December 2023

To coincide with both World Soils Day and COP 28, Parliament’s Environment, Food and Rural Affairs Committee has published the report summarising its year-long inquiry into soil health in England. It points to fragmented and disjointed soils policy, and includes numerous recommendations for government action that reflects the range and variety of challenges that face England’s soils.

The Sustainable Soils Alliance (SSA) welcomes the report which provides an accurate and helpful diagnosis of the problem, alongside a proportionate and well targeted list of the policy actions required to address it.  At its heart lies the clear, emotive message of the neglect that soil suffers in comparison with other equivalent indicators of the natural environment – air and water, a message that should act as North Star for this and future governments looking to put soil at the heart of their sustainable and regenerative farming policies.  

The report echoes many of the observations that we and other soils community stakeholders raised with the Committee throughout the inquiry – demonstrating a clear consensus around the need for action.  The SSA will reflect these points in our campaign work running up to the General Election, and work with other stakeholders to see that they are reflected in the manifesto planning of all the major parties.

In the briefing below we have laid out the key messages from the report, along with a timeline of the Committee’s recommendations compared to existing government plans. 

1. Lack of leadership in government soil policy

With the opening of the 2023 Sustainable Farming Incentive(SFI) offering a number of soil actions, targets for sustainable soil management embedded in the Environmental Improvement Plan (EIP), and an upcoming Land Use Framework, it may appear there is  progress being made in addressing the crisis of soil degradation. However, the committee were stern in their condemnation for the “lack of leadership” when it comes to soil policy, and throughout the report were calls for the government to give soil the same recognition as other aspects of our natural environment. The current shortfall in recognition can be traced back to the 2021 Environment Act which doesn’t require targets for soil health improvement, and the fact that soil receives just 0.4% of the funding for monitoring compared to air and water. To change this, the report makes it clear statutory targets are need for soil health to give it equal legal importance, as well as a significant shift in funding. 

2. No call for a Soil Health Action Plan

In 2022 we were disappointed to see the shelving of a Soil Health Action Plan for England, with targets instead incorporated into the EIP. Other witnesses shared our frustration at these targets, which are a huge downgrade in ambition from original government goals for sustainable soil management. The Committee recognised this, but argued that a standalone SHAPE would lead to confusion by adding to already the already existing EIP, Peat Action Plan and upcoming Land Use Framework. From our perspective this might not be sufficient for a comprehensive soil strategy: 

• The EIP has just two pages on soil, and the targets therein have slashed ambition from all of England’s land to be under sustainable management to just 60% of only agricultural land
• The Peat Action Plan set out plans for the management, protection and restoration of peatlands, but these cover just 12% of the UK 
• This means a great deal rests on the soon-to-be release Land Use Framework which will guide policy decisions about how land is used in order to meet climate and nature targets.   It remains to be seen the extent to which soil health will be considered- while the recent House of Lords Land Use Committee report mentioned soil health a number of times, the government response did not.

3. Concerns around ELMS delivery

The evidence given by the Minister for Farming Mark Spencer confirmed our understanding that Environmental Land Management schemes as seen as the “main tool for encouraging the restoration of soil health”. The committee picked up on this, and hence covered in their report wider concerns around incentivisation schemes, which might ultimately pose barriers to ELMs successfully addressing soil health:

• Despite Defra promising full transparency, the government has yet to publish data on how the payment rates were calculated, which has limited confidence among farmers that the schemes are worthwhile
• The calculation of payment rates has failed to address all the costs of implementing the standards, which are therefore not attractive enough for many farmers
• The Committee had significant concerns that the standards are inaccessible for certain farmers, especially tenant, non-arable, small scale and horticultural farms
• Numerous witnesses argued that the ‘pick and mix’ approach is unsuitable for driving real change, as farmers can simply enter a small parcel of land with one standard and not look to soil health improvement over the rest of their farm
• Linked to this are concerns that that the SFI is not ambitious enough and will not have an impact on the root causes of degradation, especially regarding limited support in SFI for organic, addressing compaction, and improving crop diversity- This isn’t helped by the stripping away of half of the soil-specific since the inquiry begun

