Land use conversation is welcome but won’t deliver without a legislative framework

A national conversation on land use is long overdue. The UK government’s proposed Land Use Framework is a crucial first step in ensuring our finite land is used efficiently to meet our legally binding climate and nature targets and our nutrition security goals. But all the evidence and guidance in the world won’t deliver what’s required without a legislative and governance framework. The Land Use Framework as proposed doesn’t deal with one of the biggest problems we have: our land is overallocated with too many different plans relying on using land in ways that don’t fit together or add up. The priority should be to ensure plans for land use, farming, climate and nature all fit together. What’s more, the ways the UK is looking to solve this problem at home would rely on unsustainable land use and would cause environmental damage overseas. In contrast, a Living Planet Act would provide a process for aligning and managing demands on land and sea and hold plans together, so the UK government would speak with one voice when it comes to food, climate and nature.

The consultation and Land Use Framework has started a conversation about land use, to minimise trade-offs and optimise the use of our land. It recognises that at a national and local scale, we need better spatial planning. It also recognises that our natural world is under threat. England is one of the most nature-depleted countries in the word, and the impacts of global warming threaten our land and the livelihoods that depend on it. The Land Use Framework aims to create a toolkit to support decision making and inform discussion on how we use land for nature and climate, housing and infrastructure development in a way that protects prime farmland.  

In respect of land that changes use or management (totalling 19% of agricultural land), this guidance supports the delivery of a fair and evidence-based land use transition that is very much needed. We welcome the analysis and the opportunity to input into the consultation. However, within “Category 1 land management change i.e. changes in the way the land is farmed, without introducing new habitats or planting trees” (totalling 81% of agricultural land), analysis is sadly lacking. This is because it falls outside the scope of the consultation. At WWF, we’re concerned that a Land Use Framework that doesn’t address changes across most agricultural land will be a job half done.  

Food production, measured primarily in terms of tonnes of food produced, has been the highest priority in determining land use in England since World War Two. Covid-19, the war in Ukraine and the threat of trade wars have caused a renewed concern about food security. The UK government’s Land Use Framework consultation has expressed a commitment to maintain food production. It also briefly nods to pressures such as demand for land to produce feedstocks. But by regarding food security simply in terms of the quantity of food produced, there’s a risk we would unbalance the land use equation. Shifts in food consumption towards less and better meat and dairy are key to reducing existing demands and trade-offs for land. Our best agricultural land should be prioritised for food, not for animal feed or biofuels. Our Future of Feed report outlines how reducing the volume of crops we feed to livestock would free up millions of hectares of land to grow highly nutritious food for people, while also opening up new space for nature.  

Similarly, the consultation nods to new pressures, such as demand for land for biofuels and other forms of renewable energy. Our Beyond BECCS report shows it’s possible to achieve net zero with far lower levels of Bioenergy with Carbon Capture and Storage than currently planned by the UK government or the Climate Change Committee. BECCS requires vast amounts of land, either to cut down trees from forests or to grow energy crops – several orders of magnitude greater than the land needed for producing the same energy from wind and solar, and in direct competition with nature and food production in the UK or overseas.  

Another crunch point for land use is the future of lowland peatlands, some of England’s most fertile soils but with huge potential for carbon storage and nature restoration. The consultation analysis recognises that some growing will need to give way to restoration and maintenance of peat-forming and peat-dependent habitats, or a shift to responsible management of peat. Our research on lowland peat identifies that a mosaic approach would achieve multiple benefits, including sustainable vegetable production in some areas, while raising water tables in others to support cultivation in rewetted peatlands or restoration. The Land Use Framework should encourage multi-functional use of lowland peat for climate, nature and sustainable food production, while discouraging the use of peaty soils for feed or low nutrition crops such as sugar beet. But no such hierarchy has been considered in the consultation analysis.

Imported food also needs consideration, otherwise there’s a risk of offshoring environmental impacts elsewhere and undercutting the transition by UK farmers to more sustainable farming. We are pleased to see the UK government is interested in reducing the risk of displacing food production and environmental impacts abroad and has questions on that point in the consultation. The UK’s forthcoming Trade Strategy needs to support sustainable and resilient land use in the UK and overseas. At WWF, we’re also proposing Core Environmental Standards that would set a minimum environmental threshold for imported agrifood products in domestic law. This would ensure goods produced overseas meet comparable environmental and animal welfare standards to those required of UK producers.  

The Land Use Framework consultation estimates the need to change the use of 9% of England’s total agricultural land area, to instead support peatland restoration, woodland creation, and the creation or restoration coastal and lowland heathland habitats, etc. It estimates a further 9% should change for both food and environmental and climate benefits, and 1% should undergo small changes while maintaining the same agricultural use. These changes would be offset by productivity improvements in the remaining 81% of agricultural land. Whatever view you take about the likelihood of achieving those productivity gains, or whether we need to develop better measures of productivity, any target needs to be accompanied by measures to manage our consumption footprint so the pressure on the remaining land doesn’t simply spill over onto land overseas.  

On its own, a Land Use Framework was never intended to guarantee delivery of our nutrition security goals and climate and nature targets. And it is supposed to interact with other foundational strategies Defra is developing – the Environmental Improvement Plan, a 25-year roadmap for farming, and a food strategy. Across government, the framework will interact with other areas of policy including planning, energy and trade. But even taken together, we are still missing an accountability mechanism to ensure there will be effective use of our land and seas, and that collectively their use meets our shared climate, nature and nutrition goals. It also doesn’t take into account our use of land and sea abroad, or our negative impact on other countries.  

We believe it is the responsibility of governments to produce plans that clearly demonstrate how we will manage the use of our land and sea resources to meet our climate, nature and nutrition security commitments. To do that, WWF is proposing a new piece of Westminster legislation – the Living Planet Act.  

To use a nautical analogy, the Living Planet Act would be the vessel that delivers what a Land Use Framework would guide as a compass. The Living Planet Act would create a legal requirement for the UK government to set out how its plans bring together the co-benefits and compromises to best use the precious but limited land and sea in England. And it would ensure that the impacts of those decisions do not ‘offshore’ the problem by passing them on to other parts of the world, or even other parts of the UK.  

The Act would also establish a new committee to provide independent advice on the science and the various policy pathways needed to meet the ‘triple challenge’ of tackling the climate crisis, reversing nature loss and meeting our food needs. This would work alongside existing bodies such as the Climate Change Committee and the Office for Environmental Protection, with a new remit to hold the government to account for the integrated delivery of the three objectives of the Act.  

No country in the world has yet set out sufficient plans to meet the triple challenge. Adopting the Living Planet Act is a unique opportunity for the UK to take a clear lead on this crucial front.