Cynulliad Cenedlaethol Cymru

Good morning, everyone, and welcome to the Economy, Trade and Rural Affairs Committee. We're continuing our inquiry into soils and the importance of soils in the Welsh rural economy. I welcome our witnesses today. I'll just call for apologies, first of all. We've received apologies from Luke and from Hannah, who will be joining us later. In Luke's place, we have Siân, representing the Plaid Cymru group here. Welcome, Siân. And I call for declarations of interest.

Thank you, Chair. I declare an interest as an honorary member of the British Veterinary Association.

I declare an interest as a farmer, and, obviously, owning land, which has soil on it as well then.

Welcome, witnesses. Thank you very much for coming along today and presenting your evidence, especially the written evidence, which has helped inform the questions that we'll put to you today. I'd formally ask you to introduce yourselves, starting with Ellen first, and the organisation you're representing, and then we'll go into questions. Feel free to answer them as you feel able to. Ellen.

Thanks. Ellen Fay. I am co-executive director at the Sustainable Soils Alliance. I also sit on the European Union soil mission think tank on the EU footprint on global soils.

Bore da. Andrew Tuddenham, head of policy Cymru with Soil Association Cymru.

I'm Rhys Evans. I'm the Wales manager for the Nature Friendly Farming Network, and I also farm myself.

Thank you all very much. I'll ask you a general question to start with, if possible, please. The Welsh Government have recently released a statement on their soils policy. What is your view of that statement that they've made, and did you have the chance to input into it? Ellen.

Thanks. Yes, we did input at the level that we participated in workshops that helped to input into it. I think it's excellent, it's very clear. I think Wales is exemplary in the way that soil policy and elements of soil policy are laid out very, very clearly, and you can see routes between the higher level policy and the more applied policy. I think it's really nice to see it side by side with the data that's come out of the environment and rural affairs monitoring and modelling programme, because you have these clear ideas around protecting, enhancing and maintaining the specific elements of soil health. I think there's a lot of work to be done around soil data and soil data sharing at different levels. So, it’s amazing to see that you've got this national survey, which is exemplary across the UK, and you've got change data, which other nations don't have, which is incredibly useful to direct more granular policy.

I think in terms of the specific indicators, it's going to be really important to think about the social science around how you take hearts and minds with us on the journey to really deliver on some of the outcomes from the ERAMMP survey as well. So, yes, in the round, I think it's very interesting, it’s very nicely set out, it's really clear and it's really, really helpful to be able to see routes between the different elements of policy when it comes to soil, because quite often soil isn't clearly set out in terms of policy. So, yes, that's my initial overview.

Thank you, Ellen. Andrew.

Thank you. The Soil Association, as far as I understand, didn't input into the work, although I was personally involved in a previous job with National Trust Cymru, so we responded at that point. I think, just to follow Ellen's points, it's a very welcome development. It's a step towards having something that's really clear around what the vision is for soils, and I think it helpfully conveys how soils deliver services for humans and for nature and climate as well. So, I think the vision is appropriate.

The scope is interesting. Yes, it has focused on agriculture, because agriculture is the dominant land use by area. It would be helpful to look at where forestry sits within all of this, because there are particular risks around soils with forestry practices and in terms of land use change to forestry. But otherwise, I think it's a very welcome development. It rightfully points out some of the evidence gaps in terms of nutrient loading and trends in soil biodiversity, and the objectives are perfectly appropriate in terms of needing to ensure that there's more data on soils and that that information is shared and then acted upon to protect and manage soils.

I think the fact that Wales has got further ahead relative to other UK nations in terms of understanding soils is commendable, but it also reflects that there's a very uneven effort going on across the UK, and that reflects how there hasn't really been the legislation driving this investment in looking at soils and trying to understand their condition. So, it is welcome to be ahead. I think it's an important first step.

Just before I ask you to come in, Rhys, could I just ask you to enlarge on that legislation point that you made there? You said there's not the legislation to drive it, there's not then. As a simple layperson, what are you talking about?

Well, relative to other environmental objectives, there's no target for soil health. I think historically the argument has been that soil health is complicated, we don't really understand enough about soil health, therefore, it's difficult to have a target. But without a target or a legislative requirement to deliver that, there hasn't really been the emphasis or the investment in the science needed to inform or understand better soil health. So, it's sort of self-perpetuating, really, and that's how soil—

So, it's the absence of a target, really—where to aim to seek those improvements. The statement itself is bold enough, but it's not having the target to be at the end of the job.

Yes, I think the statement is a welcome step towards now being able to put something in place that then drives and ensures, long term, that there is this continued investment in understanding soils and acting on that condition.

Okay. Thank you. Rhys.

From the Nature Friendly Farming Network's point of view, we welcome the statement. It's good to see soil getting the attention that it deserves and that the Welsh Government recognises, I guess, the multiple benefits of soils, not just for food and fibre production, but all the other ecosystem services that they provide, like biodiversity, carbon sequestration, water flow and quality et cetera.

I think the three objectives are commendable. Increasing information on Welsh soils is really important. It really goes with the saying of, 'You can't manage what you don't measure', so that's really important. Encouraging the sharing of information on soils I think can lead to, foster, more collaboration. And I think it goes without saying that the third objective, of protecting, maintaining and enhancing soils, their functions and services, that's really important, as Ellen said, with the latest ERAMMP report highlighting recent negative trends in soil health. The NFFN has been advocating for these in our written response, and for some time, so we really welcome the direction of travel.

But I will agree with Andrew as well, in that, while the words on paper are nice, there's currently no legal duty or obligation or target to deliver on these three objectives. But I think the recognition of the importance of soil and having this vision will, hopefully, lead to more policy support and legislative mechanisms that facilitate improved soil husbandry.

Thank you all very much. Jenny.

Can I just come back to Andrew first? You say we're ahead, but, in Northern Ireland, CAFRE, the College of Agriculture, Food and Rural Enterprise, is testing all soil down to 1m. So, they appear to be further ahead than us, because we're just measuring the surface. So, could you just substantiate why you're saying we're ahead?

Well, I'm saying that as a reflection of how much insight and work has been done to build the evidence base across all aspects of soil, and the 'Welsh Soil Evidence Review' is pretty comprehensive. I think the data run that Welsh Government can draw upon is quite helpful, in terms of 10 years. But, yes, I think the Northern Ireland work is showing the next stage, which is how to do that at field level and at farm level, and really build a big resource. We can talk about the sustainable farming scheme.

I'm about to come on to that. I'll just stick with you, and then I'll come on to you, Ellen. So, how well do you think the current layout of the sustainable farming scheme tackles this crucial issue of soil health?

So, what we're seeing is a scheme that intends to be a whole-farm scheme, looking at all aspects of production, and, essentially, farming with nature and using the benefit of nature to support production. I think it's welcome to have soil testing within that universal layer as one of the requirements. It's also welcome, for instance, that there's proposed support for things like herbal leys within the universal layer as part of the habitat rule, granted that how those herbal leys are delivered is going to be crucial to ensure that they not just deliver for soil health, but also for things like pollinators as well. And then continuing professional development as well, improving knowledge and skills. All of these things can hang together very well.

I think the key, though, is how do you turn those plans into action. And that's where the support and the incentive, and the guidance, in particular, to act on soil health plans and pull from some of the other layers that, hopefully, will have support for sustainable farming practices, which can encourage soil health—. So, it's the optional and collaborative layer area that will really reap the benefits of farmers understanding more about their soils. Having said that, we have to be very aware of what soil test results can also show. They can show the deficiencies in nutrients in soils, they can show deficiencies in pH. The ERAMMP data has suggested that there's quite an acidification going on, particularly on improved land that has had lots of artificial fertiliser inputs historically. So, that will set up a demand for, potentially, correcting nutrient levels, adding lime to adjust pH, other things. So, whether that results in demand for support is yet to be seen. But I think the first step, as Rhys has said, is that you can't manage what you're not measuring. So, just the act of undertaking soil testing at scale is a good first step, but it's not the only step that's needed.

Okay. So, Ellen, we could have marvellous things going on in the optional and collaborative tiers, and then, over there, people continuing to chuck all sorts of fertilisers onto the land, which will just exhaust it further. So, what do you think the action is that is required?

I guess what we haven't seen in any of the UK nations—well, certainly in my experience and memory—is something of a joined-up soil policy framework. It's quite hard to find bits of soil legislation across the different areas. We sometimes look at this from the perspective of what are the pillars of robust joined-up soil policy that could really support each other to deliver soil health in the round, as you say. And those we see, essentially, as being this question of monitoring, but also of assessment. So, there are different levels to monitoring soils. You've got your national assessments, as you said. In Wales, you've got your ERRAMP survey. In Northern Ireland they're doing something different. In fact, we did a piece of work through the Land Use for Net Zero hub, which looked at all of the monitoring schemes across the UK in detail, to see who's doing what, and there's very little consistency, as you say. In Northern Ireland, they're doing something very different—maybe they're doing some things much better, maybe they're doing some things not quite as well as you're doing in Wales—and do you have that long-term change data is really important.

But then there's the on-farm question, which is slightly different. So, assessing soils on a farm is a different process to assessing soils at scale across the country, and there are two aspects of that. One is to look at change and trends, and the other is to look at the soil in the here and now and to figure out, from your investigation, whether the soil is healthy or not. And there's a bit of a problem at that level, because soils, as we know, are very varied. We have something like 700-plus soil types in England and Wales, and levels of organic matter, for example, in one soil type might be good, whereas they might be poor in another. So, we need some structure around that question of monitoring.

But you already have these tools. I mean, one of the awards last year in the farming awards went to a company near Ipswich, which enables you to measure the land you're standing on and get a result in five minutes.

That's a good point, and it went to our company.

Oh, did it? Okay.

Well, I think it went to one system. We've looked in detail at 34 of some of the very well-used systems to measure soil, and it's very hard to find similarities between them in terms of the protocols and how they're measuring and how the interpretation is happening. So, if I'm a farmer and I'm trying to choose how to invest my time and my money in soil testing, I'm already a bit confused. And then, at the data level, do we know that the data coming out of these different systems is really going to add up to one picture? I mean, even at the national level, we've had national surveys that have used different data sets and come back with a different interpretation of the trends. So, there's work to be done at that sort of standardisation, harmonisation level when it comes to understanding the soil, and that's the pillar, if you like, of soil policy and thinking about soils, which is to do with assessment and monitoring.

Then, alongside that, I think the three complementary pillars are incentivisation, and whether that's Government money and private money, and how these things work together in order to get delivery, helping farmers—who I think manage 90 per cent of Welsh soils or so; so, basically, most of the soils—to deliver soil health. So, that's: how do we get that paid for and how do we have that data, also, to be feeding into the national picture to understand which direction things are going in? And then, complementary to that, there's the question of protections and regulations. So, what are the regulations about no more degradation, incentivisation, long-term improvement?

And around all of this, I think we need to look at the question of advice and guidance and the impartiality of advice and guidance. A horrible proportion—I'm not going to say a number because I don't know it, but I've seen lots of different numbers that are quite high—of advisers to farmers have some kind of vested interest, actually, in degradation because they're selling a product to make it better. So, where is that independent advisory industry that is also building on this clarity around what does soil health look like and how do we measure it, and how do all these things, these four things, work together?

So, before I move on to Rhys, I just wonder—. Are you, then, underwhelmed by the Welsh Government's monitoring and modelling programme, done by ERAMMP?

I'm overwhelmed by it. I think it's wonderful, because you have one. Other nations do not have change data; we do not know for sure in which direction things are going. We have what we see, but we don't have clear change data going back, and you need data going back in time because you need to model over that climate change and all sorts of other things—land use change. And so I applaud Wales. Where you are is in—

Okay. So—

I think only half of European Union nations have the level of data that you have, and that's wonderful. That's the national picture. The on-farm picture is a slightly different story and it would be wonderful to be able to get some of that data, anyway, here and now, so that you can know what's going on now, not in five years' time, and also have a bit of an interchange between on-farm data coming into the national picture.

Okay. Thank you. Rhys.

Just before you ask Rhys, Jenny, can I just ask a supplementary—

Yes.

—on the point of advice? Because it's an important point. I've got enough grey hair on my head to remember the days of the Agricultural Development Advisory Service, when it was a Government executive or body, and that advice was seen—they're now obviously a commercial company, but that advice was seen—as the gold standard in the day. Now, obviously, farmers tend to look either to Farming Connect or the companies themselves, if you like. Do you believe Farming Connect has the capacity to replace the impartial advice that ADAS used to deliver to farmers when it comes to soil health, or does this advice need to be completely remodelled under the sustainable farming scheme that we're looking forward to being introduced next year?

I do not know the answer to that, but I think it's a really important question and one that it would be nice to have an answer to. You know, what is the level of advice that is needed to make that investment from the sustainable farming payments really deliver? And I think the economics of these things are sketchy and I think a really nice underpinning piece of work would be to know what is the cost of soil degradation to Wales. We have that report—it was from 2015—but that's very, very old. I'm sure it does not use the types of climate information that we have now in terms of degradation, risk. Yes. And I think that could be a helpful way of focusing minds and knowing what investment is needed and to find out what the advice industry really looks like in terms of impartiality, and do we have that golden thread of consistency in the advice industry to really know how to benchmark soil health.

Okay. Thank you very much. Sorry to cut across you, Jenny.

Yes. That's all right; fine. You're the Chair.

Rhys, you're a farmer. Just to go back to this point about—. We could have a wonderful optional and collaborative set of policies, but if the vast majority of people are continuing to chuck a lot of phosphorus on the land just to try and get the last ounce out of it, how are we going to have a more whole-system approach to it? Because we've only got one soil; it's not something you can reproduce.

Yes, so, looking at the SFS universal layer, universal action 3, as is being proposed, is a requirement for every farmer to undertake a soil health plan. So, that includes looking at potassium, phosphorus, magnesium pH and soil organic matter, and, in theory, having to test 20 per cent of your land that has received inputs. So, in theory, you're testing your whole farm in a five-year cycle. I think that's a really good place to start. As I said, the more we know about the condition of our soils, the better we can manage them.

I think this specific action can support farmers to make more informed decisions on fertiliser application, so ensuring that the crops receive the nutrients they need without overfertilizing, which we know can be detrimental to the environment. It can help eliminate bad practice, if you like, but, as a standalone action, as Andrew said, I don't think this will necessarily lead to big gains in increased soil health. I think the testing and planning is great, it's a great place to start, but the suitable advice and support to act on the recommendations of the results is really important.

Just looking at some of the other universal actions, universal action 1 is around benchmarking. Farmers have to report on key performance indicators from an industry-agreed list. It would be great to include indicators linked to soil health for that universal action. That can help us benchmark as well and gain a better understanding of the soil health condition in Wales.

On universal action 2, around continuous personal development, it would be great to see soil health training or a module of sorts being offered as part of this universal action. If we're serious about increasing the knowledge of soil health and better management, then you could argue that there is scope to put a soil health module as a mandatory course for universal action 2.

Looking at the collaborative and optional layers, I think this is where we've got the most potential. From the NFFN's point of view, it should be looking at enhancing or facilitating regenerative farming techniques and nature-based solutions to increasing soil health, looking specifically at increasing pasture species diversity, planting multispecies cover crops, incorporating agroforestry, be it silvopasture, silvoarable or hedgerows, and facilitating the application of organic fertilisers and composting, as opposed to more chemical-based fertilisers.

I think it's important to make a point around the role of grazing management as well. Something around 40 per cent of Welsh soils are considered to be potentially vulnerable to compaction and I think it's one of the biggest risks to soil health. Grazing can be both a cause and a solution to rectify compaction. Facilitating strategic management of grazing, so that we've got graze and rest periods—you might know it as rotational or mob grazing—will be a very positive thing in the optional layer, because that essentially allows plant roots to grow deeper and denser, and roots are fundamental to soil health.

All these interventions can increase soil health through soil organic matter, nutrient recycling, biodiversity, water infiltration, increasing that soil structure. So there are environmental benefits, but there's also the production benefits as well, and the efficiency benefits, reducing that reliance on external inputs, and helping to increase overall farm business resilience.

