For the first time, the government is consulting on a Land Use Framework for England. It’s an important step, but there’s a long way to go.
By George Monbiot. This is my response to the government’s Land Use Consultation, sent on 23rd March 2025.
The Consultation document can be read here, and its Analytical Annex here. You can respond here. I strongly urge you to do so, as the opportunity might not arise again. The Consultation closes on 25th of April 2025.
QUESTION 1: To what extent do you agree or disagree with our assessment of the scale and type of land use change needed, as set out in this consultation and the Analytical Annex?
While I strongly support the principle of land use change, the proposals here are contradictory, insufficient and in some cases impossible to follow. In this and the other answers, I’ll group my responses by sub-topic.
Sub-Topic A: Even at the level of simple arithmetic, the assessment makes no sense. It cannot simultaneously be true that 1% of farmland amounts to 50kha, 4% to 370kha, 5% to 430kha and 9% to 760kha.
Similarly, it is hard to reconcile these statements, both in the Analytical Annex:
- “England is made up of a mosaic of different land uses, with two thirds of its area (67%) being agricultural while built-up areas take up 11% of land”
- “Urban areas made up 15% of England’s land cover in 2011, the most recent year for which this statistic is available.”
Sub-Topic B: More importantly, the proposed scale of change here takes us nowhere near the government’s aim, repeated in this Consultation, of “effectively conserving and managing 30% of the UK’s land by 2030 (30by30) to support delivery of the Environment Act biodiversity targets”.
According to the government’s policy paper “30 by 30 on land in England: confirmed criteria and next steps”, so far only 7.1% of England meets the criteria for the 30 by 30 target. Other estimates suggest that even this dire figure is inflated. For example, Wildlife and Countryside Link puts the true figure at 3%.
Even if all the land whose use the Consultation proposes to change contributed to the 30 by 30 target, this would add just 12.7% of total land area to the 3% or 7% that currently meets the criteria. And – please remember – 30 by 30 means 30% by 2030, not by the target date of 2050 used in this Consultation. So, even with the most generous possible interpretation of the current status, this is far too little, far too late.
To make matters worse, it is hard to see how the limited land-use-change ambitions of Category 2 and Category 3.1 in Figure 4 of the Consultation could truthfully be counted towards the 30 by 30 goal. They clearly do not meet the government’s “30 by 30” Criterion 1. They are also unlikely, in many cases to meet Criterion 2 or 3. The same is likely to apply to much of the land use change in Category 3.2.
A far more ambitious strategy, focusing in particular on upland areas currently used for low-value grazing and grouse shooting, could help the government meet its 30 by 30 goals, but it would have to be very quickly formulated and implemented. The clock is ticking!
Sub-Topic C: Also plainly incompatible with the 30 by 30 commitment is the restatement in the Analytical Annex of the previous government’s woefully unambitious biodiversity goals, namely to “Restore or create more than 500,000 hectares of a range of wildlife-rich habitat outside protected sites by 2042”; “Halt the decline in species abundance by 2030”; “Improve species abundance so that by 2042 it is higher than in 2022 and at least 10% higher than in 2030”; “Reduce the risk of species’ extinction by 2042, when compared to the risk of species’ extinction in 2022”.
There is no way that these feeble goals can be reconciled with the ambition of 30 by 30. Again, the timelines are also out of synch. Nor do these goals rise to the challenge explained in the foreword to this Consultation: “On the ground, our natural world is under threat, with England now one of the most nature-depleted countries in the world.”
As those feeble goals were introduced by statutory instrument, they could be swiftly changed by the same means, to bring them into line with the 30 by 30 objectives.
Sub-Topic D: This leads us to an even greater deficit in the Consultation: the exclusion of the great majority of land in England from the Land Use Framework. The Consultation covers only 19% of the agricultural land in England (which amounts to 67% of the total land area). This means it opens up the possibility of change on just 12.7% of England’s land. It excludes large areas crying out for change, such as those used for grouse moors, pheasant shoots and most of the very unproductive grazing land in this country. In other words, the government has, in effect, made a decision over 87% of the land in England (a decision to retain business as usual) before such a decision has been considered, discussed or consulted upon. This is bad policy, and contradicts the democratic spirit in which the consultation has been launched.
