A Green Future, Our 25 Year Plan to Improve the Environment: Written Submission by the Directors of the Sustainable Soils Alliance prepared in response to the February 2018 Environmental Audit Committee inquiry.
We welcome A Green Future, the government’s 25 Year Plan to Improve the Environment, and specifically the overdue recognition that soil is a pillar of our natural capital alongside air and water, and that all three are fundamental for our country’s long-term economic growth and productivity. This is the first time that that soil health has enjoyed such focus in a government strategy, and for this much credit is owed to the Environmental Audit Committee’s 2016 Enquiry on Soil Health which moved the issue up the political agenda. The Plan is a potential watershed moment and might be instrumental in helping achieve the Sustainable Soils Alliance (SSA)’s own objective to drive the restoration of soils to health within a generation. However there are areas where further attention is needed, many of which reflect the areas of concern highlighted in the SSA’s eight point Call to Action, published earlier this year. We urge the committee to consider these as it holds the government to account and ensures that a promising document is translated into genuine, impactful action
1. Long-term Strategy
We are concerned about the lack of detail in the document – which comes across as a series of aspirations rather than a concrete plan. The Plan states: by 2030 we want all of England’s soils to be managed sustainably, and we will use natural capital thinking to develop appropriate soil metrics and management approaches - an objective which was first outlined in D’s 2011 strategy document: The Natural Choice: securing the value of nature. Yet, there is no indication of what progress, if any, has been achieved over the intervening period, and what are the lessons learnt.
This aspiration raises further questions. It remains unclear what is meant by ‘managed sustainably’ and how ‘natural capital thinking’ might apply to this objective, while the 2030 timeframe seems very ambitious. Further clarity is needed about the precise land use or soil quality indicators needed for this and the milestones between now and 2030 that will show whether the policy is on the right track.
It is our view that in order for this objective to be both achievable and measurable, it needs to be accompanied by a clear legal framework and set of targets – along the lines of those that exist already for air and water - and by a commitment to provide the resources (both people and funds) to support the agencies required to oversee and enforce the framework. The government might even consider the creation of a statutory instrument – a ‘Soil Act’ to achieve for their restoration what the Climate Change Act has done for reducing greenhouse gas emissions.
2. Economic Evaluation
We welcome the recognition throughout the Plan of the often hidden benefits of the environment for economic prosperity. When it comes to soil, however, no viable assessment has been made of the economic ‘value’ of the nation’s soil, the societal cost of soil loss and degradation or even a possible soil quality tipping point. The Plan references the economic cost of marine plastic pollution, waste crime and water treatment, but there is no equivalent figure for the – far more dramatic - cost of soil neglect and poor land management.
Government investment will be needed into the creation of the tools and methods needed to accurately and meaningfully quantify soil’s societal and environmental benefits. To be effective and enforceable, such mechanisms should be developed that can then be applied in future economic and legal drivers of land management – owner-tenant contracts, insurance schemes, public subsidies, land evaluation and bank loans.
The need for this evaluation is made acute by the creation of the post-Brexit farmer subsidy scheme to replace the CAP and specifically the challenge for farmers and other land users to deliver ‘public goods’. A shared understanding of the economics of soil will be invaluable as a means of driving reform, of linking land user and societal appreciation of soil and for translating the importance of soil into other policy areas.
We welcome the Plan’s acknowledgement of the importance of Developing better information on soil health and the importance of research and monitoring to give us a clearer picture of how soil health supports our wider environment goals. Indeed, none of the underlying measures – i.e. the development of standards or quality thresholds - are feasible unless we are able to measure soil health or quality in a meaningful way.
To this point we welcome the commitment to invest at least £200,000 in soil health metrics and testing, but are concerned that figure represents just the tip of the iceberg. We would draw the Committee’s attention to the equivalent German project 'Soil as a Natural Resource for the Bio- Economy (BonaRes)' a nine-year programme which looks to close existing knowledge gaps in soil management costing in the region of £100 m.
The SSA has already begun work alongside Defra and other stakeholders in the preparation of a detailed delivery plan for both on-farm and country-wide soil health evaluation and monitoring and hope to be sharing with them shortly the outcomes of a workshop held in collaboration with CEH, the Soil Security Programme and the AHDB Soil Biology and Soil Health Research Partnership which will investigate the options and opportunities for on-farm monitoring of soil health.
4. Pollutant reduction
We welcome the movement referred to in the Plan towards a more effective application of the ‘polluter pays’ principle. When it comes to soil, we would draw the Committee’s attention to the fact that 80% of the damage caused by soil mismanagement is experienced away from the source, such as through siltation of rivers or increasing carbon dioxide in the atmosphere.
Following our departure from the EU, we urge policy makers to develop a joined-up framework for agricultural nutrient pollutants reduction, one that maintains the targets and thresholds from relevant EU Directives and that reflects the all-important close inter-connectedness of soil, water and air.
Given the lack of an EU-wide Soil Framework Directive, soil provides a platform for the UK to demonstrate environmental leadership via the development of the world’s most innovative and ambitious soil restoration policy. To do so, however the government needs to address the very specific environmental challenge of contaminated land/soils – something that is not addressed in the Plan.