We've talked about testing. An element of more ambitious soil testing would be welcomed in that optional layer as well, taking account of the biological and physical condition of the soil, not just looking at the chemical analysis. But over time, the SFS will be evolving and, as some practices become, hopefully, more mainstream, some elements that might sit now in the optional elements might move over to the mandatory element, particularly if we're not seeing the improvements that we want to see in soil health.

Just looking at the collaborative scheme, I think there's potential here to really think about exciting and ambitious soil health monitoring schemes, and not just looking at this over a period of two or three years, but five, 10 years, groups of farmers working together, delivering interventions aimed at increasing soil health and doing robust monitoring to see what effect that management has on soil health.

Fundamentally, I think there’s a question here around financing the SFS, and how much money is allocated to each scheme layer. Because if there’s too much money allocated towards that universal layer, then there’s limited funding for more ambitious optional and collaborative action, because those are the elements of the SFS that will really drive the change and provide the opportunity for farmers to act on the recommendations and advice of the testing in the first place.

Without that, I think the SFS will ultimately fail in increasing soil health, which, as we know from the latest ERAMMP report, was the case for Glastir anyway. So, that financial question is a really important one.

Thank you for your comprehensive answer. I'll hand over to colleagues for the following up and all that. 

Thank you. Siân. 

I'll invite you, Ellen, to respond. 

Thanks for your question. I’m not very clear about the links between planning policy and the ALC directly. I think there are innovations that could be very helpful with the way that land is classified, especially looking at what we know now about the effects of climate change, up to now, and, then, how we model that into the future.

It’s interesting that in England they’re looking at a land use strategy, which, of course, is very much tied in to the question of data, and the ALC, I’m sure, will underpin that to a great extent. But there are different data layers that could go over that to tell a story about how you protect land and where. I think the national soil inventory is an important piece of that, which I understand the ALC is built upon, to a certain extent. But I think when you look at climate change and what we know now about the need to build more biodiversity systems that are self-reinforcing, and how you plan that into land use planning as well, there’s probably quite a lot of innovation that could take place in terms of how we understand what needs to be protected.

I think soil has a really interesting role in that, if you look at soil as a habitat in its own right. We know that soils are very diverse, and if you really understand soil type—. I’m not a soil scientist, but I know many soil scientists, and they can talk in terms of how you really strategically use that knowledge of soil type across the landscape, overlaid with your farming types, and other data like that, to really understand how you can be more strategic about protections within your land use planning. So, I think there probably is innovation needed in that space to get proper protections in.

So, are you saying that ALC 1, 2 and 3a are not necessarily protecting soil, and that there is maybe not enough emphasis on that particular aspect?

I haven’t got the experience in Wales to say that. I can talk about England, where you see best and most versatile land that is incredibly productive but maybe is emitting carbon, because it includes peatlands, for example. I think we need a new look at that in terms of what we want from our land, because the opportunity with soil is always that there's food production, but there's also this whole plethora of environmental benefits—flood defences, carbon storage, biodiversity, beauty.

Some of the most versatile land for growing food may also need protection for other reasons. The question is, then, how do you get the same productivity, because we can't simply offshore that. I think when we look at that whole question in the round, we need to really understand what the needs are and maybe be more strategic about what happens where.

The example of Europe, I think, is interesting. They have a new green deal, where all of this carbon saving is modelled. There's new research that looks at that in terms of the offshoring of those greenhouse gas savings, and it sees globally a big increase. So, we must make sure that that doesn't happen. We need to be thinking in the round, but really in the round, about all of the things that go into the best and most versatile land—what we need from it, but also how we strategise around it. That's a fairly not-granular answer, but broad thoughts. 

The ERAMMP national trends report does suggest that best and most versatile land is being used for urban expansion. Urban land cover now has gone from 5 to 6 per cent of the total Wales area over the 2010-21 period. I think the majority of that, if I'm remembering the report right, is on improved grassland. As Ellen says, there is huge demand for that land for all sorts of purposes. A lot of our best and most versatile land is in low-lying areas, which is where you would expect them to be in demand for urban expansion, or potentially for other purposes: horticulture, to supply where people live; tree planting for air quality mitigation. There are all of these competing demands on that best and most versatile land, but fundamentally it does raise the question of what is going on in the planning system that has facilitated that or enabled that, because there has been—I'm not sure if this is the technical term—a presumption against the development of best and most versatile land in the planning system.

You are correct. That is the technical term, a presumption against. 

But yet it does—

But yet it has happened, yes. I think also, if we just pull back a little and just consider how to get the best use of that best and most versatile land, this shouldn't just be a binary consideration between development versus agriculture; I think the nuance comes in what form of agriculture is best used on that land. It's interesting that, I think, only about a third of the arable production—. It's not a large area, but a third of it is on best and most versatile land grades. I think a lot of it is on agricultural 3b. So, why is that? There are all of these different competing uses. A land-use strategy or a framework could help to resolve some of those and target some of the policy so that there are incentives for particular types of farming in particular areas, or there's a regulatory focus on particular areas, according to that agricultural land classification. 

So, it's out of date or it needs reforming, the land-use policy.

It needs augmenting, I think. Things could be refined to better target our policy and regulation around agriculture. That was also one of the—. Well, not the agricultural land classification point, but the need for targeting was a recommendation in the ERAMMP report. Maybe we're going to talk about Glastir, but that was seen as one of the lessons from Glastir. 

Before Rhys comes in, I'm surprised that neither one of you has focused on renewables and how a lot of land is being taken out for solar development in particular. Obviously, that has a role in soils, and neither one of you thought that that was a danger to the soil structure or the degradation of soils.

I haven't focused on that. I don't think it's a very significant land take, and there are ways of delivering it that involve agricultural production, grazing under the panels, that sort of thing. I must admit, I'm not in-depth familiar enough with the particular risks and I can imagine that there could be risks with installation and decommissioning, but that's as far as I could go with that answer.

I think there has been in England some work done around the national grid, because of all these new pylon lines, for example, and what happens with the soil in those routes. We do have soil maps, and we need to look to those to understand which soils are fragile, which soils are good for storing water, which soils you really don't want to be building on, and, I guess, the same around solar and that sort of thing.

I think what's often missing is this first step to say, 'What are these soils where I'm going to do this?' And we just don't have that, sort of culturally, in the different areas of policy making, and I think maybe part of that is that that soil resource, our national soil maps at that granular level, are not freely available. They are behind a paywall, they are subject to IP; it's quite difficult to use that incredibly useful and important resource in an agile way to get people thinking along the same lines.

Rhys?

Rhys.

I'll answer in Welsh, if that's okay, if the translation works online.

Fifteen per cent—

Thank you, Siân. Hefin. Hefin David, who's beaming in from Caerphilly to us.

Thank you, Nelson. [Laughter.] Can I ask, regarding the skills that farmers need to test their soils and adapt management practices, is it quite a skilled activity and are they appropriately skilled to do that? 

Ellen, do you want to reply first to that question, and we'll go through the sequence? 

Yes, thanks. I think this happens or can happen at different levels. There's a capacity issue that nobody's talking about as well, which is that if every farmer in the country went out and tested for organic matter, we would never have the lab capacity to give them the information back. So, I guess it's in terms of the complexity of it. There are many different approaches to doing it. I think what would be very helpful is to bring them together according to a more universal framework and in a more simplified way, and to be really clear about the protocols.

So, for example, I just imagine if I were going out on a farm and I was thinking, 'Okay, right, I'm going to test for organic matter, I think I'll go to 10 cm', and then, next year, one of my customers, Sainsbury's, says, 'I want information to 15 cm', and I think, 'Why didn't I think of that?' Well, why would you? There are many different ways that farmers are suggested to do it.

So, it would be very helpful to have some simplified and clear protocols around how to do what for which purposes. It would be very helpful also to have some real clarity around visual assessment so that it could be a lot simpler. In order to make that really clear and robust, visual guidance is needed, and that's the sort of thing that can happen at the policy level, or policy can help industry develop it, or the likes of ADAS can develop it for everybody. But it needs to be clear, it needs to be robust and it needs to be built on the understanding that soils are very heterogeneous, they're very varied. So, how do you simplify that down into something that's doable, that can be done here and now with a spade, and give some clear information in visual guidance, which is actually missing at the moment?

That has been produced, for example, within England. I think the Department for Environment, Food and Rural Affairs has done some. We have visual assessment of soil structure, which is to 15 cm. We don't have anything for the subsoil, which is really sad and very important, because if soils are invisible generally, the subsoil is very invisible, and subsoil is very often a different soil type to the topsoil. So, we need to clarify these things visually in a way that's robust and doable.

But, yes, there are mechanisms, and there are many different systems that farmers can get to grips with. There's the Agriculture and Horticulture Development Board soil health scorecard, there's Soil Association Exchange, there's the Sustainable Food Trust's global farm metric. There are all sorts of ways to do it that are doable. What's missing is a centre of gravity for all of this, which would also really help with creating some consistent data that is coming off farms and could be very useful.

What do you mean by 'centre of gravity'? 

Centre of gravity—. I guess, for example, with the water framework directive, we have really clear thresholds. These things have been really well thought through. We know what drinking water levels should be, we know what bathing water levels should be; we don’t really have that for soil. We haven’t really done that—. I mean, it’s been done all over the place, but it hasn’t been brought together, and that’s where, I think, Government used to play a role, when ADAS, for example, was within Government. That was the centre of gravity for soil advice, soil guidance and producing things that everybody could use in the same way, so that you then get consistency and then you can start to also get consistency in data and telling a story, coming off farms, as well as Government doing a service like the ERAMMP. So, I think it happens at different levels and there’s a lot happening. It really needs bringing together.

Andrew.

Well, if I could answer that question through the lens of the sustainable farming scheme, because that’s what’s coming most immediately at us, it’s a question of the capacity question and the skill question. There are two parts—there’s gathering the data, doing the sampling, and then acting on it or interpreting it. And so, just looking at what’s proposed as a chemical test, that would involve going into a field or a group of fields, potentially, that might be zoned together as one sample area and collecting multiple little bits of soil using a spade or a trowel, building them into a sample that the lab can work with, and then sending it off. So, that sounds simple. There is a time cost to that—that should be something that is reflected in the universal baseline payment. There is definitely a protocol issue around how this is conducted to make sure that the stone fragments, the root fragments are taken out, the right depth is used, areas of the field that are clearly unusual aren’t sampled, but still the sampling is randomised. So, there’s definitely a need around how this testing is done to ensure that the data that comes back is as good as possible.

I’ve yet to see just exactly what the rates of soil testing amongst farmers in Wales are. Some sectors are clearly testing their soils; for others, I think the insight seems to be that, say, in less favoured areas, sheep and beef producers aren’t so often testing their soils, whereas arable and dairy are for their supply chain reasons. But we shouldn’t assume that everyone knows how to do it and how to do it to a standard that, hopefully, the SFS can set out. So, I think that’s an ask of ensuring that that is properly provided in the first years of the scheme to get these new practices in train.

The second aspect is interpreting the results, because what comes back from the lab in terms of a chemical analysis will have some recommendations on it, based around productivity and addressing nutrient deficiencies. Some of those solutions could be by applying the deficient nutrients, but it would be good to be able to find opportunities to think about what the whole system is that’s causing this nutrient imbalance and are there other changes to husbandry or, actually, the whole system that could be brought into play as well. So, thinking holistically is an important opportunity—again, that comes back to the SFS.

And, Chair, you asked about Farming Connect earlier and I just wonder, potentially, there could be a big draw on Farming Connect’s time to provide advice for those who aren’t familiar with these soil testing requirements. So, they need to be ready with that. I think the model has been one of responding to demand, whereas now we may need to be one of proactively providing guidance for the universal layer to actually succeed. So, there are questions around that. Welsh Government have put in place a dynamic procurement framework for rural advice, which may allow other actors to come in and deliver the service alongside Farming Connect. But all of that needs to sort of hang together with a consistent approach to what the advice is and how the practices of the SFS are going to be delivered. So, there's a sort of need for a sort of curriculum that everyone works to.

Thank you. Rhys.

Thank you. Andrew's actually mentioned quite a few of the points that I wanted to raise, but I'll just expand a bit. Just around the standard of the testing, I guess, the standard testing packages commonly used across Wales will measure the plant available, or the extractable, soluble portion of nutrients in the soil, which is actually quite a small fraction of the total amount present in the soil when you consider the insoluble pool, if you like.

So, the tests themselves, I guess, provide an incomplete picture of soil health. I think there's a growing recognition that focusing solely on that chemical analysis is insufficient and that we should be incorporating both physical and biological assessments as well. Some of these can be quite simple or relatively simple tests that a farmer can do themselves on the farm. So, there's the VESS assessment, the visual evaluation of soil structure—it provides a rapid indication of the structural integrity of the soil, if you like; it can identify issues like compaction or poor aggregation. Very simple stuff like water infiltration tests—so, that measures how quickly the water is infiltrated into the soil; again, that indicates compaction and the water-holding capacity of the soil.

There's stuff like bulk density tests as well, which actually was one of the assessments that we had on our latest soil tests on the farm. So, that, again, looks at compaction and aeration and the physical structure of the soil. Because compaction, or the physical structure of the soil, might be the reason why you're getting low scores, potentially, on your soil tests. So, instead of treating the symptoms with artificial input, you could target the cause of the issue, which might be compaction, by changing your management. That might mean more diverse species, better grazing management, or mechanical intervention, aerating the soil, et cetera.

So, around the advice then that accompanies the test, more often than not, the advice is centred around, 'The solution is in a bag', essentially: purchase some synthetic inputs, and apply it to the land. I think this feeds the plant, it will grow more grass, but I don't think that necessarily feeds the soil. Because if the plant then gets its nutrients from an external source, this disrupts that symbiotic relationship that's based on the exchange of nutrients between the plant roots and the soil. That's why we often see—. Well, there's certainly anecdotal evidence from our members who are transitioning to more regenerative farming systems of the land going into what they call 'cold-turkey mode' if the land suddenly stops receiving inputs. Because it takes time, I guess, for those natural processes in the soil to kick start, if you like.

I think that's where policy support is really important, that there's long-term policy support to allow farmers the confidence and the security to implement these nature-based solutions, regenerative-farming techniques to increase soil health, as opposed to maybe improving grassland yield, which I think are two different things, and it's important to distinguish them.

Thank you, Rhys. Hefin.

That's really helpful. I haven't got anything else I need to ask.

Thank you, Hefin. Sam, to take us to the conclusion.

Thank you very much, Chair. Good morning, panel, and to Rhys as well online. I'm going to start around national minimum standards and targets, and leading on from answers that were given to the Chair at the beginning, there are no statutory targets to protect soils. In one word, should there be? Andrew.

Yes.

Ellen.

Yes.

Rhys.

Yes.

There we are. We'll go back to Andrew. What would that look like?

Something centred on soil health. There are metrics and indicators that give a reasonable feel for soil health in terms of earthworm counts, bulk density, and soil organic matter in particular. Clearly, a target needs to work for the huge range of soil types that there are and the different conditions, but the ERAMMP report points the way, suggesting a focus on a target that is framed around the best examples of soil health, and making sure that that increases, so, as a proportion of the total soil stock, there is more that's in good health.

I suppose that there are some opportunities right away. Under the Agriculture (Wales) Act 2023, there are the sustainable land management indicators and targets, which need to be set this year; there's a requirement to do that, to ensure that there's a way of measuring progress with the objectives for sustainable land management. Potentially, there's the environmental governance Bill—yet to be laid, but coming. That needs to address soil health, I suspect. So, there are some immediate tools that could be brought to bear. 

Okay. Ellen.

Thanks. I think—. Well, 'yes' is the answer. What it is, there are options. You could look to scientists who have done your ERAMMP and what is a sensible target based on the data that you have. There are examples in Europe. For example, I think it might be Switzerland that has a target of 'no net soil loss' as a national target. I think what's really important is to understand whether a target is about soil health, about an aspect of soil health, or about management. If you look to the example of England, we had, in England—. Originally, when we as an organisation came to look at this, we did some work to quantify the money spent on soil health assessment in England, and, of the money spent on monitoring air, water and soil, soil was receiving just 0.4 per cent.