QUESTION 2: Do you agree or disagree with the land use principles proposed?
Sub-Topic A: A proposed Land Use Framework is in itself a very positive development, and in principle creates a means by which rational and strategic decisions can be made. The five land use principles proposed – Co-design, Multifunctional land, Playing to the strengths of the land, Decisions fit for the long-term and Responsive by design – are fundamentally sound, but they should be applied by default to 100% of the land in England, not just to 12.7% (see Q1 above).
Sub-Topic B: On the issue of Co-design, there’s a concerning passage in the Consultation document: “Policy decisions that impact how land is used are often far too remote from the lived experience of farmers, developers, planners, and the citizens whose work shapes our places and landscapes.” While this might be true in some cases, the vast majority of people who live in, visit and value the countryside are neither farmers, developers, planners nor shapers of the landscape. Policy decisions tend to be even more remote from the lives of these people, the great majority. Decision-making should be open to everyone. Currently, landowners enjoy enormous decision-making power, in some cases over thousands of acres, and often at the expense of other people. The government should be seeking to balance and moderate this power, not increase it.
Sub-Topic C: Alongside these principles, we also need a better categorisation of land uses. The consultation recognises only three: “agricultural, non-agricultural and urban”. When something is defined in the negative it is often treated that way. We need to break down and redefine the “non-agricultural” category, and set clear objectives for its use, such as “ecological restoration and protection”, “natural flood management” and “forestry” (these categories might not be exclusive).
QUESTION 3: Beyond Government departments in England, which other decision makers do you think would benefit from applying these principles?
Yes to these proposals:
Combined and local authorities (including local planning authorities)
Landowners and land managers (including environmental and heritage groups)
Sub-Topic A: I would like to see these principles applied by all the groups mentioned, including landowners and managers with 100ha or more. There should be greater public engagement in land use decision-making, which often has a critical impact on local people’s quality of life.
Sub-Topic B: As for local and combined authorities, their capacity to apply these principles is greatly hampered by funding cuts. The same applies to the agencies that will be crucial to delivering this agenda, such as Natural England, the Environment Agency and the Rural Payments Agency. They have already been bled white by cuts, and now are being instructed to reduce regulation even further, while placing economic growth at the centre of their missions. That is incompatible with many of the aims and principles of this Consultation.
One of the dangers here is that if regulators do not have the capacity to monitor and enforce, especially in the field (rather than conducting the preposterous “desk-based inspections” now used as a substitute for genuine monitoring), the new policies proposed here will be a dead letter. They might be honoured on paper, but there is likely to be little connection between the forms filled in and the reality on the ground.
The Consultation paper correctly states that “investors, farmers and other businesses want certainty” about government policy, and “a more joined-up, strategic approach to land use strategy and planning”. But certainty and joined-up strategy require robust, well-funded agencies and authorities.
QUESTION 4: What are the policies, incentives and other changes that are needed to support decision makers in the agricultural sector to deliver this scale of land use change, while considering the importance of food production?
Sub-Topic A: We need a strong, sustained and reliable financial and regulatory incentive, in areas that are poor for agriculture, especially in the uplands, for farmers and land managers to take land out of food production and use it instead for the restoration of ecosystems. As the National Food Strategy points out, much of this land produces negligible amounts of food, while its production inflicts a very high, disproportionate amount of ecological damage. Upland sheep farming in Britain numbers among the global land uses with the highest ratio of destruction to production. It accounts for a truly minuscule proportion of our food supply, while occupying and depleting vast areas that would be better used to redeem the country’s extreme nature deficit, and to meet the government’s 30 by 30 goals.
Sub-Topic B: Where agricultural land is fertile and productive, we should focus on ensuring it produces food for humans, rather than being diverted into other purposes. By far the most effective way of optimising the use of fertile land is to switch towards a plant-based diet. Globally, a plant-based diet requires 76% less land than the current average diet. In the UK, as the Consultation paper points out, 85% of our farmland is used for feeding livestock, either through grazing or through arable crops used as feed. This is a highly inefficient way of using one of our critical resources.
