Chartered Institution of Wastes Management
CIWM
Sustainable uses of resources and waste management.
ID: 05829149535-55
Lobbying Activity
Response to Soil Health Law – protecting, sustainably managing and restoring EU soils
3 Nov 2023
General Recommendations Article 1 CIWM Ireland recommendation that the SML should include a clear legally binding obligation for Member States to achieve healthy soils by 2050, alongside intermediate targets for 2030 and 2040. Article 17 CIWM Ireland recommendation that to finance EU wide protection and restoration of soil health and the sustainable use of soils, the Soil Law should establish a link to the CAP and to future reforms of the CAP which should reward farmers for good stewardship of land and natural resources and for the delivery of ecosystem services. Additional article on finance CIWM Ireland recommendation. One of the key aims of the directive is to improve soil health, while at the same time promote food security. To date food production assessments are based on the yield / hectare, with no assessment of the nutrient content of the food produced, tying soil health to nutrient density of food and related CAP payments, would have EU long-term benefit. 1. Soil Health Definition The definition of soil health must be stated in terms of its capacity to provide ecosystem services as a fundamental concept that should not change over time and should appear explicitly as such in the text. In contrast, the definition of soil health as a combination of biological, chemical and physical indicators must be clearly stated as an operational definition that should be revised as scientific knowledge advances. CIWM Ireland recommendation. It would be more accurate to define soil health as the current provision of ecosystem services by a soil, compared to the capacity of that soil to provide ecosystem services under optimal conditions, following the definition provided by the SIREN project (H2020 EJP Soil programme) and to include standard chemical and physical properties of healthy soils considered at timely intervals to reflect scientific advances. It must not be a one shoe fits all approach. 2. Soil Districts According to the associated Impact Assessment, the monitoring grid will establish approximately 210, 000 sampling points. Even though this represents a significant increase from the current situation, this is not sufficient to create a complete overview of soil health across the EU and lead to concrete action. CIWM Ireland recommendation. Soil samples for general agricultural use under the Nitrates Directive are taken in a W pattern at a minimum frequency of one sample for every 4 to 5 hectares to a depth of 10 cm. These samples take 15 to 20 minutes and are easy to take. The top 10 cm is an active biological layer, the benefit of measuring carbon content in this layer is debatable, however, if it is measured in conjunction with soil inorganic carbon and the trend over time shows that soil inorganic carbon is increasing, its an indicator of a positive trend. Article 9 CIWM Ireland recommendation is to ensure that soil health data and assessment is communicated to the relevant landowners and managers by default. This would enable farmers to make use of this data, to increase their knowledge of the biodiversity in their soil and empower them to adopt more sustainable practices. Sustainable Soil Management CIWM Ireland recommendation is that the proposed SM law should establish a set of mandatory sustainable soil management practices for all land and soil users, building on the conditionality rules currently set by the CAP. These should include at least Good Agricultural and Environmental Conditions (GAEC) on sustainable soil management practices (GAEC 5, 6 & 7), but also conditionalities regarding climate change (GAEC 1, 2 & 3), water (GAEC 4) and biodiversity (GAEC 8 & 9), all of which have an important impact on organic matter build-up, soil pollution run-offs or soil biodiversity. Contaminated sites CIWM Ireland recommendation. It is positive that Annex I of the proposal includes the concentration of heavy metals in soil as one descriptor for soil contamination when assessing health of soil.
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