Now, Wales, you're in a different position. At that time, when the Environment Act 2021 came through for England, it was impossible to put a soil health target in it, because we had no baseline, we had no change data, so that would have been meaningless. What we did have in the 25-year plan for the environment was a goal—you need to get clever about your semantics here—which was for all of England's soils to be sustainably managed by 2030. Now, when that came through into sort of statute with the environmental improvement plan, that had been reduced down to 60 per cent of agricultural soils, and that's 70 per cent of all the soils. So, 60 per cent of 70 per cent of soils to be sustainably managed by 2030.

Now, we have a problem with the definition of what 'sustainable management' is—we still don't know—and the mechanism for delivery, the sustainable farming incentive, which has not survived the churn of Ministers or Governments. So, when setting a target, it's really important to think about what does it actually mean in practicality, and how do you, when you're thinking about actions around soil health, build in thinking about outcomes. And then also, in terms of the target, are we talking about the national soils, or are we talking about on-farm soils, and how can these things work together and how can regulations, advice and guidance and everything tie this all in together? I think national benchmarks are really, really important, and there are different national benchmarks developed by different organisations. Can we harmonise those, so that we really know that soil health benchmarks for different soil types, different farming types and different climate zones are really meaningful and robust? 

Okay. I'm going to come on national minimum standards in the next line of questioning, but I'll go to you now, Rhys.

Yes, I think a lot of what I wanted to say has been covered, but just in terms of—. You could implement a nationwide, national target that a certain percentage of agricultural soil is in good condition, and have a robust definition of what that 'good condition' is. But then you could have indicators to inform that, looking maybe at soil organic matter, the percentage of Welsh agricultural soils that are at risk of erosion, compaction. If we can harvest data around soil biodiversity, it would be good to have some sub-targets on that. And nutrient management as well, maybe—so how much, nutrient surpluses, and improving nutrient use efficiency. I think those are areas that you could potentially use to inform soil health targets in Wales. 

Fab. Thank you, Rhys. And the sustainable farming scheme's been mentioned at length in this session, but there will be farmers out there who decide not to sign up to the SFS. So, it's coming back to the point around national minimum standards. Is that then the tool to ensure soil health is part of those non-SFS farmers, in ensuring no degradation around soil in that sense? Ellen.

Yes, alongside regulations that are clear and fair and, critically, well communicated. Quite often, data has shown that, when regulations are really clear around soil, then there hasn't been the investment in communicating them properly in England. There's very, very low awareness, for example, of the farming rules for water. And obviously, this need to be backed up by investment in inspections and that holistic advice, et cetera, as well. But yes, a soil standard would also be very empowering at that level of getting buy-in and traction behind the influence of the supply chain, which is often anecdotally seen to have more negative impacts on soil health by pushing farmers to take risks with the land in order to fulfil their contracts, rather than having a clear standard that everybody can get behind that supermarkets et cetera have to report on as well.

But is there a flip to that then, Ellen, in that consumers are becoming more conscientious? Some consumers are willing to pay a premium for products that are more sustainable, traceable et cetera. So, is there some private investment that's available to farmers through specific contracts that they can have in delivering better soil health? Or is that too complex in terms of this? Because we look at it with animal rearing standards for red tractor, or if you're an M&S contractor, et cetera, there are certain standards you need to have. Can that be done on soil health as well? 

Yes, I think 95 per cent or something of our food comes from the soil. Hopefully, we get to a point where we're not paying a premium for food that is produced in a way that looks after the soil, because that's a public good in itself—idealistically, at least. And we're in a time in which food bank use is going up; we need to look at how we can invest in food at a level that everybody can afford.

I think the role of—. You're asking about private finance; yes, I think the role of the private market is really, really important, and there's a role for Government within that also to make sure that, for example, Government pays for things that the private market won't. So, if you look at soil carbon, for example, the market can't pay for preservation of soil carbon because that doesn't pass the additionality test. So, it's really important that public and private money can work together really well, and that the Government is there to help oversee how that market develops.

The soil carbon marketplace is a whole conversation in itself. I think what's also really important is that, within that conversation, we're looking at soil health in the round and there is, I think, a growing interest in private finance at the landscape scale. Soil health could be playing a really big role in that, and that would be another way to get in private finance to soil health. If you look at figures coming out of Europe, they're looking at that very many tens of billions of private money is going to be needed to bolster the public money if they're going to achieve their soil health goals. So, the private finance is a really big part of it. It has to be robust, it has to be evidence based, we need to have the scientists behind us, and it has to be really, really clear.

Okay, thank you. Leading on from that, Andrew, the Farmers Union of Wales in their paper to us described the soil carbon credit market as the 'wild west'. In building on what Ellen said, would you agree with that, and any additional information? 

Yes, I do recognise that, and I think there's a broader point around the dangers. Apart from the unregulated aspects of the voluntary carbon market and the potential for that to just perpetuate a status quo of offsetting, there is this need also to think broader than carbon and look at nature alongside climate. I think, actually, just to build on what's been discussed so far, there's a real awareness in the supply chain and within the financial institutions of how their business model is so exposed to the risks of climate change and nature loss. When they're interacting with agriculture, farms on the front line of climate change, they are investing in something that, if it's not resilient, is going to be losing them money, and at some point that investment is not viable. So, they are actually really looking at how to de-risk, and that means supporting the sorts of farming practices and systems that build soil health and build that resilience.

So, there is a lot of money that's being potentially looked at to drive that. We can see that already in some cases. We mentioned the Soil Association exchange; there are a lot of supply chain actors funding that to de-risk their supply chains. There are other actors out there also looking at how to get more sustainable production using soil health—First Milk's regenerative programme, for example. Some of that is being driven by the requirements on carbon emissions and the legal requirements around that, but I think my broader point is that there's this awareness that it's nature and climate that are going to make or break some of these supply chains.

Great. Thank you. 

Just in terms of national minimum standards, I think they should apply to every farm, regardless of whether you're in the SFS or not. I think it just creates that level playing field, really, and bearing in mind it's highly unlikely that every farm in Wales will enter the SFS; the funding isn't there to be able to do that. But the regulation, I guess, is only as effective as the resource that is provided to it, and I'm sure you've heard it all before that we do have concerns around the Welsh Government's and NRW's capacity to monitor and enforce regulation in Wales. So, for that regulation to be meaningful, it needs investment.

There's another question, I guess, around how the regulatory floor speaks to the sustainable farming scheme. For example, if the Senedd's rural affairs committee suggested that the good agricultural and environmental conditions 4 and 5, which are around minimum soil cover and limiting soil erosion, applied to national regulation, what would that mean for the SFS? Will the SFS then be able to pay farmers to implement cover crops on their farms, for example? Well, arguably, you could say 'no', because if that's required in law, then the principle of the SFS from the outset has been only paying for additionality. But where that additionality could come from, I guess, is paying for multispecies cover cropping. I guess the point I'm trying to make is that that relationship between regulation and the carrot and the stick needs to be a balanced one, and that we don't over-rely on the stick of regulation at the expense of the carrot of the Welsh Government's support schemes.

And just on carbon credits and private markets in general, I mentioned there's not enough money in the public purse to fund environmental restoration in Wales. The 'Scale of Need' report from last year highlighted we need £600 million every year over 10 years minimum to deliver on our environmental targets. That money just isn't there. So, it's a necessity, really, to tap into private markets. But I would agree that the term 'wild west' is an accurate one, so I think there's a role for Government to help get a degree of consistency and a bit of guarantee and security, maybe, for farmers to partake in private finance schemes.

I think this includes supermarkets as well. We're talking about a multibillion pound industry here that generates immense amounts of profits annually, and I think a lot of supermarkets are actually trying to support the suppliers to undertake more nature-based solutions and regenerative farming practices. That's a win-win for the farmer, for the supermarkets, and I think, ultimately, for the consumer and Government as well.

Thank you, Chair. 

Thank you. Thank you, all, for your evidence this morning. It's greatly informed the committee's evidence gathering on this, and the written evidence, as I said in my opening remarks, has been helpful as well. A record of today's proceedings will be sent to you for you to have a look over. If you have any concerns about the record being inaccurate, please contact the committee services, and the committee may, in its deliberations, choose to follow up with a written series of questions. I hope that you'd be able to answer them and provide more information, if required. But, thank you very much and hopefully we'll do the evidence you've given us justice in our final report. Thank you very much. We now move into private session. I should remember to say that.

We'll start our second panel for the day, on our investigation and inquiry into the state of the health of soils and soil structure in Wales and what actions the Welsh Government could be taking or should be taking to preserve the profitability and environmental benefits of soil, on agricultural land and urban land as well. I'd like to welcome the group of witnesses who have come in to present to us today. I'll ask you formally to introduce yourselves and the organisation you represent. I'd like to put on the record our sincere thanks for the written evidence that you've provided so far to inform the inquiry and inform the questions we'll ask. I'll start with Fraser at the left and work across the panel in asking you to introduce yourselves, and then we'll go straight into questions. Fraser.

Bore da, pawb. Fraser McAuley, senior policy adviser at the Country Land and Business Association Cymru. Pleasure to be here. Thanks.

Bore da. Teleri Fielden, Farmers Union of Wales. I'm a policy officer, but biodiversity and climate change is one of my lead subjects.

Bore da. I'm Abi Reader, the National Farmers Union Cymru deputy president.

Okay. Thank you, all. I'll start the questioning, if I may. The Welsh Government have just released a statement, or recently released a statement, on soil health and actions taken to enhance soil health. How familiar are you with that statement, are you happy with the content in it, and were you able to inform the development work that led up to that statement? Fraser, I'll ask you first, and then we'll proceed down the panel.

I think it's definitely positive to bring in all of the information into one platform on soils by the Welsh Government. I think it's positive they've got a clear vision about what they expect from soils in terms of resilience and being sustainably managed. I would say that how that translates to the farmer or the people operating the land is less clear. How much communication there is between the Welsh Government and that particular document and to farmers is slightly negligible.

I would also say—and others might have other views—that it comes at a very busy time in terms of policy development related to farming. The sustainable farming scheme, as it's continued, has got a lot of momentum, and that's taken up a huge amount of time over the past year, from all stakeholders, the Welsh Government included. So, I think, when it came out, there were quite a lot of other pressures on, which probably gave less opportunity for organisations such as us and, indeed, people on the ground to input into it. But in terms of having the headline aim, target, vision for soils, I think it is generally positive. The real importance is how that translates to people on the ground, managing farms and land in Wales. Thanks.

Okay. Thank you. Teleri.

I'd agree with Fraser there. I think we were a bit disappointed with the first iteration of it because it did come out in the middle of quite a busy period. I know we had three weeks as stakeholders to respond to it. So, obviously, in terms of our democratic structure, we didn't have the time to consult fully with members on it. I think it came out just before the Royal Welsh Show. So, the workshops were—. I think about 30 different farmers had noticed the expression of interest. So, as Fraser was saying, I think it could have had more opportunities for farmers on the ground, and a diverse range of farmers, with different farm types, but also different levels of, possibly, interaction with soil health, et cetera. That would have helped, I think, build it up. However, as it's definitely such an important subject, it's good to have the focus on it. But the SFS has, obviously, dominated workloads, et cetera.

The only thing I think we would change as an organisation—. Of the three objectives, I think two relate to information and only the one, the third objective, actually relates to action on the ground—so, looking at preventing, protecting and enhancing. And I think, actually, we would have liked more emphasis on that third objective, which would have made more action happen, I suppose, and be more applicable to farmers, and provide the insight that they need—the information element. It depends which way that information is flowing, I think. The information needs to provide insights back to the farmer as opposed to just being a one-way street of farmers providing the information themselves. We've got such a huge amount of modelling and soil data, but possibly not that much that is useful for the farmer and is reflected in field-level information.

Abi.

I won't repeat any of that, but we had an opportunity to feed in. I think that soils are incredibly important to all of our members. The outcomes—. You know, it's fairly straightforward. It's looking for more information for sharing it, and then for protecting and enhancing the value of soils, which I think we all share. So, it's a good starting point, and it's just looking to see how that will develop.

I'm surprised all three of you haven't mentioned that there are no targets in the strategy or policy document that they've brought forward. In the previous session, that was amplified by the witnesses, who agreed that the document was a good document but it lacked targets. That's something we hear very often in these committees and in this building—that there are many good documents there, but if you haven't got a target to aim for, then how do you know you've been successful? Would you agree with that sentiment, that that is a missing part of the jigsaw, that there are no targets?

I'll come in. I would say there are plenty of targets related to soil and farming within Wales currently. The document you're referring to, yes, there are no specific targets within it. I think there's sufficient—. There's net zero by 2050, which is the overarching policy aim and legal requirement by the Welsh Government and, indeed, the UK Government. There are also many aspects of the Agriculture (Wales) Act 2023. There's the sustainable management of resources requirements. There's the Well-being of Future Generations (Wales) Act 2015. So, I think there are lots of Acts and Government policy documents that relate to targets that all stem, more or less, from soil management or sustainable soil management. So, I think there's adequate targeting within other aspects of the Welsh Government.

But you accept it doesn't sit in this strategy? 

I accept it's not in it; I don't necessarily think it should be in that particular document, no.

Okay, fine. Do you agree, other guests?

So, our view is that, particularly with soils, it's really hard to put a target on it, because there's so much variability across soil types across Wales, depending on your height of land, the sector that you're in. There are so many things that can alter it. So, I think that we've got some good evidence out there. We've got the soil evidence programme. They've got a really good database. I mean, they analysed over 200,000 soil types right across Wales. I think if you start to add on further targets, it's not going to have a huge amount of meaning over a short period of time. We would definitely look forward to seeing some more baselining done in terms of much deeper soil analysis, much better LiDAR. But I think targets in the round are not really going to be applicable to farms.

Teleri, would you agree with that?

I would agree, yes. I think, as Abi said, the variability of soils means it's really challenging to make one target that is applicable to everyone. Soil organic matter is generally a good indicator of a lot of other different beneficial elements to soil. But, again, in a lot of areas of Wales we're already at very high soil organic matter levels. The challenge we've got at the moment is that there are so many other moving parts, with the agriculture Act, with SLM, with the SFS coming in, the environment Bill, biodiversity targets. So, I think, possibly, it would be a strengthening of soil within those and looking at what we've already got, as opposed to setting a target by itself. I think a target for more action and incentives would be more useful.

Okay. Thank you, Teleri. Sam.

Thank you, Chair. Good morning, panel. Fraser, I'll start with you. The SFS has been discussed and, so, your views on the SFS and soil health in the current iteration of the SFS. Knowing that there'll be an announcement in, most probably, the Royal Welsh—it's most probably a poorly kept secret—if there are options or there are abilities around soil health within the SFS on the universal or optional and collaborative tier, what's the CLA's view on that?

So, I think our view, and the view of our members, is there's got to be some element of soil testing, soil management requirements within the universal actions. There currently is; the latest iteration has things around benchmarking. So, that's covering things that are related to soil health. There's also an option for continuous professional development, or personal development, which, I would say, is a positive. There's obviously quite a wide range of expertise within farmers across Wales and land managers. So, having a bit of a baseline understanding of soil management is a positive within the SFS.

I think one of the biggest universal actions relating to soil and soil health is universal action 3 on soil health planning, and that's a requirement to do a test of your improved land that has had inputs over the past number of years. This test does cover the basics—your Ns, your Ps, your Ks, your—. There's a debate around organic matter. I agree with Teleri, it's a very good indicator for general soil health, but it can be quite difficult to measure on a yearly basis. You know, weather events and other things can affect it quite significantly.

I think where there is a real option to help farmers manage their soils better is through some of the testing that doesn't necessarily rely on a lab. So, I'm sure you've heard about it already, but a visual assessment of soil structure can be done with a spade. Yes, it's quite simple, yes, it doesn't require laboratories, but there can be a huge amount learnt from doing that, if you do it correctly and you know how to interpret your results. So, it's kind of basic things like that within the SFS, I think, that can be quite positive.