There are currently no government policies aimed at encouraging people to eat fewer livestock products. In fact, there are public bodies, such as the AHDB and Quality Meat Scotland, actively encouraging people to eat more meat. It’s as if public bodies were telling us to burn more coal. This should be stopped immediately, and a public information campaign launched, explaining the great environmental impacts of producing meat, milk and eggs, and the environmental benefits of reduction.
There is no good way of producing animal products at scale. Either livestock are reared intensively, which inevitably causes severe ecological damage to – and sometimes ecological death of – our rivers, as the throughput of nutrients from intensive animal farming is more than catchments can absorb. Or they are reared extensively, in which case very large areas of land are required (far more per kilo of produce than is required by intensive production), creating a massive ecological and carbon opportunity cost, as land that could otherwise have been occupied by wild ecosystems is instead occupied by pasture and grazing land much poorer in wildlife abundance, diversity, structure, function and biomass, and in organic carbon. According to the government’s Climate Change Committee, switching from grassland to woodland in England would eventually “increase the soil carbon stock by 25 tonnes of carbon per hectare” on average.
Through both public information and encouragement and financial and regulatory incentives, the government should seek to encourage people to reduce their consumption of animal products. It should also permit and encourage the development of alternative protein sources such as precision fermentation, which requires a very small fraction of the land, water and nutrients needed to raise livestock, and has the potential to provide far better and less processed alternatives to livestock products than those that can be manufactured from plants. The government should invest in research and development of alternative protein sources.
Sub-Topic C: For similar reasons, the use of productive land for growing biofuels should be stopped. The production of dedicated crops for biogas is especially damaging, as these often require high grade arable land. Among the most popular crops for biogas production are maize and potatoes, both of which severely damage soil. This is an extremely inefficient landuse. To give one example, to supply a biogas plant with a capacity of one megawatt requires maize production on between 450-500 hectares of land, according to an article (now offline) in Farmers’ Guardian. By comparison, wind turbines need one third of a hectare for every megawatt of capacity, or 1500 times less land.
Very large amounts of grain that could otherwise feed people are also used to make ethanol. A bioethanol plant in Hull, opened as a result of government incentives, uses, assuming average yields, 130,000 hectares of wheat per year. A report by Green Alliance shows that the food used to make the biofuels used in the UK could feed 3.5 million people.
Generally, liquid and gaseous biofuels have a higher climate impact than the fossil fuels they replace. There is no good reason to use farmland to grow biofuels. This would not happen at all were it not for government incentives. These incentives should be stopped immediately.
Sub-Topic D: A common argument is that farmers have no option but to sell some of their grain for animal feed or biofuels, as it does not meet milling quality. But this is partly because of the extreme consistency standards set by flour mills (and, for that matter, other processors). While good bread can be made from flours with a wide range of characteristics, the mills tend to demand an almost exact protein content, moisture content and Hagberg Falling Number, ensuring that very large quantities of grain eminently suitable for human consumption are rejected. Not only is this a terrible waste, it also ensures farmers are paid much lower prices for their produce. The flour mills possess a dictatorial power over farmers that would make the supermarkets blush. Government should be interceding in this issue, to ensure that as much produce as possible feeds people directly.
Sub-Topic E: Soil science remains woefully underfunded, yet many of the agricultural innovations we need can be delivered only through a better understanding of soil and soil-plant interactions. Government should be increasing the funding of research which could lead to less reliance on augmenting soil chemistry and more reliance on augmenting soil biology.
Sub-Topic F: As sewage sludge contains a wide range of pollutants, many of which are likely to be highly damaging to crop, livestock, ecological and human health, sludge spreading should be banned until waste streams can be effectively separated. Otherwise large areas of good agricultural land might need to be taken out of production, as they will become permanently contaminated.
QUESTION 5: How could Government support more land managers to implement multifunctional land uses that deliver a wider range of benefits, such as agroforestry systems with trees within pasture or arable fields?
