NFU – Written evidence (NSD0017)


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. We welcome the opportunity to respond to this inquiry as UK farming manages over 70% of our iconic countryside.


The NFU has an ambition to reach net zero across the whole of UK agriculture by 2040. We want to be world leaders in climate-friendly food production, and we believe our sector is very much part of the solution to decarbonising the UK economy. As both an emissions source and a sink, agriculture is uniquely placed CO2 and turn it into a wide range of foods, fuels and materials. Our goal comprises three key pillars: (i) Improving farming’s productive efficiency; (ii) Improving land management and changing land use to capture more carbon; (iii) Boosting renewable energy and the wider bioeconomy. This is a national aspiration, not an expectation that every farm can reach net zero.


Agriculture is also at the frontline of climate impacts and is particularly vulnerable to severe weather events. It is vital we act now to safeguard our nation’s food security, environment and livelihoods, taking a joined-up approach to mitigation and adaptation. Farming is already responsible for substantial carbon stocks in soils, wooded landscape and semi-natural habitats, and has a major role in helping society and wildlife to adapt.


Our key messages:


The NFU would like to submit the following responses to selected questions in this Call for Evidence.


  1. What is the potential scale of the contribution nature-based solutions can make to decarbonisation in the UK?


We believe that there is still some uncertainty around the definition and use of NbS as an ‘umbrella term’ encompassing a broad range of measures with multiple environmental benefits, including both climate change mitigation and adaptation. Planting/management of farmland trees, hedgerows and other agroforestry-type measures must be recognised and supported alongside larger-scale management of natural ecosystems.


NbS are not a substitute for emissions reduction, however we recognise that a reduction in peak warming cannot be achieved solely through emissions cuts, so NbS have an important contributory role to play. However, it appears to us that there is a growing consensus on the limits of NbS for climate mitigation[2]. Agriculture and certain other sectors like aviation will remain sources of GHG emissions, so residual emissions will need to be offset[3], by both NbS and engineered GHG removals.


Agriculture manages over 70% of the UK land area so it is important to focus on both maintenance of existing carbon storage as well as its enhancement. With the information available at the time of our analysis for our net zero goal (e.g. The Royal Society’s report on Greenhouse Gas Removals[4]), we estimated that farmland carbon storage in soils, hedges and trees, could reach potentially an additional 9 MtCO2e/year, delivering 25% of our ambition.


Our estimates are practicable and evidence-based, combining real-world experience and market intelligence. They are based on land sharing, not land sparing as improved farm practice and farming systems can demonstrate multi-functional land use. We agree with Seddon et al that by enabling a flexible, integrated approach to tackling different challenges, NbS can—if properly designed and implemented—enable synergies and minimize trade-offs between actions to achieve different goals.[5] Many have recognised that there are potential adverse impacts of some NbS activities on biodiversity and food security. Article 2 of the Paris Agreement sets out its purpose to “foster low GHG development in a manner which does not threaten food production”.


Tree planting has been prominent among NbS, with a focus on planting a certain number of trees. The NFU supports a different narrative, centred on “the right tree in the right place[6], with a broader portfolio of options at different scales so that “every tree counts”. We want to see the development and offer of more accessible grant schemes to fund trees in the wider landscape. This includes agroforestry type measures, hedges through to single and small groups and trees on farm that work with the farm business.


The NFU recognises that the utilisation of peatland has and continues to result in GHG emissions. We want to see estimates of GHG mitigation potential based on robust independent peer-reviewed evidence and which are clear about the economic outcomes for farm businesses and communities at different stages of the restoration process. Addressing peatland emissions from cropland, grassland and forestry could provide a high degree of abatement but measures that reduce GHGs without leading to large-scale loss of income to farmers and landowners, or to a decrease in UK food security, represent a key scientific and policy challenge[7].


  1. What major scientific uncertainties persist in understanding the effects of nature-based solutions and affect their inclusion in carbon accounting, and how can these uncertainties be addressed?


Continued research into emissions and mitigation solutions will be critical in establishing a robust independent peer-reviewed evidence base. This must include an economic impact assessment for clarity on what can be realistically delivered at reasonable cost. For example, in 2017 only 24% of estimated total emissions from the UK’s peatlands were assessed with fairly high confidence, a further 15% with moderate confidence, but the majority (61%) could only be estimated with a low level of confidence[8]. We are pleased to see ongoing research funded by BEIS and facilitated by participating farmers.


Transparency around NbS assumptions and uncertainties, and a better understanding of the range of mitigation potential are important in building confidence. Planting trees is easy; keeping them alive and healthy is not, with various threats to tree survival often beyond control of the land manager. Research undertaken for BEIS on peatland emissions excluded soils with a peaty organic horizon over mineral soil (often confusingly referred to as ‘shallow peats’ or ‘peaty soils’): these are very extensive in the UK, covering many uplands, but do not meet the national definitions of peat. There is also a gap in understanding how NbS will affect global temperature[9]. Lastly, the NFU notes that the Oxford Offsetting Principles see a clear role for relatively short-lived carbon storage such as many NbS, but that this must be accompanied by a shift towards long-lived carbon storage[10].


