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Overview of the responses to the draft Soil Strategy

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1. The draft soil strategy for England - a consultation paper was issued for consultation in March 2001 with comments requested by the 31^st May. Some 110 separate responses have been received from a wide range of stakeholders and interested parties. A list of those who responded is provided on page 8. The responses have now been assessed and comments collated and indexed. This note gives an overview of the main points and comments raised both generally and in response to the specific consultation questions. It does not comment on the more detailed, technical queries on individual paragraphs and sections unless they have wider implications for the draft strategy.

The need for a soil policy and the strategy approach

2. The importance that the Government is giving to the protection and sustainable use of soils is widely welcomed and regarded as an essential part of the Government's sustainable development policy. Not all of the responses specifically commented, but the majority agree with the proposal for a soil policy and that a strategy is the correct approach to developing one. Three responses agreed with the need for a soil policy but feel that this would be best served through integration of a soil perspective into existing policies and guidance.
3. Many feel that the current draft is a good review of current issues and Government activities, but needs further work to make it an operational document capable of developing a soil policy or forming the basis of an implementation plan for supporting one. In particular, the strategy must provide clear, coherent policy statements and a set of actions that state: what needs to be done, how, by whom and when. It is felt that implementation will be best served by the establishment of a single group or branch within Defra that is responsible for co-ordinating on soil issues and developing soil policy.

Contribution to sustainable development

4. As an essentially non-renewable resource, with intrinsic value in its own right, soil protection is a worthy goal within any overall policy for sustainable development. But, soil is especially important and central to any such policy because it is a primary resource that provides many functions and uses that underpins the three pillars of sustainable development: society, economy and environment. By affording soil the same status as air and water and by ensuring its effective and appropriate use and management, a policy will protect soil from irreversible degradation for future generations.
5. However, concerns have been raised that the strategy is too focussed on the environmental aspects of sustainable development and doesn't adequately address social and economic issues. One of the responses commented: "England is in the middle of a rural crisis and soil is key to sustaining agriculture, tourism and amenity; it is vital to the economy and social capital not just the environment". This is not only the case in rural areas but healthy soils are also an important issue for the urban environment. There also needs to be acknowledgement that demands made on the soil are increasingly conflicting and could undermine achieving the 4 sustainability objectives set out in 'a Better Quality of Life' (paragraph 1.3.2 of the Soil Strategy)
6. Some also believe that the approach is too insular and although references are made to global issues, more needs to be made of their wider relevance to sustainable development in Europe, and globally. Such global issues include climate change, food production and conservation of habitats.

The key objectives for developing soil policy

7. The objectives for the extent, diversity and quality of soil are generally supported as key policy objectives. However, there is concern that using them to structure the draft confuses many issues especially where there is overlap. For example, soil loss through erosion, which is in the chapter on extent, is often the result of a decline in organic matter: a quality issue. Such issues are not easily resolved by the current structure. The alternative structures suggested are:
• using soil functions as sections e.g. maintenance of biodiversity, providing food and fibre etc, and addressing extent, diversity and quality within them. Sections should identify what is soil used for now, what is it best used for and what might be the future range of uses
• or, structuring the strategy around soil issues such as: loss of soil to development; loss of soil to coastal erosion; fertility of agricultural soils, soil and the water environment. For each issue the strategy should identify:
• What the problem is
• current activity and knowledge
• whether current measures are sufficient
• if not, what new measures and actions are needed including what is to be done, by whom, how and when
8. If the present structure is retained, additional objectives should include:
• soil and human health
• soil and water
• soil and the economy
9. Although in agreement with the three objectives, specific comments on their actual wording within the draft, and the potential for confusion and misinterpretation is an another general theme of the responses. The main points are:
• to manage the extent of the soil resource in ways which ensure we can meet our present land-use needs
• the term 'extent' is misleading and it is unclear whether it refers to extent of the problem or changes in spatial extent
• in Chapter 2, land-use needs to include managing soil for wider environmental purposes such as: for protecting water quality; helping to alleviate flooding; retaining and enhancing ecosystems
• to manage the diversity of soils, concentrating particularly on our most valued soils, so that the right balance of soil types is available to meet current and future needs for soil to support our ecosystems as well as landscape, agricultural and cultural functions
• with respect to the 'diversity' of soils, what are our most valued soils? All soils are important e.g. many poor quality soils support important, rich and diverse habitats. Diversity must address the multi-functionality of soils
• it must be made clear that ecosystems includes those within the soil itself
• 'quality', as with diversity, must also be seen in the context of the multi-functionality of soil. The present section on quality focuses too much on agriculture; there are important soil quality issues for the soils in semi-natural habitats and urban areas
• the term 'manage' should be changed as things can be managed well or badly. Alternatives include 'preserve and enhance'
• there is insufficient information to tell us the extent, diversity and quality of our soils