Sub-Topic A: It is useful to recognise that most of what we call agricultural soils were originally woodland soils. There is some evidence to suggest, particularly through the work of Iain Tolhurst of Tolhurst Organics, that agricultural soils perform better when some of the characteristics of woodland (particularly litter fall) are retained or mimicked. This can be done by incorporating trees within the agricultural landscape (though it should be remembered that in the UK there are shading implications – shade greatly reduces the productivity of ground crops here) or by adding a small amount of woodchip (ramial or composted) at strategic points in the rotation.
Sub-Topic B: Trees within the farmed landscape offer the potential for ecological connectivity, permitting certain species to move between what would otherwise be isolated and fragmented pockets of ecosystem. But it should be remembered that sustaining woodland ecology requires actual woodlands, rather than just isolated trees or hedges, and the UK is highly deficient in such ecosystems. So in places where agricultural production is low, the emphasis should be on ecological restoration as an alternative to farming systems that cause a great deal of damage while producing very little food (in almost all cases I’m talking about extensive grazing). Please also see my answer to Question 10. In more productive landscapes, there should be more integration of trees.
Sub-Topic C: There is a major ecological difference between genuine wood pastures, of the kind you might find in Transylvania, and forms of silvopastoralism which involve straight rows of a single species cutting across ecologically-impoverished fields, with hard boundaries and few ecotones. The former is generally more ecologically valuable than the latter. However rich a silvopastoral system might be, however, it will almost certainly cause a net increase in greenhouse gas emissions, as the methane and nitrous oxide produced by ruminant livestock is likely to outweigh any carbon sequestration achieved by tree growth.
QUESTION 6: What should the Government consider in identifying suitable locations for spatially targeted incentives?
Sub-Topic A: Government should be guided primarily by the potential agricultural productivity of the land. Incentives for rewilding should be concentrated in places with low productivity, while more fertile land should be retained for food production.
Sub-Topic B: I strongly support the aim in the Consultation paper of “renaturalising our water bodies and making space for water”, and this is something that government should encourage farmers and land managers to do. Not only does this greatly enhance ecosystems, but it can also defend communities from flooding and reduce water pollution.
Buffer zones around rivers simultaneously filter out pollution and create wildlife corridors. Riparian habitats are often very ecologically rich. To the greatest extent possible, land management should strive to ensure that such buffer zones are continuous, enabling wildlife to move up and down entire river catchments.
Natural flood management offers some highly cost-effective and ecologically-beneficial forms of flood control. Techniques include decanalising rivers, permitting them to braid and form meanders, riffle sections and pools; reconnecting them to their floodplains where water can safely be stored; building leaky dams (or allowing beavers to do it for us); and increasing the general hydraulic roughness of the landscape, by allowing the return of trees and other dense vegetation. All these interventions (or de-interventions) help to slow the flow of water through catchments, attenuating flood peaks and reducing risk for communities downstream, often at far lower cost than investment in hard-engineered flood defences.
The government should resist pressure from farmers and other landowners to dredge and straighten rivers, as this not only greatly reduces their ecological value, but also raises flood risk downstream. Internal Drainage Boards (IDBs), which are riddled with conflicting objectives and conflicts of interest should be dismantled in favour of more democratic bodies whose primary purpose is flood control. Ideally these bodies would be integrated into local authorities, which, after all, provide much of the money being used, often harmfully, by the IDBs.
QUESTION 7: What approach(es) could most effectively support land managers and the agricultural sector to steer land use changes to where they can deliver greater potential benefits and lower trade-offs?
Sub-Topic A: The subsidy regime encouraging these land use changes should be generous, predictable and reliable. The recent Sustainable Farming Incentive fiasco exposes the danger of unreliabity in the provision of incentives, which generates disillusionment, loss of trust, anger and the abandonment of ambition. Land managers need to be able to plan several years into the future, especially if they are investing in plant, equipment and premises. It should be worth a land manager’s while to transform an agriculturally-poor landscape into an ecologically-rich landscape. They should be secure in the knowledge that this switch will continue to be an economically rational decision for years to come.