There's quite a number of things related to the SFS that I'm happy to go into now, but we might be covering a bit later. I'll say one of them now, and I know it's going to come up again, but according to a report that was published yesterday in terms of the sixth carbon budget for Wales, there is a need for long-term established funding for things that take a long time to get and remain in a good condition: things like soil, for example. So, that requirement from Welsh Government is really important that we have this long-term funding model to do all the things that we know land needs to do within Wales. And I think, without it, it's very difficult for farm businesses to adapt and maintain the behaviours that they need to do to meet all these targets we need to do, alongside producing the food that we need as a country. 

Thank you, Fraser. Teleri.

Yes, Fraser's covered some of them. I think, obviously, the change that we're going to be seeing next year is cross-compliance, whether that's your good agricultural and environmental conditions or your statutory management requirements, et cetera; instead of being paid for, they will be the regulatory baseline. So, obviously, we've got those staying there and being enhanced, and then, on top of that, the additionality will be the universal actions. And because soil is so cross-cutting, it obviously does come into quite a few of the universal actions, so, the soil health planning, the soil testing, the integrated pest management as well, continuous professional development, and actually the habitat maintenance and management has got quite a lot of things relating to soil protection. So, I think it's covered there fairly broadly. I think the real jump, I suppose, will be the soil testing and the need to report on that soil testing directly to Welsh Government; that's going to be quite a big change.

Just picking up on what Fraser was saying, soil testing in the past has been generally sort of chemical analysis. The biological and the physical haven't tended to be within—always within—the soil sampling. So, I think there is potential to provide more insight back to farmers. The soil testing at the moment, within the proposals, is for where you're putting inputs down as opposed to all fields. And I know, in Northern Ireland, they're actually paying for all fields to be tested, and also for the soil carbon element to be given as well.

So, I think soil is absolutely there within the universal actions, and obviously there are opportunities then to go even further within the optional and the collaborative tiers. I think there's a slight concern about the data element of that soil testing, in terms of how that will get used and the sort of data protection elements around it, but, absolutely, if it can be linked with providing insights back to farmers, then I think that's to be welcomed.

Good. Thank you. Abi.

It's really just to add that the SFS does cover soil in quite a few of the universal actions, as we're led to believe so far, in the development. The absolutely key thing is getting farmers on the SFS in the first place and they've got to get on to the universal layer in order to be able to access any of the other schemes. And also we do need to think about the ability to support farmers for capital expenditure. It's great to give them knowledge on how they can look after their soils, but if it's completely unreachable because it's so expensive, then they're not going to be able to do a lot about it, and a lot of this relies on the SFS. Farmers have got to be able to get on that scheme and it's got to properly reward them for what the Government is asking them to do.

Fab. We know that there's sort of a sub-committee in the development of the SFS, looking around carbon sequestration, but one of the academics who gave evidence here said that soil in Wales is a net emitter of carbon. Abi, I can see you shaking your head there. I'll go to you first on that point.

So, I would like to have some more scrutiny on that claim, because the information that we've seen, particularly from the Climate Change Committee report that came out yesterday, would suggest that, actually, carbon within soils is stable and, over historic periods of time, is slightly declining. So I'm not quite sure where that claim came from. It would be useful to get some more information on that.

Okay, thank you. Teleri, anything to add?

Just to add, yes, the most recent national trends that the ERAMMP came out with was that national topsoil in Wales is stable. The losses were actually within arable, and we know that there's more urban expansion happening as well, so I don't know if, possibly, it was related to that and to arable. I know, across the UK and England, there is a definite loss of carbon. And, obviously, it can be localised, can't it? It depends exactly what's happening. But, as a general term, the topsoil carbon is stable.

There was a recommendation within the carbon sequestration review to measure down further than 15 cm, down to 30 cm, because I think, particularly within our permanent pastures, this more stable carbon is in that lower level. Obviously, the topsoil is generally more in flux, so I think it would be useful to have analysis that goes deeper, where you can get deeper.

Okay. Fraser.

I think it's been covered sufficiently by Teleri and Abi, thanks.

Fab, thank you. And then just the final point is on the ERAMMP, the results of the Glastir agri-environment scheme showed that it had little benefit in improving soil. So, in designing a new scheme, are lessons being learnt from Glastir when it comes to soil health for future schemes, SFS? Fraser.

Well, they absolutely have to be, and it's really important that any lessons from previous schemes, whether that's Glastir, Tir Gofal or any of the others, that they're built upon and improved upon going into the SFS. I think the ERAMMP report is very useful, it's alongside many other reports—'State of Natural Resources Report', known as SoNaRR, and others—to determine where we are in terms of our natural resources within Wales. It's quite difficult. The climate's changing and that's affecting various metrics and measurements that were taken at the time. So, I think the important thing to remember is there were 3,000-odd members within those previous schemes, we need to have 16,000, 17,000 or more within the SFS to really make inroads on the important targets we need, all those things that land needs to do. So, I think those groups are there and all three of us, or colleagues, are part of those groups. Our members are feeding back to us what they learned, what went well, what didn't. And, again, it links to how much funding from Government, alongside some of the private investment, which we might talk about later, can be targeted towards those things we need people to do.

Okay, thank you Fraser. Teleri.

I think it's challenging because Glastir wasn't—. It was a target that was added in, to mitigate and adapt to climate change and improve soil health, but I wouldn't say Glastir was designed around improving soil health. It was very much a habitat maintenance and management scheme. So, I don't think it's necessarily fair to say that it hasn't achieved it, when it wasn't designed at the beginning. I think the biggest change we've got, which Fraser alludes to, is obviously Glastir was between 2,000 and 3,000 farmers going into it, and SFS, in theory, could be up to 16,000. The challenge is getting them into it.

There are quite a few elements to Glastir that, I think, possibly didn't contribute towards actively increasing soil health, and one of those, as an example, was the stocking rates. So, what we’ve had in quite a lot of agri-environment schemes are fairly exact, low stocking rates across the board. And, actually, we know that a low stocking rate doesn’t necessarily lead to increased soil health; it’s much more to do with impact and rest. And, in any other sort of grazing management, it is to do with that sort of graze and rest cycle. We’ve seen it happen in a lot of the uplands, where we now have, because of low and static stocking rates, large areas of quite monocultural molinia. And, so, you’ve got areas that are therefore under-grazed and areas that are overgrazed.

So, hopefully, going forward, some of the habitat prescriptions won’t be as prescriptive or static as Glastir has been, and, hopefully, will be amended. It would be good to see the stocking rates amended to reflect that. And, obviously, there’s such a link, isn’t there, between biodiversity below ground and compaction, et cetera. I know compaction has been identified as a potential risk going forward, especially with extreme weather.

So, I think lessons are being learnt. It’s balancing that against the need to get everyone into the SFS universal layer, particularly when previous rural development plan schemes were eight times more expensive to administer than your basic payment scheme. So, there’s obviously going to be a trade-off and a balance between ambition and enabling farmers to get into this from the start.

Okay, thank you. Abi.

Glastir was trying to achieve a number of things, not just soil health, it was biodiversity as well. I think that we should remember that soils in Wales, generally, are in good health. They have remained in good health throughout the period of Glastir. I think that is an achievement. I think that Glastir has seen an increase in hedges, woodland. We’ve seen waterways fenced off, ponds restored, any number of things done. So, farmers have delivered on what they were asked to do. Yes, we can have ambitions going forward, but they’ve got to be practically achievable and affordable.

Thank you. Thank you, Chair. 

Over to you, Jenny. 

Good morning. Thank you very much for both your papers. I wanted to just look at the best and most versatile agricultural land, because that’s where we are more likely to be able to grow crops and vegetables. How effective is Welsh planning policy in protecting the best and most versatile agricultural land, which, in line with your excellent bar chart, tells us is about 10 to 15 per cent? So, obviously, it’s very precious. How good are we at actually preventing it from being hijacked by other commercial interests?

I think it’s a real challenge, because land use—. The agricultural classifications were there to do one thing, whereas I think land use, now, has got so many other demands on it. So, obviously, solar panels is one that comes up quite often with our members, and development. And the Glastir report did say that, with urban expansion, I think it went up at the same rate as woodland expansion, didn’t it? So, it’s definitely happening. We would obviously like to see that strengthened to protect that best and most versatile land as a limited resource.

Our only concern here is that if we put all the protection onto BMV land, actually, the other land is still worth protecting and valuable for food protection, for carbon, for biodiversity. And as ERAMMP identified, the carbon losses are happening in those arable soils, and I think they are the ones under increased climate stress as well. Potentially, our maybe 'more slow and steady wins the race' soils are actually the ones that are becoming more resilient in the face of climate change.

So, I think the classifications possibly need to go further now, to reflect those competing land use demands that we’ve got, and how our priorities have possibly shifted over time. But I do think we need to be very cautious to absolutely protect our food producing land when we’re not making any more land. I don’t personally know the exact ins and outs of the planning strategy, in terms of how it can get overwritten in this context.

Just looking at the Cabinet Secretary’s paper, planning policy makes 'representations on planning applications'. There’s nothing in there that says ‘bans the use of, or the hijacking of this land’. So, Abi Reader, as a farmer in the Vale of Glamorgan, you’ll be fully aware of these pressures precisely around the centres of population that need to be able to feed themselves. Professor Bridget Emmett, in our last session, from Aberystwyth University, said that some of this precious best and versatile land has already been lost to urban expansion, either for housing or other purposes. We haven't got any details on that, she wasn't able to be specific, but what's your view as to whether this should be protected in law?

Some of this land has been lost in this area. I've got family members who will have had incredible grade 2 soils that now sit under housing estates. It's always complicated, because people need somewhere to live, but we have long argued for a sound decision-making framework so that if we are looking at development, we make sure that we do not do it at the risk of losing some of our most precious resources, soil being one of them, for growing food.

That decision-making framework is really important. If we can produce in Wales a well-being of future generations Act, we can produce another one that helps to protect soils in an appropriate way. Potentially, people who are making planning decisions just aren't close enough to the pressures of food security to fully understand the ramifications, and they're thinking as much about other issues. It's trying to get that balance.

A decision-making framework is essential, really, so that everyone knows where they stand. It's not just for housing, this would be for renewable energy, if we're looking at solar parks, things like that, so that everyone knows where they stand. For pylons going across the middle of Wales, what are the impacts, what should be directing and driving our decisions?

Solar panels above car parks are absolutely fine, but not on grade 1 agricultural land. So, do you think that we need legislation to actually say that only under unbelievably exceptional circumstances could we allow this land to be used for other purposes?

Legislation always makes me a bit nervous because it can pin you into all sorts of corners, and you can end up sometimes doing the complete opposite of what you were trying to do. But, absolutely, we need a framework that people sign up to, that they have faith in and believe in. In theory, it shouldn't need legislation, it should need everybody to say, ‘Yes, this is an important part of Wales.’ And we certainly need to start at that point. I think sometimes if you go down the legislative route, it can just lock you into too many corners, and we're in such a volatile world at the minute.

Okay. Fraser, is there anything that you want to add on this?

Yes, there is. Thanks. I suppose it's symptomatic of a planning regime or system that isn't working as well as it perhaps could have. We've actually done quite a bit of research on planning within Wales. We were part of a cross-party group looking at rural growth, and one of the aspects of that was looking at planning within Wales and the planning system. I think that if the planning system performed better then that pressure or ability to determine what land is more suitable for particular developments would be met. Not all 25 local planning authorities have up-to-date local plans, which means they're not fully up to speed with ‘Planning Policy Wales’, which definitely looks at grade 1, 2, 3a and 3b agricultural land as not being ideal for planning upon. I suppose it stems from the need for affordable housing, which is one of Welsh Government's key targets that it needs to meet.

We've got a whole series of recommendations that we think would really help the Welsh Government in terms of meeting those targets and probably take the pressure off that high-quality agricultural land. For example, things like permission in principle for rural economic development, permissive development rights for agricultural buildings to turn into other residential or commercial uses, and just having a system that is more streamlined while acknowledging the the competing demands of biodiversity, housing, farming, renewable energy, et cetera. I think there's definitely a way forward. These recommendations have been supported by a whole range of academics as well as planning policy experts, and I think they're easy wins without having to go down the legislation route.

Thank you.

Just on the renewables, Abi, you made the point that you would be against legislation, but only this week we've seen in England a new solar farm being given approval by the Secretary of State in England that's the size of Durham. It's taking out that volume of land. I think it's 1,250 hectares of arable land that it's taking out. So if you don't believe that the system can be used effectively at the moment, what do you think needs to happen to protect that land when it comes to renewables? Because we heard in the last session that, actually, there's a presumption against residential development very often in certain areas, but when it comes to renewables and when you're talking about the scale that I just mentioned, there's actually a presumption in the planning system that favoured that going ahead. And that, I would suggest, takes that land out of effective production. 

I didn't say I was against it; I said that legislation makes me nervous. We need to have a much more pragmatic framework that can enable us to achieve certain ambitions. At NFU Cymru, we have got an ambition to reach net zero by 2040, and that covers three main targets. One is being more efficient producers, which comes out of the SFS; another one is sequestering carbon, which comes out of fantastic soils and making sure that we've got really good quality vegetation and habitat; but the other one is trying to maximise on renewable energy, and there are opportunities for all of these to come in.

You've just given a very extreme example there, which could have serious ramifications on food security, but I think once you start to encompass that in legislation, it might protect from the extremes, but what about the bits in the middle, which are more pragmatic? So, I think we need to really think about that before we start locking things down in law, because as we've seen with things like the the Water Resources (Control of Agricultural Pollution) (Wales) Regulations 2021, that can have all sorts of different impacts. If you look at the legislation that might be coming in on inheritance tax, the impacts of these things can be far-reaching and certainly not achieve what they were supposed to.

Does anyone else want to contribute on that point?

Just to say that we've lobbied for a long time for more support for renewable energy on-farm. Like you say, for that middle section, that creates so many win-wins, instead of needing to go down the route of solar panels plastering farmland.

I think the challenge is the economies of scale element, as usual, isn't it? That is obviously one where the finances have made sense, but I think in terms of land use and making the most of what we've got, and making sure that the income from renewable energy is circulated within rural economies, that's where having the win-win of panels on sheds et cetera and integrated into farmland is a far more worthwhile achievement.

I was going to make the point Teleri made about the need for local communities to have access or use of those renewable resources. Whether that's new energy grid infrastructure or whether that's renewable energy supplies, it's absolutely paramount that they get access to that and can benefit from that themselves. I think where there is a huge amount of opposition to these kinds of things is where things are done to the community and there's no community benefit for the people who are actually putting up with the issues. There's probably a discussion around undergrounding that needs to be had and how that can benefit local people if the infrastructure does need to go in—perhaps that's for another meeting.

I suppose it also comes down to all these competing demands for our land and therefore the soil. As I'm sure you've heard earlier, there's a land use framework under consultation within England at the moment. Is there an opportunity to do that in Wales, when we talk about the local energy plans that different areas have from Welsh Government; also the need for food in certain areas, the competing demands for tree cover, and all the CCC targets that need to be met? So, I think my initial view on a land use framework to help those decisions be made would be a 'yes', with the input from all the different communities and areas within Wales that can be affected by it.

Just going back to what Professor Emmett said, she said that, actually, the soil displaced by a housing development, instead of going back onto the land, this best soil was going to landfill. So, how do we stop that happening as a complete no-no? Abi.

I confess that when I heard her giving that evidence—. I'm really not familiar enough with it. I know that if you're taking topsoil off, it has enormous value, so it doesn't make a lot of sense. I'm afraid I can't really comment on the—

No, on the detail, of course, but should there be legislation to say, 'This should never happen'?

Yes.

Thank you.

Thank you, Jenny. Hefin.

Diolch, Gadeirydd. I'll combine the two questions that I've got into one for ease of answer, I think. To what extent are farmers testing their soils and adapting their own management practices appropriately? And with that in mind, are there opportunities available for farmers to upskill on how they run soil management, and if there are those opportunities, is there an opportunity to improve those processes?

Shall we mix it up and go Abi first, and then go across the panel?

Generally across Wales, farmers are testing their soils. They won't always do it through the Farming Connect programme; that is available to them, but likewise, you can access that through various other traders who work in the industry and are quite happy to provide that information.

