar to that seen in Northern Ireland, would accelerate uptake and encourage farmers and growers to incorporate testing in business-as-usual management, which is broader and more frequent than the five-year statutory requirement.


1.7.1         Most arable farmers already test their soil, however free testing would very much encourage those who do not already do it. For grassland farmers, soil testing is relatively new so additional support is needed to interpret reports and advise on implementation. It is important to demonstrate the value of soil testing for grassland, as in many cases farmers can make visual assessments that can pick up the same issues as a soil test. While testing and measurement is important, it is not the only way to understand changes in soil health.

1.7.2         Enabling farmers to have the skills and ability to test, measure, and assess their own soils would provide greater consistency in long-term data collection. It would also lead to less reliance on third party advisers who may not have the knowledge or experience to understand the unique soil conditions prevalent on the land. Establishing clear and consistent methodologies and providing basic training resources could therefore be a cost-effective way to ensure progress is measured.

1.8   More needs to be made of new technologies like drones, satellite imagery and DNA sequencing to aid data collection. The industry is ready to take advantage of these technologies if the legislation catches up with the technology available. Soil testing should be affordable and accessible to give a true picture of the high variance of soil types both across a farm but also within individual fields.

1.9   An Environmental Land Management (ELMs) scheme that is well structured and designed can support Government in measuring and capturing progress towards a sustainable soils management. This will be dependent on positive take-up of the schemes.



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



  1. While maintaining healthy soils goes hand in hand with productive farming, the NFU believes that there exist gaps in current regulations that could be improved to ensure healthy soils.


2.1   Tenants, who make up at least 30% of the total land area in England and Wales, are increasingly under pressure from short-term tenancies and high rental costs. The tenanted sector underpins many existing farming businesses and provides an important route of entry for new farmers and growers. Regulations to provide flexibility in tenancy agreements could therefore incentivise long-term commitment to soil improvement. Tenancy legislation and private agreements should recognise and reward agricultural tenants for the additional benefit they add to soil quality.


2.1.1         The nature of tenancy agreements can lead to a tension between short-term, profit-focused agreements on farmland owned by someone else and the desirability of long-term actions to improve the soil. To encourage improvements in soil health and sustainability, policy must accommodate and support the reality of modern farming with incentives and guarantees. Without it, even simple measures like liming or applying manure to soil to improve the pH or organic matter content can be disincentivised on land held only on a short-term basis.


2.1.2         The Rock Review has made recommendations to provide tenants with more flexibility that could promote tenants’ investment in the land, and in maintaining and managing good quality soil. We encourage Government to respond comprehensively to these recommendations.


2.2   Sensible regulation of voluntary carbon offset markets is also key to helping improve soil health. The developing market in voluntary carbon offsets presents both opportunities and long-term implications for agriculture. Farmers and growers need to have confidence that the rules and standards of the market are fair and accessible. The ELMs rollout and other government incentives must work alongside private finance to incentivise action to build further carbon stocks as well as reward maintenance of the existing stores.


2.3   Markets should be accessible across a range of farm sizes, tenures and business structures, and, critically, farmers and growers must be fairly rewarded for the delivery of environmental goods. High quality offsets need to be additional, verifiable and permanent, all of which present challenges for soil carbon offsetting, particularly around soil science and the ability to maintain carbon stocks over time.


2.4   For agriculture to engage in environmental markets at scale, there is a particular need to accelerate the development of a soil carbon code. A UK Farm Soil Carbon Code (UKFSCC) is in development to set the principles and standards required for a soil carbon marketplace for farmers and growers, investors, and the environment. The development of a UK specific soil carbon code is some way off.


2.5   A barrier to improving soil health can be the difficulty of storing organic manures on arable farms before use. Whilst this is a relatively well-known problem, more support for transporting manures to, and storing them on arable farms so they are readily available for use when appropriate would improve soil health. At the moment, farmers frequently decline offers of manures and slurries because they lack the ability to store them in a way which meets current regulations, or is practical, until point of use. This is especially true with liquid forms.