Sub-Topic B: I am glad to see the Analytical Annex note that “In some areas, there are deeply held beliefs about certain land uses being part of the aesthetics of rural landscapes. This hinders the adoption of changes perceived to negatively affect landscape character and local farming communities.” This is a significant factor impeding positive change. All too often, central government, National Park Authorities, local authorities and others have deferred to these beliefs at the expense of environmental quality, sensible spending priorities, flood control and other public goods. Our deforested and impoverished hills, grazed to the quick, might appeal to some people’s aesthetic sensibilities, but they are the product of many years of destructive land use, which urgently needs to be reversed.
QUESTION 8: In addition to promoting multifunctional land uses and spatially targeting land use change incentives, what more could be done by Government or others to reduce the risk that we displace more food production and environmental impacts abroad? Please give details for your answer.
Please see my answer to Question 4.
QUESTION 9: What should Government consider in increasing private investment towards appropriate land use changes?
The government’s timing in making this proposal could scarcely be worse. It hopes to increase private investment in “nature markets” just as those markets are facing a credibility crisis and, in many cases, collapsing as a result. Measurement, Monitoring, Reporting and Verification (MMRV) have failed spectacularly in recent months across almost all climate and nature “asset classes”. Only a fraction of the land use change through market mechanisms that the previous government anticipated has materialised: according to Wildlife and Countryside Link, the biodiversity net gain scheme has delivered a mere 773 hectares, just 13% of the habitat the government believed was likely to be created by this means.
The credits industry is riddled with wishful thinking, malpractice, false accounting and outright fraud. After years of bitter experience in several parts of the world, I think we can fairly state that these problems are intrinsic to the business.
A misplaced faith in market mechanisms to deliver public goods, coupled with a naive belief that they can reduce the amount of public money spent, will deliver not the cheap and efficient solutions government seeks, but another series of expensive failures. It would be better to recognise this now before committing further political and financial resources to an approach that seems bound to fail.
QUESTION 10: What changes are needed to accelerate 30by30 delivery, including by enabling Protected Landscapes to contribute more? Please provide any specific suggestions.
Yes to all these:
● Strengthened Protected Landscapes legislation (around governance and regulations or duties on key actors) with a greater focus on nature
● Tools: such as greater alignment of existing Defra schemes with the 30by30 criteria
● Resources: such as funding or guidance for those managing Protected Landscapes for nature
Sub-Topic A: A key issue I did not address in my answer to Question 1 is that of new woodland creation. The government is making a major mistake in relying on “tree growth potential” as a guide to where woodland should be allowed to return. This might be an appropriate metric for forestry, as it shows where trees can grow straight and tall. It is an entirely inappropriate metric for ecological restoration. There is nowhere too high for trees to establish in England, and gnarly woods in the hills are no less valuable habitats than straight stands of timber in the lowlands.
By relying on such an inappropriate metric, the government has set up a series of entirely unnecessary conflicts. The map showing the Relative Potential for Broadleaf Tree Growth across England in 2050 in the Analytical Annex (Figure 2) is something approaching a comic masterpiece: an almost perfect inversion of where common sense would lead us. All the places where new woodlands could be established with the least conflict with productive agriculture, and in which some of Britain’s most depleted and diminished habitats (such as temperate rainforest and carr) could be restored, are marked as “unsuitable” on the map.
Instead, woodland creation is directed by this inappropriate metric to fertile agricultural land. As a result, as subsequent maps in the Annex (Figures 7, 8 and 9) show, the potential for reforestation using the “tree growth potential” criterion is extremely limited, because of the clash with food production. But if the government used a sensible metric, that shows the potential for ecological restoration, rather than the potential for growing timber, a very large area of land, particularly in the unproductive uplands, becomes available for woodland restoration.
Given that ministers in the previous government recognised, when the mistake was pointed out to them, that tree growth potential was the wrong metric, it is particularly frustrating to see it brought back into play.
Sub-Topic B: To make matters worse, the Consultation and its Annex refer only to tree planting, rather than to natural regeneration as a means of woodland restoration. Tree planting is expensive, labour-intensive, and can cause considerable environmental damage, in the form of drainage ditches, hole digging, machinery wheelings and the use of plastic guards, zipties and tanalised stakes, which in many cases are left in situ.