In general we welcome the suggestion that a rule-based approach to land management (using outcome-based soils rules) might be applied whereby either payments to farmers are conditioned on outcomes (as is already evidenced via cross compliance and GAEC) or harmful soil management practices are judged to be in breach of regulations and therefore subject to penalties.
The Plan demonstrates a continued over-reliance on voluntary measures which, recent history shows, have failed to deliver. A case in point is peat. The 2011 Environment White Paper set the goal to phase out peat in horticulture using voluntary action and with the promise to review progress in 2015 when alternative measures were to be considered if necessary. A 2017 survey revealed that sales of peat- based products are actually increasing, with no sign of Government having reviewed (or published a report on) progress in 2015. The deadline for phasing out all peat use in horticulture by 2030 in our view is, similarly, unlikely to be achieved if voluntary measures are preferred to a robust regulatory framework.
We welcome the suggestion that a post CAP subsidy system will reward farmers for delivering public goods – and urge that this includes managing their soil in a sustainable manner. This approach might include a minimum baseline for farming good practice (below which taxpayer support should not be paid), taking land capability into account as well as the suitability of a given location for cropping or farming systems.
Whatever approach is used to achieve this, there will be costs associated with monitoring and enforcement and these may not be small. Examining the trade-off benefits and costs of any policy regime must be a priority if policy is to be effective.
6. Innovation & Tools
We are concerned by the references in the Plan to ‘research and innovation’ as a pathway towards better land management, and specifically the example of hydroponic systems. These systems essentially take agriculture off the land and are not a replacement for basic crops such as wheat and rape. Applying R&I to sustainable soil management is less about new technologies and gadgets and more to do with enabling land managers to adopt and indeed locally design different (some innovative, some established) soil management practices, and to continue improving them with the assistance of research organisations.
Policy makers should not assume these new practices will be adopted without knowledge extension support. Mechanisms are needed to align public and private sector objectives to achieve good soil recovery and management practices to reduce the risk of environmental losses and anticipate unintended consequences - such as cases where no-plough soil management systems may depend on overuse of herbicides.
Soil health challenges are frequently systemic, and addressing them will require agri-food chain actors working together. This collaboration can produce further innovation, with the development of new logistical, technological, and information systems geared towards optimising soil health outcomes while ensuring robust supply chains. For such innovation to be spurred into action, a strong policy steer is needed.
7. Education & Training
Soil health has to be embedded in current education and training to provide future farmers and land managers with the skills needed to manage land and soils sustainably. Specifically we recommend a commitment for Defra to work with agricultural colleges, standard-setting bodies and the land-based industry, as well as with relevant departments (DfE and BIS), to develop appropriate training and education so that future farmers and land managers (such as farming contractors) will be skilled environmental managers. A plan to address environmental educational needs, customers, and means of delivery, is required.
The UK has an enormous potential in soil science research which is currently not being capitalised on as there is a noted disconnect between the farming and research communities. This is particularly due to the fragmentation of the research landscape, short-term funding, and the subsequent lack of structural capacity to support ongoing dialogue between the farming and the research industries (with the notable exception of Scotland). This can be addressed by Defra working with RCUK to ensure funding is made available for research which is truly farmer (and not just ‘industry’) facing, and which shows strong elements of knowledge co-production in the delivery of its objectives.
Enabling closer links between the farming and research communities in the interest of soil health can also be achieved by strengthening the current landscape of demonstration farms in the UK, which has shrunk significantly since its heyday. It is our experience that farmers need to see that soil conservation methods can work with their own eyes before applying it on their own farms. With this in mind, we urge Defra to consider re-invigorating the use of farmer outreach as a core element of any curriculum, especially one which delivers hands-on experience (demonstration farms, farm days and field walks).
We are concerned by the lack of integration between policies aimed at land management and nature conservation. Indeed, the two are being treated as entirely separate, with agricultural land presented as a food-producing resource and the environment as a distinct entity – even though 70% of UK land is agricultural land.
When it comes to soil management, there is considerable silo-working, including within single government bodies as well as between different stakeholder groups. For example, the role that soil management plays in flood prevention is not recognised in the Plan - either in agricultural land management or ‘green infrastructure’ in cities. While we welcome the acknowledgement that urban areas are as critical for environmental improvement as rural ones, we would like to see a greater commitment towards breaking down these silos, whether related to flooding, soils, rivers, nature or other environmental matters.
We would also emphasise that soil conservation is a systemic issue, and remind the committee of the considerable pressure placed on land managers from the agri-food sector. When driving reform, it is crucial to involve these big buyers alongside the growers, and consider all available mechanisms including the Grocery Code and its Adjudicator.
Soil is a global problem, and one where few countries have developed a fit-for purpose strategy. As we have said, the interest and attention the government is showing could be the platform to establish a global leadership position, but we urge close and continued collaboration with the EU as well as engagement with UN in demonstrating the UK’s fulfilment of Sustainable Development Goal 15: Protect, restore and promote sustainable use of terrestrial ecosystems, sustainably manage forests, combat desertification, and halt and reverse land degradation and halt biodiversity loss.