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? 


  1. The NFU ask that future policy on soil management will be flexible and not oversimplified. Ideally, ELMs would pay for mitigation and maintenance measures as well as allowing multiple funding streams so that farmers and growers can deliver for soil health, food, fibre and fuel production and the wider environment.

3.1   The ELMs prospectus does include some soil health management options like soil testing of organic matter, applications of organic manures and cover cropping. It now needs to evolve to address nutrient management and reduced tillage, if appropriate to the farming system. Payment rates need to act as an incentive to participation and disparate components of ELMs must be joined up to present a viable incentive to growers.

3.2   The current one-size fits all approach of the Sustainable Farming Incentive (SFI) soil standards limit uptake through scheme design. The standards must be practical and achievable, as well as tailored for application across a range of different soils and crop rotation. Problematically, the standards combine actions required. If a business cannot do all the actions, it cannot enter the field into the standard.

3.2.1         The arable soils standard does not work for farms with root, vegetable, and outdoor salad crops in the rotation. Similarly, the grassland standard focusses on intensive grassland systems at the expense of longer-term and permanent pasture systems. These issues need to be addressed to secure greater uptake of these standards.

3.3   As custodians of organic matter and carbon already in the soil, farmers would like to see the conservation and maintenance of these stores properly rewarded. SFI take up is currently poor. If the standards are not made more attractive, it is unlikely that many will enter into SFI and soil objectives will become very difficult to achieve.

3.4   For ELMs to positively impact soil health, incentives are needed to promote and accelerate the uptake of soil management measures which can place an extra burden on a farm system. To deliver improvements in soil health through ELMs, the NFU’s principal asks are listed below: 


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? 


  1. We are concerned that a ‘one size fits all’ approach could be detrimental to soil health given the heterogeneity of different soil types, and different management types that are needed to keep soils sustainable. Soils are a diverse resource that benefit from a tailored management approach. What works for one location may not work for another. Different soils have different needs, different abilities to store carbon, to hold water, and to grow crops.

4.1   In the NFU’s report, the Foundation of Food – our vision for good soil health, we set out our vision for a long-term, coordinated policy approach, which incentivises farmers to improve their soil and accounts for the needs of individual farm businesses. In particular, the NFU asks for:

4.1.1         Investment in research and innovation: there is still much to learn about soil and how management practices affect soil health. Cross-centre collaboration on soils research is key to setting innovation priorities and making sure that the solutions filter down to farm level.


4.1.2         Better data collection and processing: As already highlighted, the measurement, reporting and verification (MRV) needs to be reliable and accessible so that we can truly measure progress. In essence, soil testing needs to be affordable, reliable, and easily understood by farmers and growers, some of whom may not have much experience of the testing methods. Data alone however are not enough, and the Government would need to take care that it does not end up with an overly bureaucratic and inaccurate soil monitoring system that still oversees decline. Rewarding and incentivising good practice alongside data collection is likely to achieve better results in the long run.


4.1.3         Facilitation of the voluntary carbon offset markets: Carbon offsetting represents an opportunity for farmers and growers, but we need to have confidence in the rules and standards, making sure the markets are accessible across a range of farm sizes, tenures and business structures. We encourage the rapid development of the soil carbon code, and we need to see the voluntary markets working with ELMs to ensure fair reward for delivery of public goods.


4.1.4         Sufficient incentivisation: Soil management measures do put an extra cost burden on the farm system. When reflecting on how to best develop proportionate incentivisation, the Government must consider that:



4.1.5         Flexibility in tenancy agreements: As tenants make up at least a third of the total land area in England and Wales, it is essential they are recognised and rewarded for the additional benefit they make to soil quality. Flexibility in tenancy agreements could promote tenants’ investment in land.


4.1.6         Sustainable peatlands: Peatland is critical to producing food as well as being a valuable carbon store. Policies must incentivise a balance between sustainable food production and soil protection, and not be overly complex to farmers. Local decision making should tap into the generations of expertise and knowledge of farmers and growers. We believe incentivizing farmers to investigate more sensitive farming methods can be achieved by providing greater support and research for farming peatland in a more sustainable way.