We need to be a little bit nervous when we're looking at data that might be gathered from the testing of these soils, because generally, if you're testing a soil, it's because you're concerned about the condition of that field at the time, so you're not actually going to be testing your best soil. You'll be testing your worst field, to try and understand what the problem is. So, I think in terms of using it as a database to say is the soil in Wales good or bad, I don't think it's a relevant metric for us.

What was the other part of the question?

Regarding the opportunities for farmers to have their skills updated on how they do this and do it in a way that doesn't put huge pressure on outside bodies.

There's a huge amount of talk about soils at the moment. It's very trendy, particularly for our next generation who are coming through. There's uptake in various low-carbon shows, all sorts of events that are happening throughout the UK, and actually, we've got young people who will travel to look at that. There are a lot of skills out there.

I think it again comes back to the point I made at the start, which is you could have all those knowledge and skills, but have you got the capital to be able to invest in it. Some of these things can require some very expensive equipment, whether that is machinery or electronic; is there a sufficient database out there for you to be able to use that information?

I think that when you look at something like the Farming Connect programme, where they have, I feel, done well is where they've supported discussion groups so that they can bring farmers together, whether that's in a geographic area or where it links you by sector. That gives you an opportunity to benchmark and do a lot of progression on your farm that's relevant to your area.

I think there's a whole range, isn't there, in terms of testing and looking at your fields and adapting it. Part of it happens for farmers by osmosis; you walk across the field and you go, 'Right, well, there's pooling there, there's compaction there, that crop isn't looking so good', and then you go all the way up to the apps that you could have, the sort of regenerative outcomes-type apps.

I think the challenge we've got is that with the soil testing, you need to make sure that you're staying with the same lab as well, if you're continuing to test. I'll give myself as an example. I've tested soils and we've got very low indices, so generally the advice is on fertiliser to increase those indices. We have to be a bit careful about this in terms of if we're encouraging people to react according to the soil test results, that would probably point to a need for more lime and more fertiliser in many instances.

Again, I think the capital element is a challenge, as are tenancies. My concern going forward with the instability at the moment and the scale of change in farming is that we're going to see a lot of short-term tenures continuing, particularly with the scale of change in the SFS, and everything else that's happening. It's very hard for that tenant to react to what the soil needs and to be able to invest in it. Obviously within the SFS universal layer, there are lots of elements in terms of soil testing and showing what you're doing, but also the optional and collaborative, once they're in the SFS, is going to allow that ability to react and to adapt according to your soil test results, whether that's your diversity at rooting leys, whether that's lime, whether that's mob grazing et cetera.

I do think there are fairly farmer-friendly soil testing abilities to do with your VESS and your earthworm counts and your infiltration tests et cetera. Those are ones that would obviously be looking more at the biological and structural element of soils, which possibly has been missing in the past with soil tests. But again, it's time and it's continuous professional development and it's capital to invest in the infrastructure that you then might need to implement a lot of these actions.

I won't repeat what's been covered already, but an example that we've got, which some of our members are a part of, is the Beacons megacatchment. That's a number of farmers within a specific area, who've come together and identified that they might have a shared goal in terms of managing their land a bit differently, or a bit more sustainably. I think the entry to that was some kind of funding from Dŵr Cymru with some testing, but also the important thing is what's done with those tests and having funding to do actions stemming from those tests.

So, it's very easy to get bogged down in testing every single acre of land within Wales, which is not feasible and very unlikely to happen. But targeted testing on similar areas across these discussion groups can be quite useful, and they can also share some of the expertise they've learned. I think they've also found that, in this particular group, learning from each other, dragging neighbours into the group as well, has been really successful. It's led on to being part of one of the INRS schemes, the integrated natural resources schemes that Welsh Government funds, which has provided them with a small amount of funding for a facilitator. But it's all about funding to do actual actions stemming from those tests in the first place. So, I think that's a good example of where farmers have been learning and getting better at some of these things.

Thank you, Fraser. Abi, you wanted to come back in.

Yes, I'd just add two more points. Having recently had some conversation with the South East Wales Rivers Trust and the Woodland Trust, there are some fascinating maps out there that Welsh Government holds that show overland flow of water, which I think would be incredibly valuable to farmers in terms of looking after their soil, helping to slow the flow of water, which could make them more drought resilient, helping to think more about flooding, where you can mitigate issues. If this mapping is already available through Welsh Government, I think it would be excellent to make it widely available for farmers and to help them to understand how they could react to that mapping.

And then a second matter as well—because Teleri mentioned tenants—I think we do need to be very concerned about the length of tenancies on farms. Lots more land is turning over to short what we call FBTs or farm business tenancies, where they could be one or two years. If you have only got some land for a year, you are unlikely to soil test it, because (1) you won't really have time to react to it, but, if you did, you're not really going to see the benefits from it. I think we should be particularly alive to that if inheritance tax goes through in its current format, because we are going to see more short-term FBTs in our estimation, particularly because we're already seeing people who've got large property portfolios who are now more tempted to go and buy agricultural land, as opposed to a shopping mall or whatever it may be, and they are unlikely to want to put long-term tenancies on this land. There'll be short-term FBTs, and I think that will be a detriment to our soils, let alone our food production.

Hefin, a follow-up or—? Just one quick point on the testing and capacity for testing of land. It was raised in the previous session, the impartiality maybe, I think that was the word that was used, of some of the people who do that testing, because, obviously, they're promoting the product at the end of it that they wish to sell to you, they do, then. In a bygone day, ADAS for example, which was then a Government agency, used to fulfil that role of honest broker. If there was to be an increase in this capacity to test, have you got any concerns over the ability for that advice to be genuinely impartial and objective rather than high-pressure sales?

I think, generally, the advice, like you say, comes via Farming Connect or via ADAS et cetera. So, you don't get that same connection, I suppose. Also, the soil test will point to low indices, but, as I said, it's important that you stay with the same lab, because some of them can measure it slightly differently. I think we've got to be cautious on the advice element in that a lot of—. Yes, it's important to have impartiality, absolutely, and for the farmer to trust them, but we can go down the route of spending an awful lot of the budget on advice and guidance instead of actually supporting the actions that are needed direct to farmers as well. So, that would be my only caution with increasing the advice and guidance element.

Do you concur—to the other guests?

I would say this is about the credibility of the lab. I think if there's a commercial element to it then there's a stronger possibility that farmers are likely to react after the results. So, making sure that you've got a credible lab that will give you a credible result, and then that farmer can make that decision.

Do you concur?

Yes. I'd just add, I think that, with all the pressures that farm businesses are under at the moment, the days of buying anything because the rep says it are probably gone, to be honest. So, yes, I'd just concur with what's been said earlier.

Fine, thank you. Sam.

Thank you very much, Chair. Coming back to regulation, national minimum standards and targets, obviously, now the EU regulations on cross-compliance no longer apply. The regulatory framework for soil—what are your views on that, Abi?

So, cross-compliance still applies. If you are receiving BPS, you’re still under cross-compliance. If you continue to receive BPS up to 2029, which is the phasing out, it will still apply. If you opt to go over to SFS, as we understand it, cross-compliance will come in then, anyway. So, I think that shouldn’t be a concern.

Okay, thank you. Teleri, agree?

Yes, absolutely agree. And, obviously, we've also got additional regulation coming in, such as the control of agricultural pollution regs. And I think, also, the regulatory baseline for the SFS will obviously be, effectively, cross-compliance, because you will have some within the SFS and some within BPS. So, in terms of making sure that everyone is—. Yes, the two are going to be running together, essentially, and we’ve got a strengthening of that regulatory baseline within the SFS as well. So, it is actually going to be quite a huge jump, because before you were paid for cross-compliance, whereas now you’ll be paid for the universal actions.

So, it’s definitely still there, and I think as well the other aspects that we’ve got coming in are in terms of, obviously, the control of agricultural pollution regulations, and we’ve got the environment Bill coming in as well, and sustainable land management indicators. So, actually, I think we’re going to see an increase overall of those standards and the regulatory baseline.

Okay, thank you. Fraser.

Yes, they’re not disappearing, because SFS is beginning. So, they’re still going to be there. We’ve also got the environmental impact assessments, EIAs, which you need to apply for before you’re changing any land use. So, I think it is probably an opportunity for Welsh Government to explain these things a bit better and provide the guidance in a more understandable way, I think. We had, a few weeks ago, all the GAECs presented to us, which are going to be moved across into the SFS. And looking at them, even though I’m familiar with them—maybe not as much as some of the others on the panel—it’s still quite daunting looking at them all. So, I think there’s a real opportunity here for the guidance to be a bit clearer and a bit more accessible to make people get behind it a bit more.

Okay, thank you. Abi.

Yes. Just to add that one more point that, if we’re concerned about farmers who will fall outside of BPS and SFS, then the obvious point on this is to make sure we put shoulders to the wheel and get everybody on SFS—that has to be the one that everyone wants to be a part of and is proud to champion.

Yes. So, that was going to be my next question, actually. Once BPS comes to an end and farmers are making the decision whether to sign up to SFS or remain non-subsidised, in that sense, and just go it alone—to use that terminology—what happens then around NMS?

I don't think we should allow ourselves to get to that point. We are creating a scheme that is, essentially, going to be groundbreaking because it’s something for Wales, made by Wales, set outside Europe and should be there to deliver on all of the sustainable land management objectives. And we have a duty to make sure that that scheme is accessible for all farmers and delivers at least the same benefit as BPS in terms of food security, biodiversity, climate, nature—all of those things—culture.

So, we shouldn’t really entertain the fact that there might be those farmers who don’t sign up and what happens then around soil national minimum standards.

Well, there are still going to be overall standards that all landowners will have to abide by, and that’s the current situation at the moment.

Okay, thank you. Teleri.

Yes. I’d agree with that. I think, in terms of the SFS, it is obviously a huge opportunity, but also a huge risk if we don’t get it right and we don’t make it so that all farmers can enter into it, because the universal action is a huge jump in what we’re doing currently and then, obviously, we’ve got the optional and collaborative as well to really drive things forward. So, yes, I’d agree; we just need to get the SFS right.

Okay, thank you. Fraser.

Yes. No big disagreement here on this one. I think we've also got to look across to what's happening in England as well, and their sustainable farming incentive was basically pulled overnight after many years of policy development, leaving lots of people who've applied for it in the lurch and a shortfall of huge amounts of money, damaging not just their businesses but also all the things they'd built up through their own agri-environment schemes. So, there's a commitment required from Government to fund it correctly and commit to it. There's also commitment from ourselves and, all being well, we can support our members to apply to the SFS to make sure we don't get to the stage where people aren't part of it.

So—sorry, Teleri—just to come back on that point then, if we talk about agriculture as an industry specifically, and not talk about house building or anything else, the SFS is the best vehicle available to us around soil health. There needn't be anything separate to SFS when it comes to improving soil health in Wales. The SFS, if done properly and correctly, is the vehicle to deliver maintenance and improvements around soil health. Is that unanimously agreed?

That should be the ambition of this Government, yes.

Okay. Sorry, Teleri, you were going to come back on a point as well.

It was just on what you were saying in terms of national minimum standards. I think, in terms of the SFS, if you're choosing to put in national minimum standards across the board, it's: where do you draw the line? So, if they're not getting paid for it, are you saying that this is something that absolutely anyone with anything to do with soil has to comply with? So, does it apply to forestry? Does it apply to developers who are, apparently, putting topsoil in the bin, which is outrageous? So, if we're concerned about that, then it needs to be genuinely minimum standards for everyone that is managing soils.

Okay.

Yes, I agree with your point, but I suppose there's also an element of others who are part of the agricultural world to participate and carry their own load as well—so, specifically supply chain, the different companies to play their role. We know there's a quite significant shortfall in funding over the five, 10 years. Government can't do everything. I fully support what's been said earlier about them being the primary and setting of rules and regulations through the SFS, but there's got to be an option to bring in that additional private finance. I know it's a difficult area at the moment. I'm not saying it's perfect and fully possible. But, as things develop over the coming years, I think there's got to be a role for those companies to play a role.

Also, some sectors—as others on the panel will know more than I would—are already fully integrated, for example, the dairy and some of the arable sectors—potatoes, for example. But then, some of the others, sheep and beef, which Wales predominantly is, are less aligned with their market. So, there's definitely got to be a bit more ambition there from Welsh Government.

Okay, thank you. Thank you, Chair.

Thank you. Jenny.

Thank you. I want to look at carbon credits, which interlocks with the other thing I want to talk about, which is organic and regenerative farming. In your FUW paper you're talking about the 'wild west' in terms of carbon offsetting. Clearly, we need to ensure that, if people are offsetting something, it's something that works, rather than just being on paper. Could you just talk a little bit about how this soil carbon code would work?

Yes, it's a really challenging one, and I believe that the soil carbon code is still under development. We've got the woodland carbon code. We've got the peatland carbon code. They're not perfect, but they are there, and that's what most people will use. The carbon code—we haven't got one set carbon code. There are rules around how you test, et cetera. Soil carbon is, again, such a risk and such an opportunity. You have got the examples of Formula 1 teams buying soil carbon credits and offsetting what they do. So, you've got those examples, whereas you've also got examples where some of our members are going in as groups to do the soil sampling, via soil carbon credits, and then basically measuring the achievements where they have managed to, via management, increase their soil carbon. I think this is potentially quite a win-win, because they have then got the option to use it for themselves against their own businesses. But it's who holds the data holds the power, essentially. So, if they've gone into an agreement with a company, they hold the data, so they can therefore use it and sell it. It's effectively the same with supply chains, where they're using it to—. I think they call it 'insetting'. Basically, they're using it for their scope 3, and they can use it against their own carbon budgets.

So, it's quite a complicated place. There are a lot of opportunities, because a lot of the things that we do well in Wales are also good for soil carbon. The challenge, I think, for Government is that soil protection is very, very important, and because we have got, particularly within permanent pastures et cetera, such high levels of soil carbon already, the outside industry—companies et cetera—buying carbon credits will only pay on additionality. So, they won't pay for you to keep doing the good work that you're doing, they will only pay if you can prove that you've added carbon to your soils, and, obviously, that is also easily lost as well. So, it's an opportunity, but, I think, when it's being done by businesses who aren't having to prove that they're doing everything they can to reduce their emissions first, it's quite challenging, and generally our advice to members has been, 'Make sure that you look after yourself and your business first in terms of net zero.'

Okay. So, just to come back to another point you made, which is that, whilst there is a huge array of soil monitoring going on, most of the data is not being communicated back to the person who matters, which is the farmer. Why is that happening? Because ERAMMP is a not-for-profit—clearly, it's funded by the Government. Why systematically are we not sharing information about your piece of land, if we've been testing it?

It's such a missed opportunity. As Abi was alluding to, the LiDAR data is there to show run-off, it's there to show where you've increased your biomass et cetera, and I think providing that back to farmers would be quite impactful. For example, with Rural Payments Wales, we've got all our maps of our farms there; we go into it fairly regularly, but at least once a year to do single application forms, and that's going to be the same sort of process for the SFS—you go into it and you've got a dashboard, et cetera. So, there's a real opportunity there. I don't know if it's because, obviously, they compile it all to create national trends, and that doesn't necessarily really speak to the farmer. You want to know what's happening on your land—

Of course, that's the only bit you're going to be able to change.

—and what you can do. Yes, exactly. Again, personally, I don't actually understand where that link is. Is it just that they find it difficult to make that link, with all due respect, as academics, down to the people on the ground, and I think that's where, obviously, we've got an opportunity, and Farming Connect have got an opportunity, to make that relevant to the farmer.

There's a slight balance, isn't there, with farmers. We're very busy doing what we need to do and then how much time we've got to actually go into all these maps and assess things and change et cetera—. So, making it accessible and useful is the link.

I can see there's some complexity to this—well, not to that. That, I hope, could be a clear recommendation within our report.

I just want to move on now to organic and regenerative farming. Abi, the NFU document talks about—. You're quite challenging about the control of agricultural pollution regulations actually having perverse consequences. I wonder if you could just talk about that, because, clearly, there is always money in muck and it's how we handle it. How do you make it less prescriptive, without having people doing things that end up in the river, which we definitely don't want?