  1. What frameworks already exist for the regulation and financing of nature-based solutions?


The challenge of developing alternative environmental delivery models will be to develop approaches that reward multiple benefits, deliver a fair financial payment for the services provided and minimise administrative costs. Farmers would be willing to participate in these new market approaches, provided they are voluntary, and the obligations and actions are achievable, with flexibility to respond to unforeseen business or environmental changes, allowing modification or even termination. The scale of the transformation needed to deliver net zero and improved resilience alongside other public goods, means that the NFU is convinced that land managers must be able to stack public and private funds on the same area of land.


The Woodland Carbon Code is seen as quite complex, favouring those with a large amount of carbon to sell. Many farmers lack economies of scale, assuming food production remains the core business, but are keen to play their part through agroforestry or small-scale woodland planting (a few hectares). The NFU believes there is more potential in many farmers planting trees on a small scale, compared with fewer going into large scale forestry.


Likewise, the NFU is calling for a straightforward system of soil carbon accreditation and MRV. Development of a soil carbon code would be beneficial, but should not follow a one size fits all approach: rather acknowledging our diverse UK range of soil types, carbon storage potential and land management systems. A code would help farmers to better understand the potential of their land, enable a robust carbon market, build confidence, and hopefully prevent exploitation.


  1. Who are the key stakeholders for the implementation of nature-based solutions in the UK? How can stakeholders’ expertise and concerns inform the incentives and requirements for implementing nature-based solutions?


Farmers and growers are key to delivering successful and long-lasting nature-based solutions because of their local knowledge and the multi-generational nature of farming. The agriculture sector is uniquely positioned to deliver a transition to net zero whilst simultaneously driving productivity, levelling up economic growth and job creation across the whole rural economy.


Seddon et al highlight concerns that NbS may be implemented in the absence of community consent or cause adverse social consequences where rights are weak, notably on land tenure[11]. They recommend that local communities should be engaged in the design, implementation, management, monitoring and evaluation of NbS, fostering ownership, empowerment, and wellbeing of the local stewards shaping their landscapes. Engagement with farmers and the wider rural community must be genuine and early in the process and cannot be reduced to a box-ticking exercise.


In peatland restoration, many farmers may be interested in applying to do the work. Experience from the uplands suggests that the complexity of the tendering processes was a barrier. Recently £16 million was awarded for five peatland restoration projects but none seemingly have farming organisations as partners in the projects[12]. Trusted, local, knowledgeable individuals should be the source of technical advice and guidance. A just low-carbon transition requires fair and adequate incentives, with transparent funding delivered through schemes that are pragmatic and simple.


Most tenant farmers have clauses within tenancy agreements restricting the uptake of NbS, especially long-term or permanent projects, e.g. requiring the tenanted land to be farmed in accordance with good husbandry and good estate management which are often incompatible with NbS. The Agriculture Act 2020 enables an AHA 1986 tenant to obtain landlord’s consent via arbitration, but there is no similar provision for more modern Farm Business Tenancies. The short term of many FBTs (<5 years) may make it difficult for a tenant to carry out any longer-term NbS projects even with landlord’s consent, so projects would need to be transferable between parties. The NFU envisages that problems may also arise if landlords take back land at the end of a tenancy to implement their own NbS projects, so that the land is lost to the tenanted market. The financial reward of creating and maintaining any NbS should be received by the person carrying out the work, i.e. the tenant, and any new tenancies stipulating a tenant carry out NbS work would need to have this reflected in the level of rent payable.


New tree planting should support and encourage British sourced and grown saplings, providing an important biosecurity defence, and showing commitment to job creation / support in the nursery sector.


  1. How should implementation of nature-based solutions be integrated with other government policies for landscapes and seascapes, for example, agricultural, forestry, and land-use planning policies?


The NFU is very clear on this: farmers must have flexibility in how they engage with the future ELM scheme and should be offered a transparent deal that pays a fair return for the lifetime of the agreement. Our “Sustainable Food and Farming Scheme”, shared with Defra in 2020, describes an approach to a future agri-environment scheme that achieves these aims[13]. The SFFS sets out an ambition for the UK farm sector to be the global leader in climate friendly farming, delivering a broad range of other public benefits including landscape, biodiversity, access and animal welfare. NbS should not be seen in isolation from other outcomes: there is scope for an integrated approach.


The considerable uncertainty surrounding the future of government farm support schemes is fuelled by a confused funding landscape. There is a plethora of new funding streams available directly or indirectly through Government. Defra have already informed farmers of 13 different schemes within the Agricultural Transition Plan. ELM is only one of those schemes and ELMs itself will be made up of three schemes. Farmers can also, in theory, access schemes being delivered through the Nature for Climate Fund, however it is unclear to stakeholders and businesses how schemes fit together, who is eligible or the long-term implications of engaging with schemes.


9 September 2021


[1] See Q2.


[3] Sixth Carbon Budget - Climate Change Committee (

[4] Greenhouse Gas Removal | Royal Society

[5] Getting the message right on nature‐based solutions to climate change - Seddon et al. 2021

[6] NFU Tree Strategy

[7] Implementation of an Emissions Inventory for UK Peatlands (

[8] Implementation of an Emissions Inventory for UK Peatlands (

[9] Girardin et al 2021

[10] Oxford Offsetting Principles 2020

[11] Getting the message right on nature‐based solutions to climate change - Seddon 2021

[12] Thousands of hectares of vital peatland to be restored

[13] SFFS