4.1.7         Knowledge exchange: We need continued government support for the AHDB and industry initiatives like Championing the Farmed Environment, Tried & Tested and The Voluntary Initiative, alongside projects like Catchment Sensitive Farming. They play an important role in providing farmers and growers with the knowledge and skills they need. Supporting these initiatives should be reflected in SFI standards and 'earned recognition'.

4.2   Further investment in research and innovation from a cross sector range of both the private and public sector will be essential to encourage better soil management. Private industry has spent a lot on soil management research and development in the last 20 years. In particular, the sugar beet sector has invested heavily over the past 20 years in research, innovation and technology towards improved soil management. Government support is vital to allow us to go further and faster.

4.3   There is still much to learn about how soil contributes to productivity, biodiversity and climate change. We need to assess the impact of soil management practices on physical, chemical and biological soil health. Research then needs to filter through to farm level in a practical and accessible way. Support for a network of demonstration farms is needed to deliver proof of concept of new technologies. Industry must continue to collaborate on better ways of managing soils whilst better demonstrating the positive steps being taken already to improve soil health.

4.4   The NFU is supporting field-scale research and trials on new soil amendments for landspreading (biochar, enhanced weathering minerals), which can capture carbon; their long-term interaction with soil ecology needs to be evaluated before their possible inclusion in soil management policy.

4.5   The four UK Agri-Tech Centres, alongside publicly funded research organisations and institutes, are working with farmers and businesses across the agrifood value chain to support greater efficiency, resilience, and profitability. While each organisation has its own unique focus, our soils are ubiquitous to all farming sectors and systems. Cross-centre collaboration on soils research, innovation priorities and solutions could be a powerful and resourceful contribution to the industry continuing to improve the way we manage our soils.

4.6   Farmers have always valued their soil and continue to experiment with new approaches to soil management such as companion cropping or different grazing regimes. Market volatility and rapidly increasing input prices have further motivated this on-farm innovation. Farmers need to be encouraged to learn from peers to improve the industry’s knowledge and uptake of appropriate new practices that benefit both farm productivity and the environment.

4.7   Similarly, supporting the risk that comes with innovation is key. One of the biggest barriers can be the cost of adopting a system without a guarantee of success. Few farmers can afford to risk fields and crops with experimentation because of the potential hit to farm profitability. A change of system can also incur significant capital expenditure in equipment and training, which can also provide a barrier to further innovation.

4.7.1         The barrier of cost is magnified for smaller farmers, because experimenting with a change of system on 20ha entails significantly more risk to a 200ha farm, than a 1000ha farm. The situation is similar when considering the capital costs associated with investing in equipment to do experiment. It’s also more difficult, and disproportionately expensive for smaller farmers to secure the services of contractors as a way to trial new systems. This is a barrier which is difficult to overcome without an appreciation of the complex assessment of risks farms undertake.


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


  1. Soil contamination is an issue that emerges from the wider supply chain. Clear, practical, and enforceable regulations on the contamination of materials that are spread to land, as well as robust assurance schemes are key.

5.1   Given the historically high costs of artificial fertilisers, land managers and farmers are looking at alternative ways of safely providing nutrients to their soils while maintaining soil fertility.

5.2   Composts, digestates, sewage sludges, and slurry must all be kept free from glass, metal, plastics, per- and polyfluoroalkyl substances (PFAS) and other contaminants as much as possible if they are to be spread to land.

5.3   As well as removing these contaminants at Anaerobic Digestion (AD) plants, composting facilities and waste-water treatment facilities, there must also be efforts to prevent these materials entering the waste streams in the first place. Regulations to remove single-use consumer plastics and other potential contaminant from society in general would benefit those who manage their soils.

5.4   It is key that the responsibility to ensure contaminants are not in products applied to soil is remains with those who produce them, however any measures controlling this should not result in an excessive burden or cost on farm.


February 2023