The most perverse regulation is probably the stocking rate of the 170 kg of nitrogen, because, actually, the way you work out your nitrogen availability on a crop is you use a guideline called RB209. And if you use the same guideline that comes out of what is essentially the nitrate vulnerable zones regulations, you end up with nowhere near enough muck on your farm to be able to grow your crops because you have to meet that 170 kg.

The way they measure nitrogen under the control of agricultural pollutions regulations is they look at a cow—let's just use a cow for an example—they look at all of her emissions, absolutely everything the minute it leaves her body, whether that's from her mouth or back end, whatever it may be. They don't look at the value of the dung once it's hit the deck, and it's actually half of that value. So, if you're suddenly having to meet a much lower stocking rate, and actually that stocking rate is quite close to organic levels, in some cases, depending on your farming system, and it puts you on organic levels for stocking rate, it means you're going to be far short of organic manure and you will have to go out and buy in artificial fertiliser in order to top yourself up, which just makes zero sense. That is a really perverse rule.

I agree, because, clearly, we're spending money on something that you've then got to buy on the market, which we don't want them to use in in the first place, and we're not allowing the alternative of reduce, reuse, recycle.

So, things like that need to be looked at, and likewise things like the closed period. We seem to have more and more unusual seasons don't we? I've done three interviews this week. I've come from one this morning talking about the dry weather. It's so strange; these closed periods do not fit with modern-day life, modern-day farming. They're not going to enable farmers to do the right thing, and the right thing is to make sure that muck goes on the field, in your soil, and then you can grow your crop, whatever that may be.

Which brings us back to the issues we've touched on briefly, which is how we adapt our farming practices to climate change and obviously the more unpredictable weather. So, more droughts, more intense rainfall, which reduces the amount of time that people can be farming some pieces of land. Clearly, the map the Government has provided tells you the generality of it. So, how could we be using more regenerative practices that don't necessarily cost money? There was something on Farming Today this week about somebody who divided up their pastureland so that the cows could only go on one part of it for two days and then they were waiting for the fence to be removed so they could get onto the next one. But they were saying this has measurably improved the quality of the grass, because it's got more time to recover. So, is this something that is going to become blindingly obvious to nearly all farmers?

I think the jewel in the crown for Wales is the fact that a lot of farmers are regenerative farmers. Where we've got the problem is that not a lot of farmers identify with that phrase, because it doesn't mean a lot. But if you took the three basic principles of what a regenerative farmer is, it's constant ground cover or minimal ground disturbance, which even for our growers, they're all moving away to no-tillage systems or minimum-tillage systems where possible. Sometimes that's a struggle if you're organic or you're struggling with a big sort of weed outbreak or whatever it may be. So, it's constant ground cover, it's using livestock within the system, and then it's having a diverse cropping system. Every single Welsh farmer will meet at least two of those criteria, probably three, and the SFS could do a bit more.

So, I think a lot of our farmers are already there, they just don’t know, they don't necessarily use the phrase. Paddock strip grazing, which is what you've referred to, or mob grazing, which all our youngsters are going across to New Zealand and Australia to learn even more about, and they come back and they're wearing all the gear and the shorts and everything, and they get obsessed with measuring grass—these things are happening, yes. These things are happening. So, I think it's a real jewel in the crown for Wales. We just need to maybe help farmers shout out a bit about it. Maybe we can have a Welsh brand—it's not 'regenerative', it's something else.

Fabulous. Fraser.

As someone who went to New Zealand and did the same thing—

But you didn't bring the shorts. [Laughter.]

No, I left them at home. [Laughter.] Yes, I think the importance is the flexibility within the SFS to allow people to do these kind of things, whether that is mob grazing, novel crops. I think it's come up a little bit with some of our officials, while we've been developing the detail of the SFS, that some of these regenerative principles or practices aren't catered for within the SFS currently, but they've been shown that they could be with flexibility. So I think, yes, not being too caught up with names of particular types of farming, but allowing all the different practices, which have been done for years within Wales and across the UK—. To allow the people to do them, I think, is the most important thing.

But nevertheless—it's a no-brainer, as far as I'm concerned—you still see land left bare, which obviously is vulnerable, then, to soil being lost into the rivers if it rains heavily.

Yes, sometimes there's a lack of knowledge, perhaps, but I think—

If you're a farmer, can you really have such lack of—? You know, if you leave your land vacant, the soil is going to be either washed away or taken by the wind. 

Sometimes there might not be an option to plant that land before the rain comes, but I think there's definitely a wider way in which people can be encouraged to do these things that we know protect the soil over winter. Having really diverse cropping with cover crops over winter is something that can be done as part of that. 

Isn't one of the biggest obstacles that some farmers are isolated, perhaps reaching the end of their life? If you're ill, you're not going to be able to farm. So, how could we develop more collaborative farming to enable people who have a crisis, for whatever reason, to be able to draw on neighbours to help out on such an important matter as that?

Well, this is absolutely essential. It's the secret to farming going forward. We need more young people, whether they're from farms or not, to come back onto those farms. The main thing that's going to attract them—as someone who's got an apprentice and an array of young people that come in at the farm every year—the main thing that's going to get them there is good wages, because they can go off to various other places and get some seriously good wages, and it's trying to get that good return on the product that the farm is selling back onto the ground.

I think that a challenge for a lot of it, as Abi said, is the profitability element, especially short tenures et cetera and new entrants coming in. Investing in soil is obviously a good investment, but it is a long-term investment. So, when you've got that annual profitability challenge and you need to hit either those yield targets or you need that amount of money in your bank account, there's a real challenge to that, which is where I think the exciting part of the SFS is in having payment rates that reflect that wider benefit to society.

At the moment, a lot of the things that farmers will do to enhance their soils or protect their soils isn't necessarily—. It's helping them, to a certain extent, with their soil health, but, actually, those wider benefits aren't really being reflected in the payment rates. And like you say, a lot of them are win-wins—the integrating clover, your deeper rooting depth, your diverse leys et cetera. They are win-wins for both society and farmers, but there is often an initial investment cost to them, and a big part of it is the management aspect and changing your practices.

It's a big leap when you don't know exactly how it's going to work on your land, you don't know exactly what the outputs are going to be on your type of soil, and you don't know exactly what that season is going to do. So, there's a long-term investment element, but there's also a big management shift that you're asking the farmer to do, which can be challenging with profitability and, exactly as you said, when there are different family pressures.

How do we make it work for tenant farmers who may just get grazing for 12 months, and will there be a tendency to think, 'Well I'm just going to get everything I can out of this land because I'm going to be evicted'?

Yes, and speaking personally, I'm one of those. I've got tenures that range from a handshake right up to 10 months to 10 years, and it is really difficult, because it's not worth your while to put that investment into the soil health. I think, again—sorry, going back to the SFS—making sure that the active farmer is rewarded in this is really, really important, so that whoever's taking the risk on that land and putting that investment in is the one that is getting the payment. I think that's going to be a crucial element to it, and the inheritance tax issue is massive in this respect. So, it's making sure that we've got those longer tenures and that the active farmer is rewarded.

Okay, so we can—. What are the incentives? Are there other incentives that are needed for tenant farmers to ensure that we don't just have somebody who's trying to extract the maximum value today, but are thinking about the longer term?

I think having both within the SFS. We've had to make sure that the SFS, the universal layer, is an annual element, because initially it was going to be five years, which, again, for tenancies and particularly new entrants that are coming in and taking whatever land they can get at whatever tenure that they are offered to them—it's making sure it works for them and that that can be reflected. So, the SFS has got at the moment a proposed 10-month management and a one-year element, but, again, it's those optional layers that have got long-term certainty. I'm sure you hear this in all different committees, but the long-term certainty of budget cycles and investment is going to be crucial.

Well, certainly the long-term commitment that Fraser talked about is essential. 

Thank you, Jenny. Thank you all for your evidence this morning. It's been greatly received by the committee and informed our investigation and inquiry. The transcript will be sent to your good selves of the witness session that you've just partaken in. If you've got any issues about it, please raise it with the clerk, but I thank you once again and wish you a safe journey home. [Interruption.] Don't knock the furniture around too much.[Laughter.]

We'll now move into the break for lunch and resume with the Minister after lunch.

Welcome back to the Economy, Trade and Rural Affairs Committee inquiry into soil health. It's a pleasure to welcome the Minister and his officials to our afternoon session today. Two weeks on the bounce now, Minister, we've had you in—we're spoilt for choice. [Laughter.] What I will do, for the record, I will ask you to introduce yourselves, with the Minister first, and then perhaps the officials, in whatever order you'd like to say your name and position, and then we'll go into questions. So, if I could invite the Cabinet Secretary to introduce himself.

Thank you, Chair. Huw Irranca-Davies, Cabinet Secretary for Climate Change and Rural Affairs, and Deputy First Minister. I'm really glad that you're turning the focus onto soil—really glad.

Thank you, Chair. Good to be here. James Cooke, in the land, nature and forestry division; I specialise on soils, peatlands and agricultural land use planning.

Thank you, Chair. Andrew Chambers. I head up the legislative framework for agriculture as it relates to water quality, air quality and fertilisers.

Thank you, Chair. Naomi Matthiessen. I'm deputy director for landscapes, nature and forestry in Welsh Government.

Thank you very much. Minister, we've heard evidence that the data shows that previous environmental schemes, such as Glastir, haven't reduced carbon as much as we would like to see, or would have thought would have been achieved by such schemes, especially when it comes to soil management. Do you recognise that in the data that you have, and how are you constructing the sustainable farming scheme to maybe address that deficit that has been offered to us in evidence by previous witnesses?

'Yes' and 'no' is going to be my answer to this, because we've been keeping a very good eye on the evidence that you've been receiving this morning, and turning it over ourselves as well. I think what we're clear on is that the environment and rural affairs monitoring and modelling programme says a couple of things. First of all, as the committee will know, the majority of our soil in Wales is actually under grassland pasture, and grassland pasture is a particular characteristic. When it's in good shape and it's being farmed well, it's a good store, if it's maintained well, of carbon, to a certain element. It has limited capacity to increase, by the way, its carbon storage, but it's an interesting area of discussion. But it needs to be really well maintained. But the majority is pastureland—lush, green pastureland, except for the dry weather we're having at the moment; we need a bit more rain again now.

But of course, then we've got two areas, which are the areas we need to really focus on, which ERAMMP does show, which are the issues of peatland and also arable farming land as well, which is not, by the way—I'll just come back to this—the majority of our green, pleasant landscape there in Wales. So, broadly, our soils are actually in a relatively good position, but we're very aware that there are localised and very specific issues, some of which I've just described.

So, the main threats that we've got to soils, which ERAMMP has picked up—and, by the way, just to say, ERAMMP is leading edge in terms of the analysis that we do across the whole of the UK; we're glad that we've got it—it shows that the bigger three are: compaction, erosion and excess nutrients. So, ERAMMP does actually show—and this is why my answer to you is a 'yes' and 'no'—ERAMMP actually shows, very clearly, that there is stabilisation across many of the environmental indicators at the national scale. Most indicators of soil quality at the national scale—and, again, I say to committee members, 'soil quality', and that needs to be unpacked as well; this is a complex area—they remain stable, but some are in decline: localised issues and specific issues. So, the national topsoil carbon concentration, Chair, overall, remains stable, but the carbon in soils under arable land use is in decline, and the driver for this we are investigating. So, the great thing is that ERAMMP has shown us it's in the arable area and that's under investigation.

The ERAMMP 'Wales National Trends and Glastir Evaluation' doesn't actually say that Glastir had a lack of impact on soil quality. What Glastir has delivered is that stability that we're looking for, that maintenance of the indicators of soil quality. I think the challenge is, when somebody says, 'Yeah, but it hasn't done it even better', I guess what we would say is—sorry, straight layperson's terms here—when you've got well-managed, good, green pastureland that is well farmed and well managed, there is limited capacity there to improve it. What there is capacity to do is maintain it well. And what the ERAMMP report shows very clearly, and Glastir shows, is that that has been a success of it. It hasn't improved carbon stores, or improved this, that—and there are more things that we can do—but it's actually created stability.

So, I would simply say, having looked at some of the evidence that you've had already, it's not a scheme that we should expect or anticipate Glastir, or what we do in the monitor, to deliver a step change in soil health or soil quality, when, actually, the baselines were already in relatively good condition. This is a success story, if you like, for pastureland farming in Wales. The actions within Glastir were not designed to deliver step change; what they were to do was actually to make sure that we maintained the best of what we've got.

I'll give you an illustration, because this is really complex, and when you said we had an hour, I thought, 'My goodness, we could spend a few hours going through this', but—. Soil nutrient status on land, subject to low input grassland options, did not decrease. Now, the reason for this is the soil nutrient status of these soils was already low, due to historic low inputs on the land. So, we just need to be cautious about expecting step change when the actual benefit is to maintain the quality of what we've got.

But, linked to the SFS, as you were saying, there's a number of things that we're doing. One is within—. Sorry, the SFS isn't fully signed off yet and so on, but the discussions we've been having within the universal layer, which, again, in layperson's terms, is the entry point for all farmers who come into the scheme, within that, you have monitoring and testing and evaluation of soils. I think that's critically important. That's a step change, because then farmers will be able to see, with support and advice as well, what the condition of the soil is and how they can make improvements and adjustments as well. So, that testing is in there. But there are also options there that we're working on as we speak, which I cannot give the detail on without usurping what the officials group of SFS and the ministerial round-table are doing. They're in the optional layer as well, where it can go further.

Every farm is specific, but the pastureland we've got is, by and large, in good condition, is well managed by farmers and land managers. We've got issues on some of the arable parts, and some specific localised issues that we need to focus on, including, by the way, peatland.

I mean, the point about lime spreading, for example, to improve land quality once you've had the testing done—. Because I think you've indicated that you recognise testing is an important part of what needs to be undertaken—

Critical. Critical.

—although the evidence we've heard today indicates that, in the tenanted sector, for example, where people might have more limited tenancies, there's an unwillingness to obviously spend that money improving those soils, because you've only got it for 10 or 12 months, you have. So, you can test all you want, but if the tenanted market doesn't reflect the inputs, then obviously it's going to be difficult to make those improvements.

But the point I was making about lime spreading, for example, and other remediation work, are you confident that the sustainable farming scheme will be able to incentivise such activities where they're applicable? Because, again, there's a cost associated with them, and there's an uncertainty that, unless you do all the other things about testing and tenure of the land, the people will engage with that remediation work, such as lime spreading, or any other things that the testing might say you need to do.

Indeed. I'll bring in some technical expertise here in a moment, but lime spreading is a piece of its own, because the use of lime on farms definitely has to be informed by good farmer practice, analysis of the soil, the pH levels and so on, and then a decision made whether it's appropriate. But lime application has been a part and parcel of farming, not just in Wales but elsewhere, for many years, based on most of the soils in Wales. In most of our areas, they're naturally slightly acidic. It's part of the reason, by the way, we have the type of biodiversity, we have the soil, we have the complexity of the soil. It's not that we say, 'It's slightly acidic, and therefore we need to do x, y and z with it'; it's 'How do we manage that?', and each farmer will know. But if there are lime applications, very specifically on lime, then each farmer needs to make their decision. To actually bolt that into SFS to say, 'We will put an incentive for lime spreading', would be something that's never been done before, and it would be taxpayers paying, in effect, for lime spreading. It's always been a commercial decision for each farmer. I would say—

I think you'll find that, historically, there were schemes to actively encourage lime spreading in a bygone day, because it was seen as active improvement of land, it was then, and so you could get grants towards it. 

Indeed. And it is in a bygone day, and they were relatively, again, small and localised to the individual farm. I think the knowledge we have now has come on so far, but what underpins the decision for a farmer, whether they want to put lime on—. Lime at the moment, by the way, as the committee will know, is one of those that hasn't been as badly affected by the wider increase in costs. Because there's a cost to actually spreading lime, but it hasn't been as badly affected by the wider issues of applying other inputs that you have to actually purchase inputs into it. It's still relatively, compared to other escalating costs, affordable for most farmers. But it's always been, apart from bygone times, as you say, a decision for that farmer to do. The critical element of it is actually the testing of the soil and making a very well-informed decision whether that fits within it. But, simply to say, if we were to say we were going to, within the SFS, support liming, even based with the knowledge, the cost would be big for the taxpayer. So, I'm very cautious about suggesting that.