Natural regeneration, on the other hand, is far less intrusive and can cost nothing at all. Trees turn out to be quite good at self-seeding, which could be why they have survived for 360 million years.
It is true that, in some places, natural regeneration is difficult, either because the areas targeted for forest restoration are too far from the nearest surviving seed sources, or because of an overabundance of deer, or because of a failure to exclude livestock. Deer control in the UK has been greatly neglected, with the result that, in the absence of natural predators, their populations now make woodland restoration and even maintenance more or less impossible in some parts. Getting a grip on this issue should be an urgent priority.
Even so, natural regeneration in many places remains possible and desirable. We should apply a hierarchy of decision-making. Natural regeneration should be the first choice; followed, if that is not possible, by assisted regeneration (for example, protecting self-seeded saplings and suckers, or clearing competing vegetation from around them until they achieve sufficient size); followed, as a last resort, by tree planting. But despite years of advocacy for better policy, the government, as the Consultation paper shows, remains fixated on tree planting as a first resort. Financial incentives should change to encourage a rational decision-making hierarchy.
Sub-Topic C: It also seems to me that there is a pressing need to update some of our conservation objectives, including the Ratcliffe Criteria, to reflect enhanced ecological and paleoecological understanding, and to restore missing habitats overlooked or neglected by generations of ecologists, such as temperate rainforest and upland carr. We should also challenge certain shibboleths, such as the belief, common among botanists but clearly refuted by taphonomic evidence, that Scots Pine is not native to England or Wales. We need to raise the ambition and scope of ecological restoration and to cease being constrained by arbitrary and very time-limited baselines. There is no ideal state of nature, and it is certainly not that which prevailed three generations ago, which all too often appears to be the baseline many conservationists, in and out of government, use.
QUESTION 11: What approaches could cost-effectively support nature and food production in urban landscapes and on land managed for recreation?
Sub-Topic A: By far the most effective and consequential intervention the government can make on land managed for recreation is to ban driven grouse shooting. For grouse shooting to be economically viable, it needs to inflict ecological devastation on the hundreds of thousands of hectares of upland England it occupies. Damaging management practices include drainage, burning, elimination of vegetation types other than a heather monoculture and mass killing of predators, some legal, some otherwise, but in all cases destructive of ecological diversity, function and integrity. (After all, why, to give just one example, is the indiscriminate slaughter of stoats and weasels, fascinating and intelligent animals which play a crucial ecological role, permitted?).
In the absence of human intervention, heather tends to be a sparsely-represented understorey species (ie growing under trees). But thanks in part to the grouse shooting lobby and its influence over conservation objectives, “heather moorland”, which tends to mean treeless areas dominated by a single species, has come to be treated as a priority ecosystem. In reality, it is an artefact of deforestation. It is reminiscent of tropical ecologies in which rainforest has been repeatedly burnt, cleared and grazed, enabling a single species of tough, wiry vegetation to predominate. The obsession with moorland in this country, much of which has taken the place of temperate rainforest (forest wet enough to sustain epiphytes) is ripe for challenge.
All land burning, except for the creation of firebreaks in the very few situations where this might be necessary, should be prohibited. This should cover not only the burning of deep peatlands, but of all the areas currently managed for grouse, as well as those blighted by “swaling” (burning of woody vegetation to make way for sheep grazing) that continues to cause major ecological damage on Dartmoor and Exmoor. Burning is not an ecologically-appropriate form of land management in any part of the United Kingdom.
Sub-Topic B: I believe there is also a strong case for curtailing pheasant shoots in this country. The exotic, omnivorous birds they release in the tens of millions work their way through ecosystems, eating everything from frogs, lizards, baby snakes, small mammals and young birds to insects, spiders, molluscs, fungi and wildflower seeds and seedlings. The management of land for pheasants also involves the mass killing of predators and competing species, while the shooting scatters very large amounts of lead, a toxic metal, across the landscape. To make matters worse, pheasant release is an almost perfect formula for maximising the spread of diseases such as H5N1 avian flu, as intensively-reared birds are brought into contact with a very wide range of wildlife and livestock, as well as human beings. Pheasant shooting, as well as being astonishingly cruel, as many birds die of their wounds, is a major ecological blight and health hazard. It is hard to see how any of this, which serves no essential purpose, can be justified.