Pressures, state and response

10. Although most of the main issues and pressures are covered, there are areas that are either not mentioned or not covered adequately. The main areas are:
• the need to be set in a European context and the implications of drivers such as the Common Agricultural Policy (CAP), the Rural Development Project, the joint UNEP and EEA statement, the Water Framework Directive and the European Union 6^th Environmental Action Programme proposal for a European soil policy needs to be discussed
• the interaction between climate change and soil
• forestry
• soils in the urban environment
• soil as a diverse habitat in its own right and the multi-functionality of soils is not adequately addressed
• the links between soil management and water management need to be more fully recognised
• major stakeholders and the activities they are already carrying out to protect soil need to be mentioned
• the need to educate and raise awareness of the importance of soil and its sustainable management
• biological aspects of soil and environmental interactions
• Contamination of soil by organic pollutants
• potential implications of GMOs on soils. (There may be no implications but it might be necessary to have a position statement that at least addresses the issue.)
11. Information given on the 'state' of soils is regarded as adequate within the constraints of the data available.
12. Many feel that the strategy responses should go further and that several opportunities are missed. There are strong views from a wide range of stakeholders that new legislation and financial incentives that explicitly protect soil are essential; there is little confidence in voluntary measures. One approach is the development of criteria for designating special sites, such as SSSIs, specifically for soil and to bring agriculture under a wider suite of planning controls. The development of incentive approaches, such as agri-environment schemes, to encourage sustainable management of soil is also supported. However, one respondent raised the point that promises to reduce regulation and red tape in the Rural White Paper will make protection of soil harder to achieve.
13. Some believe that environmental impact assessment should be introduced for all land uses, including agriculture, and that the revision to PPG1 - General policy and Principles - offers the opportunity to introduce soil protection measures. It was also suggested that the success of PPGs for archaeology and nature conservation indicate the necessity of a PPG specific for soil.
14. Responses from several parties highlighted the need to encourage the re-use and recycling of soil and mineral resources and feel that this does not come through strongly enough in the strategy.
15. The importance of 'local partnerships' for delivering improved soil management practices, such as the River Parrett Catchment Project, is also highlighted. The project brings together local farmers, FWAG, English Nature, Local Planning and Highway authorities and the Environment Agency and aims to reduce soil erosion and moderate flooding through improving soil management; such partnerships should be both mentioned and encouraged by the strategy.

Establishing a monitoring framework and a set of national indicators

16. There is clear agreement that a single, co-ordinated national monitoring framework and a robust set of national indicators is essential and will provide a means to assess the success of a soil strategy. Targets should be set, but it is acknowledged that further research is required to set them reliably in some areas. In the meantime, the lack of information and the need to develop some indicators further should not be used as an excuse to delay action.
17. The monitoring framework should be administered by a single agency and will require a long-term commitment by the Government to support it. It is also vital that the data and information collected is made widely available and disseminated to the public; accessibility of information is one of the flaws of the existing monitoring schemes.
18. The indicators should form two tiers: a first tier of simple, broad indicators that inform on national trends and issues and a second, more detailed set that can support decisions and identify problems at more local, even field, scales. There should be flexibility so that new measures can be introduced and regular reviews so that only those that are effective are retained. The indicators should be biological, physical and chemical in nature; relate to soil function and key soil processes; and be sensitive enough to detect changes but not enough to be confused with natural variation. It is important that guidance and information is provided on the use and interpretation of the indicators for a range of users and interested parties, and that they are used to inform the public.

The review period

19. The views on the five-year review period are mixed. To many, five years is regarded as being adequate but some suggest there is a need for shorter review periods (three years has been suggested). This is particularly important in areas where policy is likely to change e.g. Sludge Use in Agriculture Regulations, or where it undergoes regular changes e.g. CAP. It is also suggested that because some soil properties change very slowly, longer review periods might be necessary in some cases.