Sorry, you also asked about—

Can I come in on that?

Sorry, yes.

By all means, yes.

I think it's partly linked to the previous conversation on the Glastir outcomes report, in that the devil is in the detail with that, that you've got the headline figures, which just give overall messages, but it's actually the technical annexes that set out the detail underpinning those. So, Glastir was primarily a habitat scheme, so those are low-input systems and probably acidic systems, and the packages of bundles—we call them 'bundles'—which were things like removing stock from woodland and fencing, those types of activities are not going to have a direct benefit on the soil.

And when you come on to look at lime in SFS, you've got to consider that, as we're developing it, lots of the habitat prescriptions will have requirements about whether lime can or cannot be applied. So, it's going to be very localised to the soils you've got, the testing, the types of habitats you've got on your farm, and you've also got to think about diffuse issues as well. So, does that liming of that field affect that neighbouring habitat? If we take peatlands, that's quite a key example. You've got lowland fens, you might have some very good soil next to it, but that peatland, if you lime it, or if that lime gets off that field into that peatland body, it's going to cause degradation issues to it. So, it's going be highly specific to that farm, it's going to be dependent on the range of prescriptions in the universal and in the optional space, and you've also got to think about the cropping as well. Certain crops aren't always particularly happy with lime. So, it's quite a complex picture that a one-size-fits-all option in a scheme can't quite cope with, and it comes back down to, as the Deputy First Minister was saying, testing, advice, scheme rules, habitats on the farm, and knowing your soils.

Thank you. Jenny.

You talk about highly specific, but the FUW evidence says that the vast majority of all the data that gets gathered about soil modelling and monitoring doesn't get communicated back to the farmers, who are the people who are going to be able to adapt their practice. And I just wondered if you or perhaps the Cabinet Secretary could tell us how we could improve on that, because if the data's there, we ought to at least give it to the person who's sitting on that piece of land.

Well, indeed, and it's worth reflecting that there are parts of this we can do through the SFS, so actually having that evaluation as part of the universal layer, so that every farmer who enters the scheme will have to do it as a step forward in itself, it really is. And then, actually, working with that farmer as part of the advice and support that comes also within the SFS design will help with that.

It's worth reflecting, though, that there are also farmers who do their own private soil analysis and so on, and, for them, that's fantastic, that's really great to do. But I think the SFS will allow us to do much more on this and engaging with the farmer. The whole basis of the SFS has been based on not doing to, but doing with the farmer. But having the knowledge of what your soil is is the starting point, and then feeding back and saying, 'Right, we've got options here of how we can maintain the quality of the soil, improve elements of it in the way you manage it as well.' But, yes, SFS is designed to work with the farmer and share with them this data. I think, probably, it's reflecting past practice as opposed to what we're going forward to in the SFS.

Did the question specifically focus on the wide range of the ERAMMP data and the soil policy evidence programme data in their evidence submission?

Yes.

With that, they've got a fair point, because this is complex, and some of the information I don't quite understand. I've been doing this for 15 years, and I have to go to a soil scientist and understand what's happening. But I think that there are levels with this, that you've got that data coming in, you've got, in support of the work we've been doing with the production of the soil policy evidence programme, a whole range and raft of reports on every subject you can think of. That then is distilled further into the Welsh soil evidence review. So, all of those reports, all of the ERAMMP data are distilled into a series of key messages and a summary document. And that’s been distilled further into the agricultural soil policy statement.

We also work with Farming Connect—ERAMMP and ourselves do. ERAMMP is a separate team; I am responsible for the soil policy evidence programme. And that information is being built into Farming Connect too. So, how do we get that science, that technical data, into these key messages, distilled and sent to the industry, and also in the knowledge transfer arm of the Welsh Government? So, I think there’s a layered approach to it.

And then, you’ve got farm data. One of the problems in the past is that soil testing results were never shared with the Welsh Government, or they were in a paper format, and it was very hard to get all of that data, and rationalise it, and put it into a digital format to be able to use and interrogate. But, hopefully, as the Deputy First Minister is saying, we’ll have a step change in that, if that is agreed and taken forward through the scheme, because that can be supplemented into the ERAMMP national data, and we get these national trends, and we can start looking at local specifics on what’s going on, and then be able to shape future interventions and policy, the knowledge transfer offer, and the range of actions that the SFS will inevitably evolve into.

If it’s of any help, we can share more of this information with you, but also, if you or your officials, your clerking team or whatever, wanted a dedicated technical briefing on this, because there’s a hell of a lot there.

Yes. Let's move on from the technical stuff. Just briefly, moving back to a policy issue, Rhys Evans from the Nature Friendly Farming Network suggested that we needed to link universal action 3 to universal action 1 and 2 in order to strengthen the emphasis on the importance of soil health, to ensure that people were not just testing it, but also getting the training they needed to know what to do about it. 

That thinking is already going on, before we land the final SFS design. But it’s more than that as well. So, it's the knowledge transfer, the sharing of information, the sharing of best practice. I’ve stood on farms, and farmers have said to me, ‘I don’t understand why my next door neighbour doesn’t do what I’ve been doing. I’ve been doing it for years, and the soil carbon is great, the invertebrates within the soil is fantastic, and I do x, y and z’. So, part of the SFS is actually linking these bits up, so it’s not individual elements. I can understand that, from some outside, before we land the whole thing, they might perceive it as just pick and choose. It’s not. These things are linked together.

But we can also do more within the SFS. Already, we’ve got a range of proposed measures, such as the integrated pest management plan, habitat management actions, capital support for tree planting and hedgerow creation—all of these support multiple benefits, which include improving soil health. So, they need to be pulled together. But we can also go further than the universal actions as well, because, as we develop, as we’re currently doing in live time, the collaborative and the optional layers, we can look at—. For example, one of the proposals is capital funding within the optional layer on the improved soil health and multispecies crop cover theme. These start to, then, tie together. It will be a step change at the universal level—and I think it’s important to say that—in the testing, the dissemination of information, using that information to improve soils, simply as a point of entry to this.

But above and beyond that, we can do even more. And you are right in what you’re saying. The point is well made; these pieces need to be seen as part of the ecology of the farm, not one individual element.

Thank you. I think we need to move on; I can hear the Chair wanting to move on. I want to focus on the best and most versatile agricultural land. We heard evidence from Professor Bridget Emmett from Aberystwyth University that prime agricultural land is being lost to urban expansion. We’re talking about the 10 to 15 per cent that is most likely to be of use for growing food, either cereals or vegetables. And it is pretty terrifying if the planning system isn’t robust enough to protect that from the developers. 

Thanks for that. We saw that evidence, and we think there may be an element of confusion of apples and pears and what different things are doing. There’s a difference between the way that land is classified for ERAMMP reporting—. ERAMMP is reporting on land use, not land capability—the ability to grow a wide range of crops with consistent yields.

Fr example, a field, as I've mentioned before, may be really good at growing grass and really fit for purpose with that, but it may not be capable of much else. ERAMMP classes this examples as productive land, but the ALC system does not. So, if you're looking in at this from the outside, you might look at those two and go, 'Hold on, what's going on here?' Well, ERAMMP categorises grass pastureland as productive land, the ALC system does not. 

Our take on this is that we strongly believe that the existing measures are not just strong but they're actually the strongest in the UK. And it's supported, by the way, by things like the Soil Security paper in 2022, which described Wales as being set apart from its neighbours, where the primacy of ALC and BMV land has been maintained.

But there is more that we can do. We've taken steps over the last seven or eight years to reinforce this policy, both through the production and the publication of the predictive ALC map—. This is a piece of work that we are leading on. England isn't there on this yet. So it's a predictive ALC map, which is the first update since the 1970s. We've also strengthened this through the chief planning officer circulars as well.

But the trends are really interesting. If you go way back to the pre-second world war years, up to 2010, 2011, there was something in excess of 21,000 hectares of BMV land lost. We've got a strong regime here, but we do need to reassess BMV land loss since 2012, following the most recent set of local development plans and the most recent urban data sets.

But to come back to the point I started with, given the strength of the policy here and the fact that others have said that this is a stronger policy than elsewhere, we don't think that the loss of BMV land will be significant, but there is that confusion about a bit of apples and pears here.

Right. But, nevertheless, there is a housing development in the Radyr area, which Abi Reader mentioned in her evidence, where really good agricultural land was then built on. Is Cardiff Parkway in this category? Your predecessor always said that she would protect grade 1 and 2 land. She didn't used to mention grade 3a and, looking at the bar chart, that seems to be the majority, grade 1 and 2 seems to be a tiny part of the land surface. 

I'll bring in James now, but just to say that I don't want to comment on individual ones that are going on.

Okay. Perhaps you could write to us.

However, it's worth commenting that local authorities are now producing themselves dedicated BMV evidence papers. They're acquiring ALC surveys and soil management plans. This is a heck of a contrast to where we were even five years ago. This is the Welsh regime. I don't want to comment on individual ones, but I don't know, James, if you want to come in.

Yes, I'm happy to. This goes back to 2010-15, where BMV wasn't being considered at all within the planning process. So, we put in a package of measures. That started with the predictive ALC map, because to make decisions, you need to know what is where. That came in in 2017, just before the last round of local development plans. We had particular issues in the Cardiff area, and planning inspectors were saying, 'Well, how can you expect a developer to conserve BMV when they don't know where it is?' So, the predictive map now means that there are no excuses, because our standing guidance is that you take the predictive map grade, unless you get a survey. If you refuse to do a survey to confirm that grade, the local authority and the planning inspectorate have to go with the predictive grade. On the housing, I can't comment on that—

Okay. We understand that; what happened in the past we can't change. 

—but it might have been part of that. But now, moving forward, the change is, as the Deputy First Minister said, every local authority now is starting to produce, as they renew their LDPs, dedicated background papers, because the key in avoiding BMV is not to not place a housing site there, it's to take account of it in the spatial assessment. When you're looking to grow settlements and add new settlements, your spatial assessment is key, because if you choose a BMV area or an area with a lot of BMV, you've already made that choice that it's going to be developed in the future, to a certain extent. And then to fight that through the planning system and make that local authority go back to the drawing board is a hard process. So, upfront information is key.

Looking at today's level of rigour in the local development plans, can you categorically say that no best and most versatile agricultural land will get hijacked for other purposes, particularly in areas around Cardiff, for example, where all the housing developers want it? 

No, because BMV planning policy is not an outright ban on development, but it has to leap some very high hurdles. So it's not an outright ban because there are always tensions between development and other aspects, but what we can say is that the planning policy seeks to preserve BMV land as a finite resource, because we know it is, for the future. It also puts considerable weight on protecting such land from development because of that special importance. This scope and the importance of this policy is clarified in a 'dear chief planning officer' letter where it states that unless other significant material considerations indicate otherwise, it will be necessary to refuse permission. So, these bars are high. And we're ahead of the game, it's worth stressing as well. We think that we've got a really robust regime, and there have to be darn good reasons why somebody would say that the best quality land needs to be developed.

My second and last question is around the agricultural land classification system, which FUW describes as a blunt tool for determining appropriate land use at local scale. They particularly raise the issue of tree planting for development, and that it's such a moving feast because of climate change, which is obviously affecting the vulnerability of particular parcels of land. So, I wondered if you could just comment on that, as to whether we've got this right. As you say, even you don't seem to be completely clear as to exactly where the land we really do have to fight for actually is.

I dispute it being a blunt tool or that we don't already have a good idea of what land is what—we just have different tools to do slightly different things. The ALC is not a blunt tool, but it's got a very specific function, because the agricultural function of soil is one of several considerations in the wider planning context and the wider planning balance. What the ALC does quite cleverly is it takes, as we're getting from this conversation, a very highly technical set of data, and then can present it in a very clear picture of land quality from best to worst in colour-coded grades. It makes it easy to interpret for non-specialists, but that wraps up a lot of complexity within it. ALC is just one of our tools that we can use for ecological or agricultural function.

We have, by the way, invested something like £150,000 now in reviewing every technical aspect of that system on behalf of England and Wales, and we're doing that on behalf of the Welsh Government and the Department for Environment, Food and Rural Affairs because we're leading on this. We've actually begun this week, I think it is, updating the findings of that review to fully update the ALC, so it's futureproofed for the next 20 or 30 years as well. But, James, your head is deep in the detail of this, is there anything you want to add? 

I live and breathe it, and dream it—

We'll have to move on. We're going to run out of time otherwise. If I could ask Sam to come in. 

Thank you, Chair. Good afternoon, panel and Deputy First Minister. In previous evidence sessions, we heard from one academic who said that soils in Wales are net emitters of carbon. That was asked by a previous panel for us to further scrutinise, given the Climate Change Committee's most recent report. What's your understanding of soil and carbon, and then the role of the SFS within that? 

It has a role, and I'm very pleased that, as part of the SFS, we actually looked into this in quite some detail. We've published the findings of the group that looked at carbon within soil. From our perspective, what we know—I touched on this at the outset—is the majority of our soil is pastureland, and it's good-quality pastureland that's well maintained. But we do know, as we face this dry season now, that it can have a real impact in terms of carbon that's stored and carbon emissions. So, the degree to which soil can actually help with carbon sequestration varies, but it also can be quite limited, the additional scope that you have.

Sorry to cut across you there. Is it a case of ensuring maintenance of the carbon that is sequestered within soil, rather than looking at sequestering additional carbon within soil? That's not an oversimplification of it. 

No, no, that's helpful; not a simplification, but putting it in broad terms, yes. If we maintain our soil very well, we know it's got a carbon benefit for sequestration. There's a limit to the extent to which you can suddenly do a step change in that, and it also balances against other things you want in the quality of that soil, to do with invertebrates and wider ecology as well. But we know that good, well-maintained soil locks in carbon. It's just that there's—. Different from other mechanisms like, I don't know, woodland planting or other, there's a limit to which you can stretch that within soil. It's also a living, breathing thing, and it's affected by climate change, so this can vary over time as well.

Okay. And we've heard from some witnesses—the Farmers Union of Wales—describing the soil carbon credit market as the 'wild west'. Would that be your analysis of it, and what is the Government's role within this, more broadly?

Well, I think it's right to be cautious about some of the schemes that are out there, not just within soil carbon sequestration, but also on the wider piste. One of the things that, as you know, we did—I think it was last November, certainly last autumn—is we consulted in Wales on the principles of sustainable investment behind ethical investment to the very highest standards in terms not only of carbon, but also biodiversity as well, because we have to be wary. It's not that I would describe it as the wild west—other people have used that phrase there—but we certainly know that there have been schemes before that have found themselves undermined: when people look at it in detail, they say, 'What are you really adding here, beyond what's already there?'

Okay, interesting. And then a final point around the recycling of organic matter into our soils and the reduction of the use of artificial ends, fertilisers. What are your plans in this? Because we've heard evidence around how actually the nitrate vulnerable zones, the water regulations, could actually have a detrimental impact on soil quality, given the timings around the spreading of it. So, getting more organic matter into the soils, how's the Welsh Government addressing that?

There's potential within this, but, again, it does depend on the individual farm and the soil itself within particular locations. So, for example, things like compost from household carbon waste collections, I've come from a meeting earlier on on a very different, actually to do with—. It was a water summit. We actually had it at a venue where they did the collection and the reconstituting of carbon waste for farming and other uses. So, we know there are benefits to this, and it's particularly true in arable and organic systems, but it will depend—let me make it clear—on the quality and the quantity of the material that's available, and that is crucial, because you do not want to be adding—we've got some farmers in the room—stuff in there that is to the detriment to your soil, it's the wrong mix and so on there. So, it'll be down to material testing at a local level, subject to regulations and quality standards. Local authority material that comes through this route, for example, does have a degree of certification to ensure that the material meets quality standards for safe use, including on agricultural land, but it has to be horses for courses, and the right application in the right place.