4. Critical gaps in regulatory framework 

There are significant gaps in protections for soil, and the Committee recognise that the situation will get worse with the phase out of EU-based Cross Compliance at the end of this year. In the long term the report suggests that a strong regulatory baseline is needed, becoming increasingly ambitious to “ratchet up soil protections” and prevent degradation. This would mean that in the future regulation should represent minimum requirements for all farmers, while ELMs can continue to develop concurrently to support the restoration of soils at a higher level. The report questioned whether the Environment Agency’s aim to increase visits from 2% to 4% of all farms will be enough to support farmers and address malpractice, especially given the Environment Agency recently stated that “compliance with limited soil-related legislation is poor”. We hope this will be picked up at the ongoing EFRA inquiry into the Environment Agency, and the Industry and Regulators Committee inquiry into UK regulators. 

5.  Agreement on metrics is needed

Action to reverse degradation is currently hampered by the use of disjointed measures of soil health among farmers, academia, government and the supply chain. Without a common set of indicators, there is no way for the wide range of stakeholders involved to comparatively measure their soil health and interpret the results. This was echoed in the recently released Environmental Audit Committee report into Environmental Change and Food Security, where the importance of soil for food security was explored. We’re glad this vital component of improving soil heath has been recognised, with the EFRA Committee urging the government to finalise the promised soil health indicators by the end of 2024. The first step is likely to be revealed soon, as Defra recently announced the imminent publication of their Soil Classification Framework, that will hopefully unify all soil health monitoring.

6. Sustainable farming needs to be profitable

Despite the rollout of ELMs and growing interest in private ecosystem markets, numerous witnesses raised the point that addressing unsustainable soil management is not financially viable for farmers, with an overall lack of profitability in the sector driving farmers to intensify practises. This report calls for the government to work with the supply chain to ensure that assurance standards and contracts with retailers support sustainable soil management. The Committee stopped short of considering how the imbalance between costs of production and consumer prices can be addressed in a non-regressive manner, a question that has also been be raised in the inquiry into fairness in the food supply chain.

7. Little focus on carbon markets

Although the report touched on the role of private finance via ecosystem marketplaces, it left for the future any in-depth analysis of how they are developing and impacting farmer’s decisions. There was no exploration of farm soil carbon markets, despite the rapid growth in the sector, but separate Environmental Audit Committee inquiry into the role of natural capital in the green economy is currently exploring these questions in more detail. Meanwhile, the BSI are developing standards for nature investment markets, that the Farm Soil Carbon Code Consortium is feeding into. 

8. Need for data to guide decisions

Running through much of the report was the understanding that a lack of data on the health of the country’s soils is hampering progress on reversing degradation. This data is vital to build an understanding of what areas to prioritise, and what practices are most effective, in order to support farmers transitioning to sustainable soil management. Without a baseline understanding of the state of our soils there is no way to measure progress, and the Committee made it a priority for the government to put consistent data at the heart of future soil policy. This will require ring-fenced funding, but at the moment we don’t know how much is being spent- the budget for the Natural Capital Ecosystem Assessment is £140 million, but how much of this is dedicated to soil? Currently data on soil health is not being collected from the farmers who have signed up to the SFI standards the require soil testing, and we’re glad that the Committee share our opinion of this as a huge shortfall. They have recommended that “ELM schemes should incorporate mechanisms to feed publicly funded data back into the soil health monitoring programme” and recognise the need for anonymization. 

9. Education and advice

It was noted that general understanding of soil health, as well as regulations and options for government and private finance, remains low among a large number of farmers. These knowledge gaps prevent more rapid uptake of sustainable systems and incentivisation schemes, and the Committee highlighted the need for supporting the farm advisory sector and encouraging peer-to-peer learning. We welcome the recommendation for a review into skills and training, but would like to see more concrete action from the government before 2026, given farms are already presented with a bewildering array of messages around metrics, environmental outcomes, technologies and financial opportunities relating to their soil.  This will only grow as supply chain demands, the market for soil carbon, and the array of sustainable labelling/ measurement schemes expand. 

10. Timeline of recommendations for soil health

This timeline sets out all the recommendations made by the EFRA committee in their report, alongside already existing government targets and promised delivery dates.