Ending these practices would make very large areas of land available for ecological restoration and improvement, helping the government achieve its 30×30 objectives.
QUESTION 13: How can local authorities and Government better take account of land use opportunities in transport planning?
It seems strange that this question is within the scope of this consultation, while 87% of land in England is not. It reinforces the sense that some of the decision-making behind this consultation is arbitrary and hard to read. However, an excellent land use opportunity in transport planning is to stop building major roads. Road building is simply incompatible with our climate and nature targets, and government should encourage a shift to other transport modes.
QUESTION 14: How can Government support closer coordination across plans and strategies for different sectors and outcomes at the local and regional level?
I believe there is an argument for designating river catchments as the appropriate political unit for land use decision-making. At present, decision-making boundaries (counties, agency regions etc) cut across catchments, making flood control, pollution control, landscape connectivity etc harder to achieve.
QUESTION 15: Would including additional major landowners and land managers in the Adaptation Reporting Power process (see above) support adaptation knowledge sharing? Please give any reasons or alternative suggestions
Yes, large landowners (100ha +) should be included in the ARP. The ARP should also be expanded to cover, for all parties, not only climate adaptation, but also climate mitigation and ecological restoration.
QUESTION 20: Which sources of spatial data should Government consider making free or easier to access, including via open licensing, to increase their potential benefit?
I am very pleased to see the proposal in the consultation to make more of the data held by HM Land Registry “free to access”.
QUESTION 21: What gaps in land management capacity or skills do you anticipate as part of the land use transition? Please include any suggestions to address these gaps.
Yes to “Environment and forestry”.
Sub-Topic A: Levels of ecological understanding in the UK are in general extremely poor, including among many landowners and within government. Outright myths and misunderstandings are all too often treated as fact. Fundamental principles are unknown to most or widely misunderstood.
I strongly welcome the adoption of the Natural History GCSE. I would also like to see ecological principles featuring more strongly in basic science and geography teaching (Years 7-9).
Sub-Topic B: A particular deficit in almost everyone’s education is an understanding of the principles of complex systems. Everything of material importance to us – the human brain, the human body, human society, ecosystems, the atmosphere, the oceans, the financial system, the food system – is a complex system. Yet, when we are taught about them, we are taught as if they are simple systems, sometimes with circuit diagrams and flow charts. This is highly misleading. One result is that the behaviour of these systems repeatedly takes us by surprise. This is particularly the case in ecology, where instead of the smooth, linear progressions we would expect from a simple system, we see sudden tipping from one equilibrium state to another in response to environmental stress.
The basic principles governing complex systems are not hard to understand or to teach. They are common to all the systems I’ve mentioned here. In the absence of this instruction, it is difficult for any of us to make rational and appropriate environmental decisions.
Sub-Topic C: I would also like to see ecological training programmes offered to farmers and other land managers by government. While some farmers have a high level of ecological understanding, others appear proudly ignorant of even the most basic principles of ecology, hydrology and soil science, and make public statements on these matters that should alarm anyone with an interest in these issues.
Some farmers are unable to distinguish even between the tree species on their land. In the film Six Inches of Soil, for example, a well-known sheep farmer repeatedly identifies hazel as birch. Many farmers, to judge by my interactions on these topics, appear to believe that the treeless state of the hills is both natural and desirable, or that a clover ley is a rich ecosystem. There seems to be a very weak understanding of ecological data and principles. I don’t blame anyone for this, but it is hard to see how wildlife and habitats can be better protected unless the level of knowledge is raised.
QUESTION 23: Should a Land Use Framework for England be updated periodically, and if so, how frequently should this occur?
Yes to “every 5 years”.
QUESTION 24: To what extent do you agree or disagree with the proposed areas above? Please include comments or suggestions with your answer
This question is poorly worded. By “areas”, do you mean subject areas or land areas?
Assuming it means subject areas, I am disappointed to see no question about the Community Right to Buy that the consultation proposes for the first time in England. I strongly support this proposal.