The other thing that's worth saying is that the latest data that we have, Sam—it's a few years out of date, but—it suggests that this sort of material probably represents only around 1 per cent of the organic materials applied to agricultural land coming from these sources, so we're probably talking about material, the reuse of composted materials, of probably 1,000 to 2,000 hectares in total.

Okay, because there is a good example, and I heard Sam Carey, who's a farmer in north Wales, at Sealands farm in Bridgend, which I believe is your constituency, Cabinet Secretary, give a presentation on what he's doing within a formerly quite poorly managed dairy farm in north Wales, as a new owner-tenant, mob grazing, intensifying the dairy cattle in one area, so the organic matter is recycled, brought back into the soil in quite high quantity, and then that rejuvenates the soil. So, there are good examples out there, aren't there?

So, the point is: how are we looking at making sure those good examples—? And you've used the sort of discussion group models and what the SFS can do about neighbours learning off of each other, but there must be a little element of formalising of that, because anecdotal sort of, 'Hey, here's what I do next door,' isn't going to cut it when margins within agriculture are so fine to start with. There's got to be some legitimacy and some science, evidence, et cetera, to back this up. So, within the SFS, what are you looking to do? We've heard about universal action 3, I believe, that looks around this, specifically the professional development element of the SFS. So, is that—

You've answered my question.

Is that it? Is that what you're looking at as the vehicle for this?

It's that and more. So, there are elements within the SFS in the universal layer, which are to do with—. I'm trying to strip this away from business management terminology, because we need to land this in a space where the language also works for farmers, so, when you talk about CPD, farmers go, 'What?' Not all farmers. But when you do talk about learning from each other and actually mentoring, as in sharing good practice, those are being locked in now to the universal layer.

By the way, a lot of the discussion we've had has been very much on this thing: what's the practical application that would be of most use to farmers in things like soil health, in the sort of innovations you're talking about, that would enable it to fit within this? So, you haven't got a top-down scheme that says, 'Here's your menu of prescribed options from the Minister,' it's more to do—. We're trying to design it in a way with farmers and environmentalists that says, 'Here are things that are already going on that could feature within the professional development, within the mentoring,' so it's much more systematic, Sam, it's not ad hoc.

Helpful. Thank you, Chair.

Jenny.

Thank you. NRW's SoNaRR reports have highlighted limited evidence to assess how land management changes have impacted on soils. Some people are calling for soil carbon to be assessed to a minimum of 30 cm, but Northern Ireland's CAFRE is in the process of measuring all land down to 1m, so that you can get a much more longitudinal survey of the impact of different influences. What is the Government's view on how we might be able to see a much more nuanced approach to what improves or has a detrimental impact on soils, given that there are so many different variables in these?

There are different variables, and that's why we think what we've got is a good approach to soil monitoring evidence in Wales, but it's based on what we need to monitor and evaluate and then take actions on. But I'm interested in the depth one, and I might ask James or colleagues to come in in response to that, how deep you go within the soil. But we've got a set of soil indicators through the ERAMMP national field survey. I've been out literally in the fields with people watching the work they do. It is cutting-edge stuff. It is, by the way, a survey that other nations are only now catching up on. They're keen to learn and work with us.

But you are right in saying, as we've discussed here today, soil is actually constantly changing as an ecosystem. So, I do recognise the need to adapt as we get new pressures and new threats to soil health there. So, what ERAMMP is now doing is working with a range of partners, developing an indicator framework for sustainable land management, SLM, and we expect this framework to include, now, soil health indicators. That will then inform the future SLM monitoring programme that goes forward from where we are now. As this goes forward, we will review the survey design, the coverage, the statistical power behind it, and we will also monitor, by the way, coming back to the earlier question, the best and most versatile agricultural land lost as part of that piece.

We also, of course, Jenny, as you know, monitor peatland restoration, we estimate carbon and emissions and recovery, and, quite soon, we're going to be trialling a really interesting piece of work here, bare soil monitoring—so, bare soil monitoring across Wales using satellite imagery to assess the risk of bare soils to water courses, and how it might be used both to report on soil health and to target future SFS interventions. So, what my argument would be is you can always do a hell of a lot more and throw a hell of a lot more resource and do something comprehensive, crossing every t and dotting every i, but, actually, what we've done is something very bespoke to the purposes we're trying to fix and the outcomes that we need to achieve and what we need to monitor. But, James, I don't know if you have any thoughts on the soil depth thing, which is quite interesting.

Yes, it is interesting. This has been a long-standing request from multiple stakeholders and policy teams. My understanding is that, as part of this wider SLM indicator review, they will be reviewing the depth to which they go and whether or not 30 cm is required. Of course, there's going to be a lot more expense with that—

Well, in Northern Ireland, they've developed a tool, so you don't have to dig a massive hole, you just tunnel.

No. They've cored it and taken it, but then it's—

So, I'm intrigued just to know why they decided that 1m is going to give them a lot more and better information.

It will, because the top 15 cm is within the plough range. It's also because soil breathes, so that carbon is stored, probably, as organic matter rather than a mineral form. So, if you've got drying and warming, the bacteria in that soil breathe, they let off more carbon, the carbon goes down if you plough it. And if you plough it, you might be going down to 25 cm or 30 cm. So, it can be in quite a bit of flux. And the interesting bit about below that point is that you might have carbon stocks stored in there that are a lot more stable; they give you a clearer direction. So, there's always a trade-off between the budget to do as much as possible and how far you go to look at that wider soil piece and those trends.

Okay. Well, perhaps you could send us a note on what does Northern Ireland think they're going to get so much benefit from that they are investing all this time and—

And it may reflect the characteristics of their farming as well. So, when I say that we've got a Wales approach, a lot of that is based on that we have the arable, we have the peat, but we also have that massive pastureland—slightly different in characteristic, I suspect—but we'll try and find out, and engage with Northern Ireland colleagues.

Okay, thanks.

Just on agricultural land classification, we go down to 1m 20 cm, for ALC assessments, because that's usually the routine depth for cereals and grasses. So, you need to look at the top and the bottom to make sure that you understand how that crop responds.

Thank you, James. Hefin.

Diolch, Cadeirydd. Can I ask the Cabinet Secretary what current opportunities are available for farmers to upskill on soil management? Are there further plans to do so? And to what extent can soil management be part of the continuous professional development universal action plan of the SFS?

Yes, thanks, Hefin. And yes, this is part of the SFS as we're taking it forward. But there probably is also more that we can do, particularly with Farming Connect in particular. So, we've got an extension to the current service, which goes through to spring 2026, which will be needed to ensure that we've got continuing support and provision through the introduction of SFS into 2026. So, that's a decision that will need to be made. I can't pre-empt a decision on the details of what that will be, what the new contract might look like, because this will be subject to the outcomes of where we get to with SFS and me then signing off on, 'This is what we now need to do.' But I can tell the committee that enabling farmers to maximize the benefits from SFS in line with the discussions we've been having and the sustainable land management objectives will be core to the work of Farming Connect and their support of farmers.

Okay. We heard that soil monitoring data is not being communicated back to farmers to improve soil management. Do you agree, and, if so, what needs to change? 

Yes, going forward—. Well, yes, I think in response to previous questions, we've very much acknowledged that it's not only the evaluation and the data, it's then what you do with that and how you share that on an individual farm, back with the farmer, but also with other farmers who can learn from that as well. So, we're keen to do that, but I don't know, James, if there's anything you want to add to that.

Farming Connect already offer a range of mentorship masterclasses and learning groups. And it's how that information, then, is also shared and how those groups, then, are taken forward in the future to share that best practice more widely across the sector. 

So, Hefin, if it's of any help, we've got some of the stuff already on the ground happening, which will lead us into the SFS. So, for example, within the farms network programme, we've got showcases with farmers of how to improve soil health, which cover 40 projects and bring all the knowledge together. So, within that, we have things such as nutrient management plans, baselines for 15 demonstrator farms. We have the Welsh soil project, which is 40 farms, or just short of, soil sampled for the project in the current programme. They look at carbon stock, bulk density, nitrogen and other things. We've got multiple events, just short of a score of events, under the Our Farms network workshops there, which have been delivered with farmers, with a focus specifically on soil health. We've had over 400 people attending those. This is big stuff there. We also have an app—sorry, I don't know if the committee has come across this in the evidence—it's a soil health Farming Connect app to help inform as well. And we also use Agrisgôp, which is a scheme that brings ideas into action. Basically, it's an expert group of farmers, leaders, coming together, finding solutions to challenges on soil health by sharing their experience, their ideas, their knowledge, and finding solutions. We do masterclasses, we do mentoring now, and that will work its way, then, into the SFS going forward.

I think the point that Hefin was making there was the evidence—and correct me if I'm wrong, Hefin—that we received from Abi Reader in the last session, where she talked about the overland maps that show water rates and flow rates that go across the land. She said that she'd had sight of these maps that are in possession of the Welsh Government, found them very informative, but as a rule of thumb they're not shared with the industry or individual farmers. We'll follow that up with a written note to make sure I've given you the correct explanation, but that's my understanding of the type of information that she was highlighting that the Welsh Government are in possession of but isn't shared with farmers that would help them manage their soil.

Is there a soil functions map, then? No?

I think the flow path mapping—it's something that Northern Ireland have done and they've shared through their rural payments version online, so farmers can see that risk through the farm. It's absolutely fantastic. As part of the bare soil monitoring project, we are looking at whether we've got the data sets in Wales to make that feasible. I'm not aware of Welsh Government actually commissioning anything specific and it being produced, but I have discussed with the sector assessing whether we can do it as part of this project. Because when you're looking at bare soil and its risk to the watercourse, you need to know where those flow paths are, you need to know where the hedges are and vegetation is that will intercept that soil and that flow. So, we are hoping to be able to do it, but the key question is whether our LiDAR, our terrain data, is good enough. That's the key question, and we'll have a play around with that at the moment; the teams are working on it at the moment, as we speak, in fact.

Okay. We'll follow that up, we will, because it was a point that was introduced in the last session. Hefin, have you got anything else you want to say?

Nothing else to say.

Thank you, Hefin. Hannah.

Diolch, Cadeirydd. I'm going to turn to cross-compliance and national minimum standards now. During the Agriculture (Wales) Act's development, Welsh Government highlighted that some EU rules to protect soils are missing from the regulatory baseline, post EU exit. Are there plans to reinstate these rules as part of any national minimum standards?

Hannah, a fairly straightforward answer, I hope, to this question. The GAEC 4 and 5 are expected to be included within the SFS scheme requirements. There's no reduction in controls from the current cross-compliance regime, but my officials are also working with the stakeholders on the officials group of the SFS, looking at possibly strengthening the protection of soils from inappropriate practice. So, yes, we're keeping where we are now, but we could actually do a bit more as well.

Thanks. It's good to have a straightforward answer as well. If I turn to the legal framework and targets for soil health, to what extent do you believe an overarching legal framework with statutory targets is needed on soil health in Wales, and is this something that should be a priority for the next Government?

We believe—and I hope we've put a fairly compelling case here, and we're keen to engage more with the committee if the time has been short today—that the current approach we've got with the soil indicators is the right one for what we're doing in Wales. Our monitoring and our indicators are tailored really to the needs of us here in Wales. So, this is a very cost-effective and very responsive way of targeting and exploring and responding to our issues and our trends here and our type of farming and land management.

The practicality of statutory targets and determining what we are measuring against a healthy soil, bearing in mind the complexity of our discussion this morning, makes this fraught, I have to say, with challenges. The challenge comes from the different capacity of different soil types to deliver different ecosystem services within climate and land use constraints, and I have to say the requirements of different stakeholders as well. So, there is, just out of interest for the committee, a very insightful paper called 'Developing a multifunctional indicator framework for soil health', which sets out the full range of issues in developing targets and the challenges, and we'd be happy to share the link with the committee.

Thank you, Deputy First Minister. We look forward to it.

May I just come in on that point, Chair?

Yes, by all means.

That paper was produced by Professor Hannam at Cranfield University, and Cranfield University have the national soil institute for England and Wales. It's where all our soil records and surveys are kept, and if the committee ever get a chance to go across to it, it's the most fantastic set-up. There are other universities available, but the actually archive is amazing—it's all samples from all over the country—but also the farm practice set-up, with big sheds that they can test machinery in and the impacts on soil. They can do rainfall simulations, they can do gas fluxes from agricultural land from different treatments. It's absolutely fantastic and it's well worth visiting, if you do get a chance, as a committee, to do that.

Thank you. Hannah.

Just one final question from me, Chair. Our understanding is that there isn't currently a Welsh Government strategy for organic farming. Is there an intention to produce one?

We don't currently have any plans to write a strategy for organic farming, and to be fair to my officials and what we're doing, we're probably up to our eyeballs at the moment in doing various other elements we've discussed today. I'm not ruling one out, it's simply that, at the moment, Hannah, the simple answer to your question is, 'No, we don't.' But that's being factored into the work that we're doing in the wider sustainable farming scheme, so that we do support the needs of organic farming in Wales. We regularly attend meetings of the Welsh organic forum to understand what they need, the challenges and opportunities in the sector and feed back on Government policy. That's shared across my officials. And we still have in place, of course, the organic support payment. It's been a source of support for many organic farms, following the end of the Glastir organic scheme. So, we're really focused on that sector, but producing a strategy is not on our agenda at the moment, I have to be honest.

Okay, Hannah. Jenny.

Linked to that, the NFU evidence was kicking back on the control of agricultural pollution regulations on the grounds that it's actually a perverse regulation that forces people into using artificial fertilisers, rather than the organic fertilisers that are available on the farm, and that the weather is a much better guide as to when is the best moment to spread, rather than the time of the year.

Rather than the calendar month, the condition.

Sure. I absolutely get it.

If you want to become an organic farmer, you're obviously going to be attracted by the possibility of being able to say goodbye to artificial fertilisers, as long as you can use the organic ones to the greatest effect.

Listen, I think Professor Susannah Bolton's work, actually, looking at a review with a very independent eye on the future of the regulations to avoid agricultural pollution of our watercourses and so on, and to avoid soil run-off, because we've talked all day about it—it's a precious asset; we don't want it in streams from the rivers and so on, or any pollution in there—. We're keen to take that forward at pace and with urgency. She's identified within it some short, medium and long-term things, but there are some complex areas, including that, that we need to properly work through, not to just leap at it. But we're keen to explore that, because I think that something that has more of a targeted approach, something that can work with those who are in the organic sector, and also those who deem themselves to be, if you like, within a broadly regenerative space, including regenerative dairy, but there'll be others as well—. We just need to get that right and work through what Susannah Bolton has brought forward. But I think that gives us a platform and an opportunity now to think seriously about how we address what is a challenge, agricultural pollution, and soil loss.

I'm a paddler. When you go to the Cleddau, and you look at some of the work that's being done there, for example with oyster seeding, it's not the pollution that's causing the problem for the oysters, it's them being buried with sediment run-off, with soil. It's good soil. So, we need, in your inquiry, to look at all of these things. The quality of the soil and not losing it—not losing it—which is why our bare soil analysis, using satellite technology, I think, has some real potential as well.

Thank you. I look around the room, there's no further—. Sam.

I've got a very quick question, and I know this is somewhat separate to the remit of this committee, but it is important in the context of the inquiry around soil: the other industries involved with soil use and land use. And I think of house building, and it's been touched upon in other sessions. But the Welsh Government's policy around house building and the reuse and recycling of soil, knowing that certain soil types can't be mixed, for a host of different reasons from my very limited agronomy knowledge from being a cricket groundsman and a farmer's son—. When it comes to the house building targets the Welsh Government sets itself, and inevitably that's going to be on green belt areas to try and match these targets, how, then, can the soil be managed to the best of its ability, reused, recycled and not lost, when at the same time advocating for a high house building target? 

That's a really good point, and this is the tension between different policies that Governments always have to reconcile. I go back first of all, I have to say, to the point of where the Welsh planning policy on this is, which is that we shouldn't be—. The default position is we should avoid actually using the best productive agricultural land, and we know where it is and there's clear guidance around that. The use of the soil, though, is an interesting point, because rocks and soils currently qualify, of course, for landfill disposals tax, but if it's really good-quality soil, I think your point is—