Prepared by Peter Redfern for
Marine, Land and Liability Division
Defra
July 2001

List of responses

1. National Trust 2. English Nature 3. Dr Robert Evans 4. Ms Clare Stuart 5. Friends of the Earth (Swindon Branch) 6. Wealden Council 7. Land Look (Midlands Branch) 8. British Sugar 9. Multicultural Organic Shambus Society 10. Institute of Arable Crops Research (IACR) -Rothamsted - Prof. Philip Brooks 11. University of Reading 12. IGER - Institute of Grassland and Environmental Research 13. Herefordshire Council - Monuments Section 14. Fieldfare Associates 15. East Staffordshire Borough Council 16. Rugby Borough Council 17. Dr Roland Bol - Soil Scientist 18. Natural Law Society 19. Dr Bridges - Soil Scientist 20. Cranfield/SSLRC - Cranfield University & Soil Survey Research Centre 21. Concerned Residents of Wivenhoe 22. University of Newcastle - Professor David Manning 23. Queen Mary University 24. Ms Caroline Clarke 25. Dr Bruce Lascelles 26. Gateshead Council 27. University of Wales (Swansea) Dr. R A Shakesby 28. Luton Borough Council 29. Horticulture Research International 30. University of York 31. BSSS - British Society of Soil Science 32. CLA - Country Land and Business Association 33. Ms Cara Wilson 34. University of Newcastle - Dr David Rimmer 35. Farmers Link 36. University of Lancaster 37. Mid Sussex District Council 38. Institute of Field Archaeologists 39. Dorset County Council 40. University of Wolverhampton 41. North Hearts District Council 42. Mr John Richardson 43. Newark and Sherwood District Council 44. Mr Steven Bailey 45. Friends of the Earth - Dartford Branch 46. Hampshire County Council 47. Forestry Commission 48. Shropshire County Council 49. Mr. Bob Evans 50. Dr P Cawse 51. Friends of the Earth - Saffron Walden 52. CPRE - Council for the Protection of Rural England 53. National Council for Housing and Planning 54. Town and Country Planning Association 55. Environmental Services Association

56. Mrs L Priest 57. Ms Tessa Gee 58. Friends of the Earth - Devizes 59. Wycombe District Council 60. Woodland Trust 61. Royal Society for the Protection of Birds 62. NERC - Natural Environmental Research Council 63. SRI - Silsoe Research Institute 64. IACR (Institute of Arable Crop Research) - Rothamsted 65. QCA UK Limited 66. Initiative on Organic Research 67. Soil Science Advisory Committee 68. West Sussex County Council 69. Ms Helen Paul 70. Liverpool City Council 71. Cranfield University/SSLRC/NSRI - Ian Bradley 72. Institute of Arable Crops Research (IACR) -Rothamsted - Prof. S McGrath 73. Local Government Association - West Midlands 74. Urban Environmental Regeneration Division - DETR 75. UK Climates Impacts Programme 76. Friends of the Earth - Leicester Branch 77. MLURI - Macaulay Land-use Research Institute - Confidential 78. Plantlife 79. NFU - National Farmers Union 80. British Waterways 81. IPSS - Institute of Professional Soil Scientists 82. Cumbria County Council 83. Warrington Borough Council 84. Devon County Council 85. Composting Association 86. Lancashire Country Council 87. Hertfordshire County Council 88. Cotswold District Council 89. ADAS 90. Somerset County Council 91. Royal Town Planning Institute 92. RCEP - Royal Commission on Environmental Pollution 93. CPRE (Council for the Protection of Rural England) - Sheffield Branch 94. Econexus Ltd 95. Mr Eric Grey 96. DETR - Marine, Land &Liability Branch 97. Scarborough Borough Council 98. University of Reading 99. Reading Agricultural Consultants 100. Edmunsbury District Council 101. Soil Association 102. Association of Sites of Natural Beauty 103. Wildlife Trust - Nottinghamshire Branch 104. FMA - Fertiliser Manufactures Association 105. Thames Water 106. Council for British Archaeology 107. Lincoln City Council 108. Environment Agency 109. Soil Science Direct 110. BBSRC - Biotechnology and Biological Sciences Research Council

 

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Updated 15 January 2002

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